ML18017A293

Provides Responses to Improved TS Section 3.8 Per 970324 NRC Rai.Schedule 980628 for Improved TS Implementation. Submittal of Revised Specifications Is Planned for Jan 1998

ML18017A293
Person / Time
Site:	Susquehanna
Issue date:	01/06/1998
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PLA-4814, NUDOCS 9801140015
Download: ML18017A293 (299)

Text

CATEGORY 1 REGULAT RY INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9801140015 ACIL:50-387 Susquehanna DOC.DATE: 98/01/06 Electric Station, Unit NOTARIZED: NO DOCKET I Steam 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsy va 05000 88 AUTH. NAME AUTHOR AFFILIATION BYRAM,R.G.~ ~ Pennsylvania Power a Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

'Provides responses to improved TS Section 3.8 per 970324 NRC RAI.Schedule 980628 for improved TS implementation.

Submittal of revised specifications is planned for Jan 1998. A DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR i ENCL i SIZE: T TITLE: OR Submittal: General Distribution E

NOTES: 05000387 G

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 LA 1 1 PD1-2 PD 1 1 NERSES,V 1 1 INTERNAL: ACRS 1 1 FILE ling ~01 1 1 NRR/DE/ECGB/A 1 1 bE/EbICB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 TERNAL: NOAC NRC PDR 1 1 D NOTES:

E N

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK tDCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 14

lP k i 1

ert G. Byram Inc Senior Vice President 'wo North NinthL,Street aaa g II r Generation and Chief Nuclear Officer Allentown, PA18101-1179 ponos O~~

Tel. 610.?74.7502 Fax 610.774.5019 Tel. 61 0.774.5151 e,

0 o E-mail: rgbyramepapl.corn http Jhwww.papf.corn/

p ~i JAN 06 1998 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P 1-137 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO IMPROVED TECHNICALSPECIFICATIONS REQUEST FOR ADDITIONALINFORMATION(RAg Docket Nos, 50-387 PLA-4814 FILES R41-2/A17-2 and 50-388

References:

1.) Letter, C. Poslusny to R .G. Byram, "Request for Additional Information (RAI) Regarding the Technical Specification Change Request to Convert to the Improved Technical

" I Speci Jications (PLA-4488). Susquehanna Steam Electric Station, Unit and Unit 2 (TAC No. 's M96327 and M96328) dated March 24, 1997.

2) Letter, C. Poslusny to R G. Byram, "Request for Additional Information (RAI) Regarding the Technical Specification Change Request to Convert to the Improved Technical I

Speci Jications (PLA-4488)." Susquehanna Steam Electric Station, Unit and Unit 2 (TAC No. 's M96327 and M96328) dated April I, 1997.

3) PLA-4797, "Reply To Improved Technical Specifications Request For Additional Information (RAI)"dated November 26, 1997.

The purpose of this letter is to provide PP&L responses to Improved Technical Specifications (ITS)

Section 3.8. Attachment I contains the Section 3.8 responses, which along with reference 3, provides the complete PP&L response to rcfcrcnccs I and 2. We trust that thc Commission will find the responses acceptable.

As indicated in reference 3, wc have scheduled June 28, 1998 for ITS implementation. To support our schedule, we plan to submit revised specifications in January 1998 incorporating agreed upon changes and updates including generic changes to the standard specifications.

PP&L is willing to provide whatever assistance is required to ensure that this amendment and thc included provisions for 24 month operating cycles can be reviewed in a timely manner in support of our schedule to implement on June 28, 1998.

Please contact us ifyou have any questions or concerns regarding this schedule. Any questions should be directed to Mr. M. H. Crowthers at 610-774-7766.

Sincerely,

'l

..By Attachments 8

e801.1.400~5 e80106 Nllllttllllllltl3ltlllllll ADOCK 05000387 Ii'DR P PDR,

FILES R41-2/A17-2 PLACS14 Document Control Desk copy: NRC Region I Mr. K. Jenison, NRC Sr. Resident Inspector Mr. V. Ncrses, NRC Sr. Project Manager Mr. K. Kerns, Pennsylvania DEP/BRP

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SECTION 3.8 NRG RAls SSES Improved Technical Specifications iTEM k DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 3.8.1 AC Sources Operating

.8.141 PD NUREG hange Pd does not include any of the CTS material 11I20187: After discussions Proposal to make the following Closed (NRC page 3.8~ regarding when and how the LCO Actions for 1 DG th NRC, PPL has revised ording changes for clarity: "When closed 1 inoperable are entered. See also consnents re: P.3 in 3.8.1 Action Note to clarify an OPERABLE diesel generator is 11r21/87)-PPL Bases consnents. re uirements. placed in an inoperable status solely II provide for the purpose of alignment of diesel SSES ITS INL enerator E to or from the Class 1E distribution system, entry into associated Conditions and Required ions may be delayed for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> provided both offsite circuits are OPERABLE."

e new wording provides the following restrictions: Willonly apply for transferring an OPERABLE DG, only apply during the ransferring of DG E, and only applies when both offsite circuits are OPERABLE. This allowance made re restrictive (Discussion of Change M.6) for the implementation of SSES ITS, is part ol SSES's current lice~nsin bases.

NRC RAIs -. SSES frtgurrvvd Teclrrnc~f Spvcrhc,4bcurs 24-Nov-OT Page1of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM 0: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

)3.$ .14~2 PA NUREG LCO 3.$ .1 Condition B- Change PA is Not Acceptable. See NUREG 1433 MIU Page B 3.84. OpenARC to page 3.8- s proposed, the SSES ITS takes the best parts of the constructed, NUREG 1433 Section review PAL 3 NUREG-1433 and CTS. This is not the intent of ITS 3.8.1 for an Offsite Source does not response onverslons. Either take the NUREG totally, or retain require for an OPERABLE Offsite ich TS totally. [Proposed TS adopt Req. AcL B3.1. AND Source that all ESF Buses be capable provides M/U ify Req. AcL BD2 to reflect CTS] Insert corrxnent of being powered from an Offsite of SSES ITS re: Action C.1 and DOD P.3 from Bases corrsnents Source. NUREG 1433 identified that and new L17 a single feeder breaker to an ESF Bus 'OC.

could be inoperable and the ssociated Offsite Source still be considered OPERABLE. This is also consistent with and more clearly stated in the PBAPS ITS as follows:

An OPERABLE qualified Unit 2 offsite circuit consists of the incoming breaker and is connect to startup and emergency auxiliary ansfonner, the respective circuit path to the emergency auxiliary transformer, and the circuit path to at least three Unit 2 4 kV eniergency buses including feeder breakers to the three Unit 2 4 kV emergency buses. If at feast one of the two circuits does not provide power or is not capable of providing power lo all four Unil 2 4 kV en>ergency buses, then the Unit 2 4 kV emergency buses that each circuit powers or is capable of poweriiig cannot all be the same (Le., Iwo feeder breakers on one Unit 2 4 kV emergency bus cannot be inoperable)."

PAL changed lhe NUREG 1433 definilion of OPERABIUTY for an "Olfsite Source". This change required changmg some ctlons/Notes in NUREG 1433.

PAL is now reconsideriiig this initial change and will rnostlikely adopt a delinilion nl OPERABILITY for the Ollsilc Soiuce similar to PBAPS and

<<<ta><< ilic ltcquired Aclions dcluicd <>n>>iiu C<<nd>l<<<<>G. Thischan e HRC RAls - SSES Irr>>f>rvvert Ter rinrr af Sfm >r dl>una 24.Nov-97 Page 2 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS is acceptable understanding that SSES ITS Condition G will be ddressed because in a condition no OPERABLE Offsite Source or DG to a single ESF Bus, only one ffsite Source will be considered inoperable.

Specifically, PPE L will address the issue of having a single buslloss of single offsite source for one ESF Bus indefinitely.

PP8 L willprovide a revised SSES ITS Wtj to incorporate changes to the definition of an offsite source/circuit and add Actions to SSES ITS 3.8.1.

HRC RAls - SSES lrnyruvvtf 1 eclirirt.ar Sf~rfrt ~ f> tsuuies ut oiic ESF bus feed bieakers. This is nul a likely sceiia<<ii. More discussion is required.

J NRC RAls "SSE 5 Irr>pruvvd f vi rinia ~l b)wt IIILolfiuns j4'tAJv 97 Page 4 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM 0: DOCIJFD: TS LCO'ESCRIPTION OF ISSUE'RC COMMENTS: SSES RESOLUTION: STATUS K6.64~4 ~P.6 RUREG LCO 3.8.1, Condition F- Change P.6 deletes NUREG See NUREG M/U page B3.840, Insert Closed (NRC page W- Condition F. This is acceptable because SSES uses 02. The individual load sequencing closed individual bmers. However, DOD P.6 includes a timers provide protection for the 11/20/87)-

statement that failure of a timer would inop. the offsite source or a DG by properly PP8 L will associated DG or offsite source. Is this correct? If it sequencing the loads. If a timer is provide a M/U is, this LCO and alt others in the SSES ITS Section 3JI inoperable, the affected offsite of SSES ITS.

need some serious revision. source will be declared inoperable based on not meeting a Sureveillance Requirement for the affected Offsite Source (explicitly stated in SSES ITS Bases for SR 3.8.1.18). Therefore, Conditions for an inoperable Offsite Source or a DG would be entered in h>s case PPS L will revise SSES ITS Bases for SR 3.8.1.18 to specifically identify at different affects failures of the Offsite Timers will have on the O>erahrlilg el lhe hmpa~cled s slams.

[3.8.14S NUREG LCO 3.8.1, Cond>tion H- Change P.? is acceptable ~IThis issue is addressedunder Repeat, see I P.? I page 3.8- except lor the part about "reasons other than [resolution of NRC RAI 3.8.142. J NRC RAI 3.8.1-02 for Condition G." Proposed Condition G is not acceptable as discussed above. Therefore, this resolution.

reference lo it is also Not Acceptable.

" SSf S /n>yruvarf Tacl>>>>a~> Sl>>N >f>r ~f>u>>s 24.Ho v-97 Page 5 of 75 HRC RA/s

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM fl: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~S.M~6 ~PS NUllEG SR 3.8.12 - Change P.8 is acceptable in concept. g SRpability 3.8.1.2 is performed to verify the Closed (NRC page 3.8- However, the SR does not make any reference to of the DG only. The SR closed alternating the SR behveen units; Le., conducted from does not test any Unit Specific 11/20I87)

Unit 1 for one SR and from Unit 2 for the subsequent design feature. Therefore, PAL performance, etc. The submittal should be revised to does not see the need to specify that reflect this. the test will be performed on alternatin units.

~8.147 ~P.11 NUREG SR 3.8.1.3 - Change P. 11 is acceptable except for the Review and discussion of this NRC Closed INRC page 3S- last pari of Note 8. As stated, the last part of the Note RAI identified that as stated the Unit closed otally negates the beginning requirement to alternate 2, SR ML1.21 Note, is acceptable in 11I20IST)+PL between Units. This is Not Acceptable. The submittal that it provides an acceptable ill provide should be revised to address this issue. allowance for Unit 1 3.8.1 SR not to MIU of SSES be perlormed when not required by ITS.

Change P. 10 is Not Acceptable. See previous Unit 1 Techncial Specifications.

caivneols, PPL will provide revise SSES ITS to eliminate possibility ol misinterpretation.

NRC RAls -. SSES lrrclcrovc ct 1c c hcric el Slur cfic >fcucis 2<.Nov-g7 Page 6 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.$ .14$ M.11 TS M/U .8.1.12.f.6.b M.10, M.11, 4.8.1.12.d.6 -One part of 11/20/87: NRC reviewer See DOC M.11. The DOC identilies Closed(NRC page 3/i is change (Ledecreased frequency tolerance) is convnented on proposed that the limits are removed and dosed

$4 indeed More Restrictive. However, the deletion of the Discussion of Change L16. provides justification for the removal 11/20/97)-

upper voltage and frequency values is a Less his Information is being PP6L will Restdctive change. M-11 does not address this. The incorporated into SSES ITS PAL will revise M.11 to remove less provide submittal should be revised to provide a justification DOC L16. Once completed, restrictive change and define that revised CTS for the less restrictive as pect of the change, including NRC reviewer finds chan einanewL16DOC. M/U and M/U discussion of the Bases section that covers c cen c~Cange acce eagle. of 3.8.1 DOCs nitoring of the time to achieve steady state voltage ILL16 .

n ~rerLnenc~

8.148 M.1 TS M/U LCD 3.8.12m - Change M.1 indicates that a his change is shown on Unit 2 CTS losed (NRC page 3li requirement for Unit 10ffsite pwr sources is to be M/U ~e 3/i $ -1. closed 11/20/67) 4a added to the Unit 2CTS. However. no insert was included the 3.8.2 submittal. What is intended to be mcluded here?

HRC RAra - SSES rrrgrrrr crr 1car nr cr nrrccrrrrnrrac a 25-Nov 97 pagelof 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPT(ON OF 1SSUE: NRC COMMENTS: SSES RESOLUTION: STATUS SR 3JL1 Jt - Change P. 12 is Not Acceptable.

8.1-10 J LP.12 NUREG e Performance of this and other SRs have the potential PPE L has reevaluated their position nd willincorporate mode restriction Closed- (NRC closed for causing perturbations to the electrical power tor the following 3.8.1 SRs: 11/20/87) ~

systems and should not be done at power. PPSL will SR 3.8.1 Jt (Olfsite Source Automatic provide M/U e change form18 month to 24 month frequency is nd Manual Swap) 24 Months of SSES ITS outside the scope of ITS conversion. ln addition, it SR 3.8.1.11 (LOOP Test) 24 Months has not been adequately JustifierL (See consnents on SR 3.&.1.1$ (LOCA/LOOP Test) 24 CTS lielllu f4'hil ~lmue . Months SR 3.8A.T (Battery Service Test) 24 Months SR 3.8A.8 (Battery Modified Performance T~est 24 Months

)3.8.1.1 1 P.t HUREG Change P.S a Noi Acceptable. Generic change P.8 identiges the addition of "<= 10 Closed (NRC tati peuc ttwRGG.18. whrc4 ra tnc basis tor uus change, has seconds" into NUREG 1433 SR closed 3 84 rat bcwr accepted by the statt. I 3.8.1.2 (Month test). This is incorrect 11/20/87)ARC nd viilt be corrected in SSES ITS o review Final Submittal. See NRC RAI 3.8.1- PAL 23 (Removal of slow start response.

thodology for M/U at SSES ITS See NRC RAI pages) 3.8.1-23 lor M/U of SSES ITS.

NRC RAIs .- S.'rES Irrrfrruvr >g the CTS require/nant, i.e. PAL will "r>>a>>de>>ance whxh could alfect DG independence'. provide M/U A @peart~ Iusbteatron to( the change must be of DOCs.

Provetcd. or ratarn the CTS <aquucmenL 8'1 14 NUREG C hange P. 13 is confusing. Is il possible to load a DG 11/20/97: NRC Reviewer and tter further review, PPSL has Ctosed (NRC iiP 13 I determined thai a statement detining closed irage 3JI- o 4000 Kw while connected only lo an ESF bus? If PPL discussed the issue ot .

9 s o, please provide an explanation. It not. what is the esling DG E to its full additional loading of DG E should>>ot 11/20/97) purpose of change P. 13? capacity. It was agreed that be added to SSES ITS. The specific it would not be appropriate concern is that the Bases cannot The change in frequency trom18 months to 24 to incorporate this testing, conflict with the SSES ITS SR nths is Not Acceptable. good practice, inlo SSES requirements.

ITS. Ppl. did describe to NRC Reviewer the current No further action rerLuired.

testing practice at SSES for the reviewer's infonnatio>>.

HRC RAIs. ~ SSES Irr>pruvod 7sclsrui ~I Ipaxrhaifrrn/s 24.Hov-!I 7 Page&of 75

SECTlON 3.8 NRC RAls SSES improved Technical Specifications ITEM¹: DOCIJFD: TSLCO: DESCRIPTIONOFISSUE'RC COMMENTS: SSES RESOLUTION. STATUS

~4415 ~Pea RUREG What change re rhis RR is rerlecred hy DDD P 14? NUREG MJU page 3.0-10 will be Closed (NRC MIU Page revised to delete reference to JFD closed 3.8-10 P.14. 1 fnofgy)-

PAL will provide revised NUREG MIU.

Qs.s.ws ) ~r.n RDRRG Change P. 11 Is under staff review. As proposed, PAL will revise the SSES ITS Bases Closed (NRC tnsert 3.$ -1041 would allow DG E to be substituted to provide a clearer understanding of closed 10 for OGs AN without having demonstrated electrically y DG 'E'lesting is acceptable. 11norgy)-

that the substitution works. Perfonnance of this SR Specifically, the following changes PAL will in the test facility does not demonstrate this. II be made: provide M/U Consequently, ifmore than 18 months has passed of SSES ITS.

without an actual substitution and SR performance, 1. Change Bases table to identify he E OG must be considered inoperable, and it that when DG E is not substituted nnot be substituted for any of the other DGs. Since instead of stating "OG E" state that it the above discusinon is at odds with!he SSES CTS, is "not substituted tested on test lurther slatf review is required. facilily".

2. A more explicit discussion will be added to lire Frequency statement lo state!hat all "active components" are tesled every 24 months while some portions of the "passive components" are only tested once every 90 months. In addition, a stalement will be made why this is acceptable.

NRC RAIs SSI.S lrirprrjvurl leiflirrr~r Spg r rfrcifrurrs 2yf Nov-97 Page 10 of 75

SECTION 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS L81 3~7 ~P8 NUREG 8R38 113-88aapa P 8 la accaplaala as lac as ll )

JFD witl be changed to state that Closed (NRC e goes. However, it does not address alternate unit initiation signals from the different closed esting as described h Note 6 to SR 3.8.1.3. Units are tested by other testing and 11/2O/8 TI-this logic testing is unique to each PPYL will DG. provide M/U of JFD P.8.

L8.3-38 J~Naca NNRRG SR 3.8.1.16 - DG E's not addressed in the Notes for here is no specification for load in Repeat, see his SR. his requirement. Therefore, no need NRC RAI 3.8.1-13 for an exception for DG E'nd the 14 for est faciti~t. See NRC RAl 3.8.1-14. resolution.

t3.$ .1.19 P.1T stUHf. G SH 3.$ 1 1$ . Ctsange P.tf ii, Not Acceptable. The )

IAs stated in Note 2 to SR 3.$ .1.16, "a Closed INRC tpatte 3.$ - pinposed SR Notes do not uiclude any reteience to isingle test of each 4.16 kV ESS bus closed 14 Unit rotation such as descnbed us Note 6 to SR tat the specified FREQUENCV will 1 1/20/$ 7) 3.$ .1.3. Tlie subiiuual should be revised accordingly. satisfy this Sur veiltance". Theielore, this test is perloimed for each unique 4.16 kV ESS bus on both Units, no Unit rotation is needed because each

.16 kV ESS bus is tested every 24 months.

NRC RAls - SSES l/ttl)rtsvutf Tao/it Pi if Slsecsfscit 24 Nov-97 Page11of 76

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 8.1-20 P.14 NUREG SR 3.8.1.18 - Change P.14 is Not Acceptable. The 11/20/87: Additional See SSES ITS Page B3.843/34. This Open/Under page 3.$ - proposed change does not include the acceptance iscussion between NRC change was made to avoid confusion NRC 16 criteria from CTS ( 10'%f design setpoint.) This and PPL identified a concern ssociated with what equipment is Review)PP6L DOD also Incfudes a discussion of what actions are th relocation of the inoperable when a load Iimer is made ll provide appropriate when an individual timer is inoperable; cceptance criteria. NRC inoperable. NUREG 1433 identifies in revised CTS l.e., the actions associated with an inoperable AC reviewer had specific SR 3.8.1.18 that the load block are M/U and new source. This part of the DOD is Not Acceptable oncern that acceptance sequenced within the required time. DOC UL6 because 1) there is no corresponding Condition or criteria for OPERABIUTY NUREG 1433 Bases for SR 3.8.1.18 Required Action in LCO 3.8.1, and 2) the actions should not be relocated from identifies that the function of the load ssociated with the system/component made echnical Specifications. imers is to ensure voltage and inoperable as a consequence of the tkner failure PPL identified to the NRC frequency recover between events, should be followed, not the actions for an AC source. reviewer that other but does not state how and what parameters similar to the components are inoperable when a acceptance criteria for the specific load timer does not meet the timers has been relocated to SR. SSES ITS revises this SR to he Technical Specification address SSES design of individual Bases or other qualified load limers and identifies specifically documents. These at LCO requirement will be examples are as follows: rendered inoperable for a TS Timer being out of tolerance.

1. SSES CTS Table 3.6.3-1 contains closure times tor The 10k of design setpoint is

Primary Containment coveredby the change to an

Isolation valves. These "Allowable Value". To ensure a values are part ol the design complete discussion of the changes requirements for the PCIVs, a 3.8.1 DOC L/L6 will be added to but have been relocated lo address the relocation of the the SSES FSAR, because tolerances to the SSES ITS Bases.

SSES ITS SR 3.6.1.3.6 iequires verification of the isolation times and the information being relocated could be adequately controlled in the SSES ITS Bases

2. Power Distribution Limits (SSES ITS 3.2) relocate the specifc numbers lo the Core Operating Lknits Report.

3. Relocate piessuie/lempeialuie hmits lo the Piessuie Teinpeialuie I ends Rcport.

4 tic~Asucs>>l valve Iv 'blV i llol Cllalllv I>> i>>c NRC RAfs -. SSf S tiri>Nucleal f ~ v t>>>>c ~ i bt~raitir itiuiis 24-Nuv.97 Page 12of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM N: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS Primary Containment Leak te Testing Program.

The above cited examples demonstrate that it is the intent for the conversion to he improved technical specifications to remove detailed plant requirements en they can be adequately controlled in other regulatory controlled documents. It is PPL's position that because the conversion from SSES CTS o SSES ITS format is requiring a much more detailed table defining each offsite and onsite timer, the information is more appropriately controlled in Ihe SSES ITS Bases. This change can be made on a

,planl specific basis because iSSES is designed with lindividual load timers which I

have dillerent settings and Iunctions. Furthermore, because the information is being relocated to the SSES ITS Bases, the SSES ITS Bases Control program will ensure that any change to SSES ITS Bases willnot result in a change to the corresponding SSES ITS requirement to have these timers lunction and protect the associated AC Power Source.

NkC kAIS - SSf:5 Irrifirvveal li i biu al S]ice ifiatfir>(ia 24.wuv-97 Page 13 of 75

SECTION 3.8 NRC RAls SSES Improved Technicai Specifications ITEM ff: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.8.1-21 None NUREG Thts SR (sod dtt 3.e.t.\8) mustee Oertoooed foresee I SSES design includes individual losed (NRC page 3.8- unit. How is this accomplished within the required timers for each 4.18 kV ESF Bus. closed 16 frequency, assuming that one of the units Is ahvays at herefore, SR 3.8.1.18 is performed 11I20I97) ~

power? for each 4.18 kV ESF Bus. Therefore, PAL will esting can be performed as required provide MIU rough individual calibration of the of SSES ITS..

load timers.

his information willbe added into e Bases for SR 3 Jt.1.18.

HRC RA>> . SSES litic<<>v<<tf Xi~In>>cif Si~ifiLafio is 24-Nov-97 page f4of 75

SECTION 3.8 NRC RAIs SSES Im proved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS f 8.1-22

] NUREG page 3.&-

insert 3.8-1642- The proposed SR (SR 3.8.121) appears to be acceptable. However, the proposed 11I20I97r NRC reviewer raised question as to ether basis should be staled in the Note to Unit 2 SR A.121, this allowance is only Closed (NRC closed 16 Note regarding SR 3.$ .2.1 is Not Acceptable. The applicable for Unit 2 and only applies 11/2&IS 7) proposed Note brings into question the issue of a changed. After further to Unit 1 AC sources (when they are blanket exception to the definition of OPERABIUTY review, PPL determined that in MODE 4 or 6 or moving irradiated ithrespect to SRs. Seeconanentson CTS Markup Bases discussion was clear fuel assemblies) which are required for CTS SR 4.8.12 (ITS LCO 3.8.2) as to the requirements for o support Unit 2 Operation. This he note. No furlher change is necessary to ensure the changes were determined to allowance provided in SR 3.8.2.1 is be nacessar)~. Intained, and does not constitute "blanket exception" based on'the bove discussion.

Therefore, it is PP& L's position that e Note as written is acceptable. It should be noted that this same Note as incorporated into the PBAPS ITS.

PAL willrevise SSES ITS SR 3.8.121 Bases to more clearly state y tests are not required to be performed and while some tests are not applicable.

Atter review of SSES ITS, it is PP& L's posilion that the SSES ITS Bases rovides adequate information.

NRC RAls - SSf I lrtipruvvd I va firucwl Spvi ifia ~tiuris 24 Nov-97 page 15 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~&.t.&& Q ~t& CT& MIU page 8I4

.8.1.1.2.aA - Change (L4) is acceptable in concept.

However, the justification does not positively state Because SSES does not have the capability to perform a slow start losed (NRC closed 84 t SSES has the capability to conduct a modified oday and no immediate plans to 11/20IS7)-

start, and uses tlds capability. Absent this capability, incorporate this allowance, PPKL has PAL will all EOG starts must be fast starts, and the ITS should determined that this allowance will be provide a MIU not include any reference to modified start. removed from the SSES ITS. of the SSES ITS.

~&.&.t.&e

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B38-2

Background:

What is the reason for deleting the last part of the 1st paragraph on this page? Not the SSES eslgn?

PP8 L will revise the wording to reflect &&&&~desi e.

Closed (NRC dosed 11I21I07)-

PP8 L will provide MIU I SSES ITS.

(X8.1-25 NUttft ~ LCO: 2nd Paragraph The Bases ielers lo 2C 4 20 (NUREG MIU will be corrected to Closed (NRC SATs - is this correct? Should this not be S'l'10 and [address commeiit. closed Wit&'t2.$

4 ST 20? 11I20I97)-

PAL will I provide revised I

NUREG MIU.

RAIs" SSES Irt&provt tf Tucftri&cit Sf&ecrfit JfrU&ls 24-Nov-97 Page 16 of 75 NRC

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM¹: DOCIJFD: TSLCO: DESCRIPTIONOF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~6.6-26 P.2 RURRG Paction A.1, Insert B3.8441 - Pd The proposed Repeat issue, see NRC RAI 3 JI.141. Repeat, See page change does not include all of the material from the NRC RAI 3.8.1-B3JI4 Note In CTS (See also cogent on P.2 in NUREG 01 for up conanents). Also, note that the Bases can resolution not hnpose requirements such as that in the last sentence of the tnsert. Appropriate changes to both TS and the Bases should be made.

'he 8.1-27 P.3 NUREG ction A2 - P.3 The staff interprets this DOD as JFD P.3 need eliminated by Repeat, see page follows: The SSES design is such that the resolution of NRC RAI 3.8.142. resolution of B3.84 inoperability of a single offsite ckt. would not result in NRC RAI 3.8.1-a ESS bus wlo offsite power because of the automatic 02.

ransfer to the alternate AC source. If the automatic ransfer failed, this would constitute two (2) offs(te ckts inoperable even if power was available from the alternate offsite source. Is this staff interpretation correct? It so, this DOD should be revised to reflect this. As worded, the DOD is confusing j3.8.1.28 I.a.2 Cf 5 M.tJ a,8.11.3,a O>scuss>o>> UL2 >s Nol Acceptable, and )fRepeel,eeeleeolollooolRRC jRAI Repeal, see P<>ge 3>a uie assocMtcd cha>>gcs a>c also Not Acceptable. The l3.8.1-12 resolution of 84 d>scuss>on add>esses regulatory acuvilies NRC RAI 3.8.1-of GL 844ti thai will bc conducted

'implementation 12 (outside ol the ITS conversion process. The license amendn>cnt that impte>nents lhe ITS cau only address what exists at lhe time the amendmenl is issued. It cannot address future regulatory issues. The submiltal must be revised to provide a 'standalone Justification for the change, or CTS >equiremenls nust be retained.

NHC HAb - SERFS lrr>pru>pwf fR< ~ >>>i< ~ I Sip<a 6N< rt>u<> ~ ?4-Nuve97 Page170f 75

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~8.1-2~$ ~PA NUREG on C.1 - PA The staff does not understand the This issue will be addressed by NRC Repeat, see page part of this DOC which addresses deletion of Action RAI 3.8.142. NRC RAI 3JI.1-S3JI-10 C.1. What allowance in the SSES CTS is retainedby 02 for deleting Action C.1? The licensee should provide resolution.

additional explanation for this issue.

~JI.14D )

P.6 J NUREG page Insect M.8-1641- P.6 The Insert addresses a new .

Required Action G.1, but DOD P.6 addresses deletion his issue will be addressed under NRC RAI 3.8.142.

Repeat. see NRC RAI 3.8.1-BMI-16 of NUREG-1433 Condition F. The licensee should 02 for provide the appropriate DOD for the proposed inserL resolution.

lf DOD P.6 is the appropriate DOD, the see conanents re: P.6 for LCO 3.8.1 Condition D in NUREG markup.

l3'8' 4I P'20 HUREO SR 3 0 I I Y.20 SR 3.$ .1.7 The DOD does not

~ ~ See NUREG MIU page 83.8-16. The Repeat, see P4Q+ due.tly address the proposed change and, change to SR 3.8.1.2 allows a warm NRC RAI 3.8.1-Blk.10 consequently, does not adequately address the up period while SR 3.8.1.7 does not 23 for change. Die DOD sliould be ievised to adequately allow a warmup peciod. resolution.

,address flic proposed change.

Repeal, sec NRC RAI 3.8.1-23 for NOTE:( iThis change may nol be necessary. Th>> resolution.

licensee should discuss with the staff the possible applicability of all ot Note 2 in SR 3.8.1.2 to SR 3.8.1.7.

HRC RAIs - SSES licit(uviol I ~ a liinl ~c ~f~ cihcafiuci~ 24-Nov 97 PTye18 Of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: OOCIJFD: TS t.CO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS K8.14~8 ~P.8 RIIRER insert B38-1841 P 8- The proposed Bases addition is Repeat, see NRC RAI 3.8.147. Repeat, see page cceptable. However, the Bases and Note 8 to SR NRC RAI 3.8.1-B3.$ -1& 3.8.1.3 do not entirely agree. The Bases addresses 07 for one unit in shutdown with SR 3.8.2.1 precluding resolution.

performance of the SR on that Unit. The Note, however, provides an unrestricted exception which is not acceptable. The submittal should be revised so that note and the Bases are in aareement.

~8.143 QP.I~8 RUREG Insert B3.8-1842 P.1$ - The Bases addition is Not Repeat, see NRC RAI 3.8.161. Repeat, see page ceptable because the NUREG change and NRC RAI 3.8.1-B3JI-18 associated CTS change are not acceptable. See 61 for consnents for Insert resolution.

-3.$ -743 ln NUREG Markup.

SR 3 8 1 8 ~ ffolus<<<<cat>on is piowdedin support of 1433 markup willbe modified Closed INRC

)3.$ .144 NUREG ] [NUREG

[to indicale JFD P.12. closed dele>>>>u ff>v Sinai discuss>8>n. far Nofe 1. A IA $ 2 I prsf>feat>o>> sf>>>u>d be p>owded. 11/20/$ 7)-

PP&L will provide revised NUREG M/U.

Repeat. see NRC RAI 3.8.1-10 Repeat, see t3.$ .146

• g fp.12 )

NUREG page I SR 3.8.1.10 P.12 - Deletion of the Note precluding conduct of this SR in Modes 1 $ 2 is not acceptable. NRC RAI 3.8.1-B3.$ -23 See con>>nent for SR 3.8.1.& in NUREG Markup. 10 for resolution.

NRC RAIs -- S.'>ES f>f>prf>v> d 1 ea./>r>>i.af Si>e> >f>rat>vns 24.lVov-97 Page19of 75

SECTlON 3.8 NRG RAls SSES Improved Technical Specifications ITEM¹; DOCIJFD: TSLCO: DESCRIPTIONOFISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~$ .14~6 ~P.I4 NUREG SR 3.8.1.11 P.14 - The DOD does not address deletion JFD P.14 w>ll be revtsed to Closed (NRC page of the second paragraph in the Bases discussion for closed B3.8-24 SR 3Jt.1.11 on this page. DOD P.14 addressed 11I20I87)-

changes to SR 3.8.1.18. Also, SR 3.8.1.11 still PAL will contains the Bases material proposed for deletion. provide MIU is inconsistency and the absence of an appropriate of JFD P.14 000 should be addressed.

t3.8.147~ P.12 NUREG I SR 3.8.1.11 P.12- Deletion of the Mode constraint for Repeat, see NRC RAI 3 Jl.1-10 Repeat, see rie ( conduct of this SR is not acceptable. See conxnent NRC RAI 3.8.1-for SR 3.8.1.8 in NUREQ Markup. 10 for resolution.

).8.14$ LA.8 (:f S MiU 4 t t.2 d 13 - The f>>oposed change is acceptable. commitment will be made that the Closed (NRC tI~ 3>i rtowcve>. d>scuss>o>> LA.8 should actually be a Less TRM will be part of the FSAR.

Furthermore, LA.8 is a unique class dosed 11/20I87I 84 Rest>>cnve rather than a>> Adm>n>st>at>ve change.

Atsu. the d>scuss>on should >dent>fy the controls lor of less restrictive changes.

lhe fRI>t.

LA.8 is written consistent with lhe ay other relocated information has been justified. It is requested that the NRC provide furlher reasons why a specitic "L"DOC should be written for this char>ge.

HRC RAIs" &Sf S I>r>I>rr>vr >I 7 v> I><>>> wf SI>v>>I>r al>u>>s 24.Nr>v-gT Page20o1 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ff: DOCI JFD'S LCO: DESCRIPTION OF ISSUE'RC COMMENTS: SSES RESOLUTION: STATUS

~8.14~$ ~lA5 CTS MIU .8.1-12.d.12 - The proposed relocation of Table 4.8- Repeat, see NRC RAI 3.8.1M and Repeat see page 3l4 1.12-2 to the ITS Bases is Not Acceplable. Contrary 3.8.1-20 NRC RAI 3JL1-8- o discussion UL.6, ITS SR 3.8.1.18 (SR 3.?.1-17 in 04 and W.1-i LA'S) does not include the 10% (+20%, -10% for RHR pumps) tolerances from the CTS. In addition, 20.

this change is Not Consistent with NUREG-1433 as stated in LA.S. The proposed ITS must be revised.

e proposed change associated with discussion M2 is not clear. Does the SSES design include separate sequence thners for sequencing safety loads onto the ffsite circuits; i.e., one set of timers for the DGs and another set of timers for the offsite? If this is the se, ITS SR 3.8.1.18 must be revised to reflect both sets ot timers Lin addition to the tolerance valu~es .

[3.8,1m P.12 NUREG SR 3.8.1.12 P.12 ~ Deletion ol the Mode constraint is Repeat, see NRC RAI 3.8.1.10 Repeat see p40c sN4 mccpt~. See convnent for SR 3.8.1.8 in NRC RAI 3.8.1-836 ls HURLS G at<<aup 10.

j3.8.141 'j jj'i j

.NirREG Insert B3.8-2641 P.12 -The DOD is not applicable to NUREG MAIwill be revised to address comment. See NRC RAI Closed (NRC closed page the proposed insert. It would appear that lhe 3.8.1-16 1tr20Isr)-

B3.8.26 appropriate DOD is P 11. If this is correct, then P 11 is still being reviewed by the staff. See comments for Repeat See SR 3.8.1.11 in NUREG Markup for details. NRC RAI 3.$ .1-16 and PP6L ill provide revised NUREG IWU.

NRC RAIs - SSES lrrjPruvs rf ice frrncaf SPac sfsctfrurss 24-Nov-97 Page 21 of 75

is SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ff:

[3.8.143 l'.."

DOCIJFD: TS

~is P 12 l!' l LCO:

NUTMEG B3.8-27 huktt IL1 8 lr 83.8-27 DESCRIPTION OF ISSUE:

SR 3.8.1.14 P.16 - Change P.16 makes a statement but does not include any quantifying data; Le, what is the field excitation current at unity power factor and 400 Kw as opposed to the excitation current at maximum post accident loading. This information should be provided in supporl of the proposed change.

aR ) 8 1 ts p m oaivtNabie.

NUkLG tassaup 12 ~ Detction of the Mode constranit is See conviient lor SR 3.8.1.8 ni ilaw SR 3.8.15 P.12 Insert B3.8-2842 - The DOD that is indicated as the justification for the proposed cliange does not address the change. The proper ustilication should be provided.

NRC COMMENTS:

I 11/20/97: PPL informed the HRC reviewer that after review of what actions will be necessary to implement Power Factor Testing, the closure of this requirement ould remove all power factor testing.

SSES RESOLUTION:

Current licensing basis. PP8 L will revise SSES ITS Bases for SR 3.8.1.14 to identify that effort will be de to get as close as possibte to power faclor.

fter further evaluation, it is PAL's position that no additional restriction for testing at a specitic power factor should be added to SSES ITS Bases because it delines an additional requirement not specified in SSES ITS and as specified in the new ustification for Deviation (P.13) will rovide no specific testing benefit.

] tRepeat, see NRC RAI 3.8.1-10 NUREG 1433 M/U will be revised to indicate JFD P.19 to support this change as indicatednext to the inserl on the insert page.

STATUS Open4RC to reevaluate PP6L response.

PPL will provide M/U of SSESITS revised JFD P.13.

Repeat, see NRC RAI 3.8.1-10 for resolution.

Closed (NRC closed 1 1/20/87)-

PP8L will provide revised NUREG M/U.

'nd SSE S /itifuuviNU 7 vi, /ii ss .ii ! siva itic ~ t 24.Hov-97 Page 22 of 75 HRC RA/5 ~ ~

SECTION 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 8.146 P.18 NUREG SR 3.&.1.16 P.18 insert B3.8-284)1 - The DOD indicates JFD P.19 will be revised to clarify Closed (NRC page he RG1J), Rev. 3 endorses a 26 month refueling statement. closed B3.8-28 cycje. The staff is not aware of anything in the RG of 11/20/97)-

his nature. This DOD is, therefore, not acceptable. PP& L provide so, the proposed change from 18 months to 24 M/U of JFD nth refueling cycle Is beyond the scope of this P.18.

conversion effort.

iha~~ ]~as cTnhhN .8.1.1 &d.& M.3 The DOC indicates that Power Factor CTS M/U will be corrected to Closed (NRC requirements are added to ITS SR liminale statement. dosed

.8.1.16. The ITS does not include such a 11/20/87)-

requirement. Some correction is required here. PAL will provide revised CTS M/U.

)3.8.1il P.ll r<UHEG SH 38 1 16 P tl Insert B38.2942 ~ The staff does not I) i ll is p pal's pos ilian inal lolalional Closed (NRC u<<de<stand the t<rcnsce's proposed schedule tor testing as described in the SSES ITS closed 838 Zl testing DG E <n this SR. Assu<n<ng DG E is tested on Bases is current licensing bases. 11/20/97)

Bus tA lsubstitutcu lor DG A) at t<n<c zero (0) how

~

long w<<t <t be before DG E is again tested on Bus 1A?

ln the proposed Table, what is lhe purpose ol showing DG E substituted tor itscll in two places?

!The licensee should provide clarif<cation.

)3.tt.tm NuREG )Also, the Bases discussion of Note 2 for this SR does From discussions with Staff, Closed (NRC

) [P.& ) ustification acceptable. closed page not appear lo accurately rellect the Note, or the Note B3.8-28 is not consistent wilh the Bases discussion. The 1 1/20/97) licensee should review the Note an the Bases in light of staff com<nents on both, andmat<e any necessary changes to resolve staff concerns.

NRC RAIs - b!ifS I<<<I/r<<v< af ler /<ill< oi/ .h/<<'l <f<l 4f<<HI'~ 24-Nov-97 Page 23t/f 75

SECTION 3.8 NRC RAIs SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS KL24~1 ~P.'l4 NNNEG SR 3.8.1.18 P.14 tnsert B3.84042 -The proposed It is PPaL's position that lhe failure Repeat, see page Bases addition includes a statement that failure of an of a timer may or may not render the NRC RAI 3.8.1-B3.$ 40 ffsite timer may result in both offsite sources being offsite source inoperable. Ifthe timer 04 for inoperable. Should this not read "witt be inoperabte2 fails such that it would not allow the resolution.

start of the associated load then the offsite sources would not be impacted, only the corresponding load would be rendered inoperable.

ee NRC RAI 3.8.14i.

~$ .1G~P ~P.12 NUREG ~SR 3.8.1.17 P.12 - Insert B 3.84041- Deletion of the NUREG M/U will be revised to Closed (NRC page Mode constraint is Not Acceptable. See comment for reference JFD P.17. Repeat for mode closed B3.840 SR 3.8.1.8 in NUREG Markup. restriction issue, see NRC RAI 3.8.1- 11/20/87)-

10. PpaL will DOD P.12 docs not address addition of the Insert. provide fhc tlr22nscc should i2rov4c a rcletence to the rev>sed sun cnl tush t2ccuon. Il ll2c correct DOD ts P. 17, see NUREG M/U, convi2cnts <e: P.17 lor the Bases tor SR 3.8.1.16 see NRC RAI trxtul/2ng the <ssue ol lhc Bases d>scussion and the ML1-10 for pr of2oscd Nole nol being conslslcnl). other resolution.

HRC RAIS .- SSES Irtspluved frsIU 12 <<I ~l)earf2s<<t22<<2s

~ 24.Hnv.97 Page 24 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~3.8.W1 J IA~6 TS M/U Page 3/4-LCO 3.8.1.2.b.1 - Change A.6 is Not Acceptable. A.6 references L16 for LCO 3.8.1 8 L16 is Not As stated in the DOC, the Closed (NRC requirement to maintain a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fuel closed 84 ceptable. The 1 hr. fuel requirement In CTS should supply is an unnecessarially 11/28/87)-

be retainerL restrictive burden on SSES. See PP8L will 3.8.1 DOC L16. The DOC justifies the provide M/U change based on conservatism in the of DOC L16.

calculation. the reason for the cliange remains that of operational onvience because the practice of topping off the tanks manually results in an unnecessary expenditure of manpower. Discuss bases for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provision and SSES design.

PP8 L will revise DOC lo identify the physical limitation associated with requirement.

I3.8.142 P.11 NUREG SR 3.8.1.18 P.11 l<<sert 83.8'3141 - No justilication NUREG M/U will be modified to Closed (NRC

'page has been piovided for deleting the Bases discussion include reference to JFD P.12. c/osed

,B3.841 of the NUREG Mode constraint. The appropriale 11/20/87)-

(

d h ld be provl'ded. PAL will provide revised NUREG M/U.

NHC RA/s - SSf S /iripriivuir r ui/ilute ~ / b/tvLI/li~ frvtls 24.Nov-97 Page 25 of 75

SECTION 3.8 NRG RAls SSES Improved Technical Specifications ITEM 5: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~s.u~s~ rrui<<d insert B3.84241 P.1 - The proposed addition of SR JL121 (Unit 2, only) appears to be acceptable.

Repeat, see NRC RAI 3.8.1-22. Repeat, see NRC RAI 3.8.1-B3JI42 However. the Bases discussion of the proposed Note 22 for to this new SR does not a ppear to be acceptable. resolution.

is is because the proposed Note appears to be a blanket exception to the def<nition of OPERABIUTY th respect to SRs. Discussion of this issue with the licensee is r nired.

JL14i P.18 NUREG nsert B3.84341 P.18 - No insert was provided in the tinned will be presided. Closed (NRC page submittal package provided to the staff for review. losed 83.843 11/20/8?I-PAL will provide insert.

(3.8.tas M to M 1 CtS MU See as<< t<<ev<<bus c<~<vnents re: d<scuss<on s M-10 See CTS M/U page 3/4 84. Both DOC Repeat, see 1 payt 14 ~<<t M t 'l t<e<<<g. <n put. less <estr<ct<ve changes. M.10 and M.11 are specified. This is NRC RAI 3.8.1-84 M 10 wsN < ~a Ihe vul<ige tolerance r equ<rements considered to be a more restrictive 08 for v<</<<pse<t by Ct 5 SR 4.8.1.1.2.a.4 - this <s less change because of the tighter resolution.

<esu<rl<vc an<t must b< addressed. It would appear tolerances. See NRC RAI 3.8.N)8.

Ihal M.11 <s also applicable here. Has the<e t<een an onu as lQn?

l HHC RAIs -- SSE5 Irr<plovurf lb /s/<<< ur bpvs<l<r af<<>rts 24 Huv 97 Page 26 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD'S LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION'TATUS L8.146 j ~LA [CTS MIU 34.1.1.f2 - Change (L4) does not appear to make sense. RA ML1.1L3 only allows 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore 3 See NUREG 1433 M/U. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is the specified time. Furthermore, as Closed (NRC closed (or more) EDGs to OPERABLE, but 3.8.1.1.f.2 would DOC L4 identifies the time is 11/20/Sl) allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to test the remaining OPERABLE consistent with that recommended in EDGS. If 3 EDGs are not restored to OPERABLE, the Generic Letter 84-16.

plant will be on a shutdown track long before the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is up and long before any reasonable time It should be understood that NUREG necessary to adequately prepare for EDG testing has 1433 address common mode failure passed. In addition if 3 EDGs are restored to differently than CTS. Therefore, OPERABLE, testing may not be required, ifthe onxnon mode failure issue is sence of consnon mode failure can be determined. addressed for CTS Action c.2 as well as f.2.

$ 147 8 A.10 CTS Note -, A.10 - This discussion refers to DG 'rapid [Repeat, see NRC RAI 3.8.1-23. Repeat, see loadir<<g that may be interred bul not required.'his NRC RAI 3.8.1-M/U,'ari'ii state iiv>>t is cunlusuig, f4I<<d loading ot DGs either 23 for is. w is i<<r r vituueil flic uiienl ol this Note is lo resolution I sitivv/y <<ieiitity wtie>> last loading is not required, ui. cwivviscly. wh<<>> r4pid loading is required The piopused use ol llus I emussive in the SSES ITS iesu/is ui at toast 3 SRs where rapid loading is nol iequuedbul the Note providing the exceptionis>>ot used. Consequenlly, last loading could be considered a requireinent for these SRs, and failure ito do rapid loading could mean failure of the SR. The llicensee shouldieconsider the applicability of this Note such that the discussion need only state that the generic permissive in CTS is applied on a specific bases i>> ITS.

HRC RA/s " S 5 f5 Iiryicii eu l ec/nni u/ 1)i%i,ifiL4lNNIa 24-Ho@-97 Page 27 of 75

SECTlON S.S NRC RAls SSES improved Technical Specifications ITEM 0: DOC/ JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS'SES RESOLUTION: STATUS Ia 8.14~$ ~M.18 CTS MIU .8.1.1242, 48.1.1.2.d.3, 4.8.1A.2.dA*, 4.8.1-1.2.d.6- he voltages for several Closed (NRC page 3/4 he proposed ITS Indicale that the maximum surveillances where the limils were closed llowable voltage excursion during conduct of these specified as steady state in NUREG 11/20/87)

SRs is 4400 VAC. Is this really achievable, especially 1433 were restricted to 4400 VAC.

for the fuII load reject SR? (See (M.10)) is restriction was reviewed and found acceptable, but the values will be reconfirmed.

PAL accepts new voltage limits s 'fied in SSES ITS.

~erde ~UI4 ic28 MN i [4 81.1 Td2.change (UL4) appearaInbe See SSES ITS Bases page B3.8-20. Closed (NRC ipage 3/4 I .acceptable. However, some clarification is required. he information requested is closed 84 Specifically, what is the method used at SSES to specified in the Bases. The addition 11/20/ay)-

conduct this SR7 With the EDG. only, powering lhe of this information to DOC LAAdoes PAL will t Sf bus and re/ectuig tlie actual load7 Or paralleled not seen to be necessary. provide M/U f

wgitg trge giid and othengng the DG output breatiers?

discussion of the Power Factor of DOC LAA.

il d ga!he first ineihod, the aclual load needs to be speci/ied by name. testing requirement will be added to DOC LAA.

NHC RAIs -. 5.'ht 5 Iirgpruipirs/ I ~ i Iiriiti/ %PS s dlii afiud i> 24.Nov.97 Page 28 of 75

SECTION 3.8 NRC RAts SSES Improved Technical Specifications ITEM ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS CTSM/U .S.1-1.2.d - Change (LA.3) is not acceptable. The LA DOC's are generically written. A

$ 8.1~0 J~ULS page 3/4 'ustification does not address the 4 criteria of the final Closed (NRC corixnitment that the TRM will be part closed 84 policy statement with respect to this relocated f the FSAR will be made. No further 11/20/8?).

requirement. In addition, the Justification does not 'ustigcation will be provided for the PAL will address the control mechanisms associated with the relocation unless it is made provide revise TRM (i.e., part of UFSAR under 10 CFR 60.68, or what) genericatly. DOC L/L3.

onsider atso matdng this a part of the Maintenance Rule Program. Additional information is provided in 3.8.1 DOC LA.3 for clarification.

8.14l1 L10 CTS M/U .8.1.1>A L10 - This change adds a Note to proposed tRRepeat,see NRC RAI 324147. Repeat, see page 3/4 SR 3.8.1.3 which allows the SR to be alternated NRC RAI 3.8.1-84 belween Unit I and Unit 2. This is acceptable. OT.

tttowever, the proposed Note also contains a piowsion wtuch essentially states that performance ut tne SR on Uni!2 ls Ilul actually required. Thisis lrut Acceptable. A part ol thrc SR is to also tesl the DG breaxeis. As worded. ttie proposed Note would auuw untirrirted plant operation lor up to 26 months without testing the Unit 2 DG breaker and associated controls. The subnuttal sliould be r evised to delete tlio unacceptable part ol the Note.

8142 lPLA'1 .8-1.1.2.aA LA.1 - DOC LA.1 is not acceptable, and ln accordance wilh Generic Leller 94- Repeat, see I 01, the accelerated lest program will NRC RAI 3.8.1-the associated changes are also not acceptable. The DOC addresses regulatory activities (implementation be deleted under an 3.8.1LS DOC 12 for ol GLS441) thai will be conducted oulside the ch will identily that the resolution.

onversion process. The license amendment that intenance rule lias been implements the ITS can only address what exists at implemented at SSES.

the time the amendment is issued. It cannot address future regulatory issues. The submittal should be Repeat, see NRC RAI 3.8.1-12 revised to provide a "stand along'ustification, or CTS requirements should be retained. 7L8.1.1.2.b7 I"

Du the t: DGs at SSES have integral (enguie mounted) tuel uiiiiar rsritLs7 fbi~ ic iiut the uciiar r uiiroyus Awry HRC RAIs -. SSt.h Irrr/rrvva.<I lee Irirri ~l 5/rc'crfrcifrrur'4.Nov 97 Page 29 of T5

SECTION 3.8 NRC RAls -- SSES Improved Technical Specifications ITEM¹: DOCIJFD: TSLCO: DESCRIPTIONOFISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS p,s.143 J!L.~S CTS M/U .8-1-14m.1 - Discussion L6 by itself is Acceptable. ccelerated testing will be eliminated Repeat, see page 3/4 However, the change on which it is dependent (LA.I) under Generic Letter 8441. See NRC NRC RAI 3.8.1-8-7 is Not Acceptable. Therefore, L4 is MOOT pending RAI 3.8.1-12 12 for resolution of the issue with LIBEL resolution.

gs.<m )[LS crs MN .8.1.1.2.aA - Justification L6 does not appear to be CTS M/U will be changed to delete Repeat, see page appropriate for this change. L6 is applicable to reference to L6 for this change. NRC RAI 3.8.1-specific SRs, and this is not one of them. A proper 12 for

'ustification should be provided. Repeat, see NRC RAI 3.8.1-12 resolution.

[3.8.1~6 L6 C16 M>U a .8 1 t 2 a.t.4.$ .1.1.2 a.3- Change (L 6) appears tobe statement will be added to identity Repeat, see paipr 3 acceptable. ttowevei, the Justification does nol hat the 31 day Frequency is NRC RAI 3,8.1-acceptable based on performance 12 for appear to duectly address the issue, i.e., does not say why a 31 day trequency for these SRs is acceptable. history. resolution The tact that EDGs will no longer be subject to accelerated testing is something less than adequate Repeat, see NRC RAI 3.8.1-12 in way of a justification. (L4 is MOOT since LA.1 is Not Acceptable)

MHC HAli - SSE.S frri/Jl v 'ei

~ ~ ~ 8 04 loni at brH'i IIN +tlUrl'>> 24-Nov-97 Page 30of 75

SECTlON 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~8.14~6 L6 CTS M/U .8.1.1.2.a - Change (L4) appears to be acceptable. DOC L.6 will be revised to address Closed (NRC page 3/4 However, the justification appears to be improper for correct chan e. closed 84 is change. Staggered Testing of the four EDG on a 11/20/97)-

31 day schedule would mean that a different EDG PPB I will ouldbe tested every 31 days until all 6 EOGs were provide M/U ested, and they cycle would begin again. However, of DOC L6.

e requirement for testing EDGs is EACH EDG at least once EVERY 31 days. The rationale for deleting

'Staggered Test Basis'rom this SR should be that it is Inappropriate and contradicts the actual intended frequency. The gibberish in L4 regarding EDG reliability shoukf be deleted and replaced with something tike the above discussion. The only restriction on EOG testing is that it only be conducted on one EDG ate?

f3.8.1 67

'I ~

'L.16 CTSM/U '.8.1.1+.1 L-16-Theproposedchangedoesnot IRepeat, see NRC RAI 3.8.1 61. Repeat, see page >I a ppcar to bc accc pt able. The been see has not NRC RAl 3.8.1-81 tuuvutcd an sdeqwtc tusufesuon for the change 61 for hwlc uM QPclaluHJ a.uuvclucnce Is not an adequate resolution.

tuNit~sl~i Tt~ tscciace should prowde the twas.cs,~y luQitxatwn or retam the CTS I hr. fuel oil

< cquu es neil.

t3.8.14 8 (iM.6 CTS M/U i3;B.t.t.b Note+ - Deletion ot part of this Note >s ft 1/20/97: PPL will revise CTS M/U to Closed (NRC page 3/a 'ctassihedmore reslrictive M.6. The justification clarify what is being impacted by closed

-1 however, is not clear. Some additional intormation DOC M.6. 11/21/97) +PL regarding DG substitulions is required. (see EBT ill provide comments Pg. l.a 4 1.6, these comments). CTS MIU NRC RAh - SSES Irrlprovurf fed Iunr u/ Spud>fir>>trurrs 24.Nov 97 Page31 of 75

SECTION 3.8 NRC RAIs SSES Improved Technical Specifications ITEM¹: DOCIJFD: TSLCO: DESCRIPTIONOFISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS K$ .$ 4 / ~M.$ $ cTS MIU page 3/4

-7

.8.1.1.3.aA M.16 - Proposed changes to the voltage requirement of this SR are indicated as being covered by OOC M.16. There is no M.16 in the SSES submittal TS MIU in error will be corrected to reference M.10 Closed4$ P8 L ll provide revised CTS for 3.8.1. See NRC RAI 3.8.1-10 MIU, see NRC RAI 3.8.1-10 so, see corianents re: M.10 and M.11 for SR 4.8.1- 11I20I97: PPL will revise CTS MIU to for resolution 12~ (Page 3/4 83). Those conanents are applicable i~eniire i.$ .$ $ 0C $ .$ . of other issue.-

o these proposed changes.

DA Note is added to Proposed ITS SR 3.8.1.3 (L10) ich allows the SR to be alternated between Unit I nd Unit 2. This is Acceptable. However, the Note iso contains a provision which essentially states hat perfonnance of the SR on the Unit 2 bus is not actually required. This Is Not Acceptable. A part of this SR is to also test the OG breakers. As worded, the proposed Note would allow unlimited plant operation for up to 24 mos. without testing the Unit 2 DG breaker and associated controts. The submittal

,must be revised to delete the unacceptable part of the Note.

P.8 1 70 liA.2 j CTS MIU 3.8.1.1.C A.2 - The proposed change does not appear to be acceplable. CTS 3.8.1.1.C addresses one olfsite t $ fRepeat, see NRC RAI 3.8.142. J Repeat, see NRC RAI 3.8.1-page 3I4 8.2 andlDGinop., period. Cond. G.addresses2olfsites 02 for and 1 BG inop., and references LCO 3.8 In CTS, the resolulion.

plant slalus in proposed Cond. G would require entry into LCO 3.0.3. The ITS appears to be less restrictive than the CTS, bul adequate justigcation is not provided. The submittal should be revised to provide the necessary justification.

HRC HAh - SSES hr$ Pri vwl 7$rcl$ $ $ $$ ii:$lm$fieibc$ >> $ 24.Hov 97 Page32of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOG/JF D: TS LGO: DESCRIPTION OF iSSUE: NRC COMMENTS'SES RESOLUTION: STATUS jl.1-71 L2 CTS M/U 3.$ .14CA L2 - Change L.2 does not appear to be See NUREG M/U page 3.84. NUREG Closed (NRC page 3/4 cce ptable. The DOC does not convey a convincing 1433 allows 6 days from discovery of closed

$ -2 rgument ln support of the proposed change. Also, failure lo meet the LCO. Therefore, 11/20/97)

Note that the proposed change is BEYOND SCOPE of he proposed change of L2 ls a an ITS conversion. simple adoption of NUREG 1433 and

'thin the scope of the lTS conversion. Discuss justigcation for DOC L2.

~$ 178 QL12 To~as> ] .a>.1*L>a-p>repropesedoaaopedoesoo>appear See NRC RAl 3.8.1-10. Repeat, see i o be acceptable. The DOC does not provide a NRC RAI 3.8.1-Qge 3 )

convincing arguinent in support of the change. 10 for I resolution.

t3.$ .1-73 A.$ C15 tpt/U 4,$ .1.1.2.d.7 Discussion A.$ appears to be misleading. 11/20/97: Need to refer~ence See DOC A.8, the DOC states that lTS Closed INRC I does nol specify the start method losed Page 3I4 CTS SR 4.$ .1.1.2.a.4 includes 4 start signals to the flalest revision lo TSTF 36.

The rationale of A.8 is and then continues to state why it is 11/20/97) ~

(8- , >DG, noliust a LOOP signal.

~

equally applicable to the otlier 3 start methods as it is O.K. lt is PPdL's position that the PPdL will o the LOOP signal. The licensee should consider DOC does address all starling provide M/U revising this discussion. thods. of DOC.

PpdL will add statement to DOC A.$

to state that specific test initiation signal is not required to be specified and that all start signals would be eiLuivalent.

NRC RAb ~ .'pal 5 Illiproviir I vi.lineal blip d prii jr doited 34-Nov-97 Page 33Of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION. S'I'ATUS 17l..M.10, CTSMIU ~ 8.1.12~ M.10, M.11- The staff does not agree with See NRC RAl 3.8.148 Repeat, see M.11 page 3I4 the classification of these changes. One pat of the NRC RAI 3.8.1-change (Le., decreased frequency tolerance) is indeed 08 for, More Restrictive. However, deletion of the upper resolution.

voltage and frequency values is a Less Restrictive change which ls not addressed. The submittal should be revised to provide a justification for the less restrictive aspect of the change. This should include a discussion of the Bases section that will address itoring and trending of the thne required to chievaslea~dsteeevalle~aandfr lied~a

.8.1-76 P.6 NUREG tion D.1 and D.2-P.S - See comment re: P.6 in LCO See NRC RAI 3.8.1 02. Repeat, see page 3.8.1 markup for Condition D. This Bases section will NRC RAI 3.8.1-B3.8-1 have to reflect resolution of staff convnents re: P.S 02 for and changes may be required. resolution.

RAfs" SSf frrtfwuvu<< fa.L jnn eII SfJcllfn eatllNls 24 Nov.Q7 Pdrge34of 75-NRC S

SEGTlON 3.8 NRG RAls SSES improved Technical Specifications ITEM ¹: OOCIJFO: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 3.$ 4 AC Sources Shutdovm HAIs" SSf S Irrgwuva'd l~h>>i wr Spc irhcehu>>i 24.Nuv.J'/ Page 35 of 75 NRC

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM 0: DOC) JFO: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.8.241 P.3 NUREG LCO3.82, Condition A - Change P.3 is Not 11l20l87: PPL to provide a 8 is recognized that the Required Open+RC to page ptable. Condition A and Condition B do not have description of the hardship tions are different. The change review 3.8.12 he same Required Actions, and combining the two ich would be encountered as made to maintain SSES CTS acceptability Conditions into a single Condition is more than an n dealing with the singular Action for loss of an AC of change.

dmhistrative exercise. The proposed justiTication Is corrxnon loads. Source. It was determined that not adequate. ether the Actions are taken for the Source or the inoperable features necessary actions willbe taken.

Need to maintain SSES ITS structure because of consnon loads for Unit 1 and Unit 2. tfa DG is inoperable and II the DG supplies for the shutdown plant are common loads, if NUREG 1433 Actions were adopted all activities would be stopped for the loss of the DG that supplies the common load. This is overly restrictive considering in most cases, all four DG will be availabe for the shutdown plant because the other Unit is Operating.

An example ol the over restrictive requirement would be il for Unit 2 hite it is shutdown, one of required Unit 1's DG Breaker supplying a comnen load such as RHRSW was inoperable, the lollowing would be the Required Actions for the Inoperable Unit 1 DG IlfSSES ITS as written following NUREG 1433 guidance): 1) suspension of CORE ALTERATION,2) suspension of nvenent of irradiated fuel assemblies in secondary containment 3) initiation of actions to suspend OPDRVs and 3) initiate action to restore the required DG lo OPERABLE status. All these actions ouldbe taken for a loss of a DG hich only supported lhe TS requirement tor Decay Heat Removal SSLS llS 3A.S, which it these Achoia were taken they require that a>> alternate>>ietl>od ol decay heat re>>oval >s ava>table lor each

>>io icvautv HIIR shutdown coohn NRC RAID" SSES lrrtlrrovccf Ivchr>>c al Slrc>> rfrcahorta 24-Nov.97 Page36of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS subsystem within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND once per 2I hours thereafter. In this example, the NUREG 1433 Required ons would address all requirements with the exception of the safety function of concern.

Therefore, it is PPL's position that he proposed SSES ITS 3.8.2 Actions II provide much more appropriate Rertuirements.

[i s zaa.. NUREG I ISR 3.8.2.1 - Reconsider Change P. 4 is Not Acceptable After furlher review, it was Closed (NRC page because the proposed change involves an issue that determined that no further changes closed

[

has nul been accepted generically; i.e., what is the ere necessary, because bases 11/20/97) dillcrenae between "nwl and performed." In describes why the SRs are required

~urowi lu tl~ lac.k ol gei~ra acceptance, the to be mel.

ptupused Bases lur tlus SR does nol adequately

~ dckcss Ilw >ssw.

t3 8 24~ ] [~ 3 ] INUREG Action A. 1 P.3 Insert f33.84842 - The change ) IRepeat, see NRC RAI 3 8.241. Repeat, see

<<ssocialed with P.3 is not acceptable because the NRC RAI 3.8.1-page 1 for (83.8~8 assoaated change to the LCO is not acceptable. See comment tor LCO 3.8.2, Condition A in NUREG resolution Markup; re: p.3

- SSES Atra(uvtrf fs< /nut i/ 5pvc i@a.Ironic 24.Nuv 97 Page 37of 75 NRC RAIS

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹:

~$ 24l ~DOCIJFD: TS LCO:

NGRRG B3.847 DESCRIPTION OF ISSUE:

LCO 3.82 P.6 - Insert B3.84741 - The description of offsite circuits does not address transformers 101, 01, 111, and 211 or what Condition applies if one of hese transformers is Inoperable. This is part of a NRC COMMENTS:

11l20l87: This issue is related to NRC RAI 3.8.142.

SSES RESOLUTION:

SSES ITS Bases states "The offsite rcuit consists of the incoming STATUS Repeat, see NRC RAI 3.8.1-breaker and disconnect to... and the 02 for respective circuit path including resolution.

larger issue regarding what constitutes an offsite feeder breakers to the four 4.16 kV source, and when an offsite source is inoperable. ESS buses (A, B, C and 0) for both Unit 1 and Unit 2." This description includes the identiged transformers therefore unless this is a significant concern the wording utilized is believed to adequately define the required equi ent.

$8.246 '.3 1 NUREG Action A. 1 P.3 insert B3.W844 - The proposed cruuige is iiut acceptable for Iwo reasons. First, the The insert and SSES ITS Bases is identifying that the option to declare Repeat, see NRC 3.8241 lQ 84l start dues nilt uiideistand what th$ wording of!he

$ affected features inoperable in this for resolution.

uiwit Bl 84844 is supposed to say, and second, the condition provides an equivalent wiiidiiigol tlie insert does nut have corresponding level of protection. This is related to tang wgc in t tie L CO. The proposed inserl appears to NRC RAl 3.8.2-1.

bc a peimissive ol some sort that is inappropriate for uiclusion ni tlic Bases.

ction A.1 P.2 lnserl B. 384842 - The change eee NRC RAI 3.$ .241. Repeal. see I3.8>~6 ][ )

NUREG page }a ssociated with P.3 is not acceptable because the

[ [Repeee, NRC RAI 3.8.2-a3>48 associated change to the LCO is not acceptable. See 01 lor comment for LCO Ml2, Condition A in NUREG resolution.

Markup; re: P.3 IVRC RAls .- SSFS INiliruviil7 ~ 2 liiiii~$ 'Rlwaifii Jfiuiis 24-Nor-97 page 3B of 7$

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS K824~7 )~6 CTS MIU Unit 2 CO 3.$ .1.2.b.1- Change A.6 to Unit 1 LCO See NRC RAI 3.8.141. Repeat, see page 3/4 3.$ .1~.1 adds the day tank requirement DG E. Why NRC RAI 3.8.1-8- is the requirement not included in the Unit 2 TS? 61 for resolution.

~824$ ] +P.1 NUREG SR 3AL2.1 P.1 insert B3.8M41 - The staff does not Repeat, see NRC RAI 3.8.2-22. Repeat, see page understand the last part of this insert. See Question NRC RAI 3S.2-B3.8W in SR 3Al2.1 coneant NUREG Markup. 2 for resolution.

I3'8'240 L.1/L.1 CTS MIU Pope L4 SR 4.$ .1.1 ~ Change

~ver. lhe discus+on L.l >nr ul Spur rficifrorrs 24-Nov-97 Page39of 7$

SECTION 3.8 NRC RAts SSES Improved Technical Specifications ITEM 0: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS K&.~2-10 CTS M/U SR h.&.1.1A - Proposed Insert 6.6-1 references both 11/20/97: Need to delineate Reporting requirement is included in Closed.

[

page 3/h RGB, Rev4, and RGI.108. This is not acceptable. the di//erences between both Units ITS. The statement

&- RGI.9 Rev.3 incorporates RG1.108- the two RGs can Reg. Guide 1.9 Rev. 3 and identified is a direct quote from not exist or be referenced simultaneously. Why is Reg. Guide 1.108. PPL to NUREG 1h33.

here a reporting requirement in Unit 2 but none for verify this ls correctly stated Unit 1? Is sometMng omitted? in SSES ITS. Unit 1 does contain the DG Reporting r uirement in 6.6.6.

~8.2-11 ) ~M.1 CTS MIU LCO 3.8.1.2.b.2 - Change M.1 appears to be a subset CTS M/U of Unit 1 will be revised to Closed (NRC Page 3/h- of A.6, above. DOC M.1 ln the LCO 3.82 discussions delete reterence to DOC M.1. closed

&4 is only applicable to Unit 2. This appears to be an 11/20/97)-

error in the submittaL PAL will provide a revised CTS M/U, NRC RR/s " S SES /rri/Ir<ivvd lee h/rii ~I .'/or vlicif/uri~ 24-Nov-97 page 40 of 75

SECTION 3.8 NRC RAls -- SSES Improved Technical Specifications ITEM 0: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.82-12 M.1 TS MJU LCO3.8.1.1w- Change M.1 does not appear to be lt is understood that the definition of losed (NRC page 3/4 correcL CTS is silent on the Unit 1 AC sources, but Operability for the components closed 8-1 e definition of OPERABILITYincludes BOTH off-site ould require both power sources, 11I20IS7)-

nd once power. The ITS definition allows but what is being identified in the PAL will systemslcomponents to be OPERABLE with off-site submittal package is that this provide a or once power available. An Inoperable AC source requirement is being explicitly revised DOC o any of the safety equipment required by Unit 2 r uired under ITS. M.1.

kes that systemlcomponent Inoperable, and the applicable LCO would be enterecL The ITS specify e Unit I offmte sources required for Unit 2, but will not require the systems/components of Unit 2 to be eclared inoperable in the event of a loss of offsite or n-site power. This appears to be a less restrictive hange, and OOC M.1 does not provide a justification for the change. The submittal should be revised, c~cordln I .

NRC RAts " SSt S trriprovvd le a hrwc A Spec itra atiuoa 24.Nov-97 page41 of 75

C SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ff: DOCIJFD'S LCO: DESCRIPTION OF ISSUE NRC COMMENTS: SSES RESOLUTION: STATUS Diesel Fuel Oil, Lube Oil and Starting Air

.8.341 P2 NUREG LCO 3.83, Condition A Change P.2 is not necessary. is statement was added to SSES losed (NRC page Ml- e rules governing use of NUREGsIITS cover this ITS to provide ctarity. No technical closed 1 item. The proposed change willmake the SSES TS changes were made. 11/20I87)-

different from other licensee's TS with the potential PAL will for confusion, but with no offsetting benefit. Change eliminated, MIU of SSES ITS provide MIU is provided. of SSES ITS.

~814~2 ~ PNUREG age (

Lgo an 3.condition g-change p. 2 to not necessary. The rules governing use of NUREGsIITC cover this item. There is no adequate justification provided for making the SSES ITS look different when

'compared to olher conversions.

his change was made to be consistent with the corresponding part of Condition F. It is accepted that this is an editorial change lo the NUREG.

Closed (NRC dosed

'l1I20I87)-

PP8L will provide M/U f SSES ITS.

Change eliminated in SSES ITS.

SR 3.8.3.6 - Change P.3 is Nol Acceptable. TSTF42 is TSTF402 is approved by the NRC Closed (NRC t3.8.343 ) IP.3 J fNUREG [ )

No change required to SSES ITS closed Ipage 3.8- not approved, and changes relerencing a proposed generic change must be considered as Nol Submittal. 11I20I87) cceptable until such time as the change is approved.

HRC HAts SSES tiritiroved 7ratggigg at Sprig itii etguni 24.Nuv.97 Page42of 75

SECTION 3.8 NRG RAls SSES Improved Technical Specifications ITEM ff: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~S.u~g ti 3 CTS M/U LCO 3.8.1.1 Jt2 - Change L3 is Acceptable, but a y required changes to the FSAR Closed (NRC Page 3/i question exists. Has the (U)FSAR been updated to ill be made prior to implementation closed eflect this change? Also, the DOC indicates that DG of the SSES ITS. Also DOC L.3 states 11t20/87)-

I consumption rates were determined using the thai the highest heat values will be PPKL to highest heat value fuel". Is this the most used during observation of fuel provide M/U onsetvative approach? Would it not be better to consumption and the Lowest heat of DOC L3.

stablish fuel consumption rates using the lowest value will be used during accident heat value fueL conditions (highest consumption cate).

PAL willreview calculation and revise DOC to accurately reflect calculation and eliminate ambiguous arding.

[3.0.3~0 C1S Mlu tCti 3 0 1 lbrepresents 3 Chaiige L.t is essentially

~ iscussion of change L.1 will be Closed (NRC Pauv 3a Ac.ccptabtc ttuwvver. lhe DOC could be improved by evised to address change. closed 01 aodu~ vei~v to the ~ llect tliat a timded amount of 1 1/20/87)-

litic lo restore fuel od. lube oil, or starting air to DOC L.1 to be revised to provide PP8 L will wdtun lanits less risk than possibly additional justificalion balancing provide requiring a ptiuil shutdown. and is therelore an proposed change against risk revised DOC.

,enhancement in safety. L.1 does not discuss allowing ssociated with plant shutdown i30 days to teslore stored luel lo within limits - must transient.

ibe adiled.

NRC RAb - SSES Intprnvutf Ter/n>>caf S//iw rfrcdfiorts 24-Sov-97 Page43of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM 4: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~s.sa~s ~vA Nun@a page B3.841 Background PA - The proposed change is not correcL There are no SRs addressed In the Diesel Fuel Oil Testing program. All fuel oil SRs are

~ See NUREG 1433 SR 3.8.3.3. This SR ites the Diesel Fuel Oil Testing Pr ram.

Closed (NRC closed 11/20/87) included in LCO 3.8.1 or LCO 3.8.3. This submittal should be corrected.

~8.347 SR4.8.1.1.2.e - Change LA.1 includes a discussion specific convnitment will be made Closed (NRC

] LA.1 TS M/U Page 3/4 regarding moving this CTS requirement to the TRM. at the TRM willbe rt of the FSAR. closed

-1 The DOC does not, however, address the controls 11/20/87) associated with the TRM. The discussion should be revised to provide this information.

The DOC also does not address the CTS requirement to pressure test the F.O. storage lank in accordance with ASME Code Section ll etc. The licensee should

~

provide additional discussioii regarding where this iequuenient witt be nioved to (i.e.. TRM) and what cuiiriuts witt be applicable. or retain the requirement ui Is NRC HA/s - SSkh /rri~uvwt I>>./ii>ii~/ Spearfitutl\uI'~ 24.Nuv 97 Page44of 75

0 SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO'ESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.8.348 PA NUREG SR 3.8.3.3 PA - The proposed Bases change is not 11/20/9?c PPL will provide Discuss need to celocate Closed+PAL acceptable. The purpose of the Bases is to explain J F D to justify the deviation requicements. o provide B3.8M e TS, and the SSES proposed Bases does not do in the proposed wording M/U of SSES is adequately. The purpose of moving details such from N OREG 1433. PAL willrevise submittal to only ITS and as ASTM Std. ¹'s a Revision date to the Bases was to include revision date in bases. revised 3.8.3 ow some flexibilitywith respect to changes while STM standard will be maintained in JFD PA.

ensuring the purpose of the program was met. 6.6. Also determine ifnew Diesel Placing this materLd in the TRM does not provide the Fuel Dil Particulate standard is to be same degree of control as the Bases, and is not the issued soon. lf so consider lace for ex Ianation of TS. generating TSTF.

PAL has determined that the new standacd wilt not be immediately available so a M/V of the revised SSES ITS will be provided.

11/20/9lc PPL willprovide a revised 3.8.3 JF D PA to justify the deviation in the proposed wording fcom NUREG 1i33.

fL8.349 NUREG SR 3.8.3A - What constitutes a slarl cycle foc the DGs This is a bracketed item in NUREG Closed+PAL Il I at SSES? The NUREG Bases with respect lo a staA N33 which was chosen not to be 'll provide a page B3.848 cycle is deleted, but the licensee has not provided a incocpocated. Changes to bracketed M/U of the ceason foc the delelion, or provided any unit specific information in the NUREG have not SSES lTS etails to ceplace it. Appropriate information. previously required specific Bases.

ustification.

PPKL to add information into SSES ITS Bases.

NRC RAfs - SS ES hclpruvc cf P

l c Lclcni t/ hp('~ /fran ifcu)cw 24.Nuv-97 page45of 75

SECTION 3.8 NRC RAls -- SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS K8.3-10 J P2 ] NUREG page ction E.1 P2- The pcoposed addition to the Bases is not acceptable because it constitutes a permissive SSES wording was added specifically address concern to 0penWRC to rereview B3.846 t is not reflected in the TS. The staff understands following a successful start of the PP6L e purpose of the proposed addition; but the DG. This is an interpretation Issue cesponse.

ordlng is Inappropriate for Inclusion in the Bases. ich should be addressed. PPL will an alternative, consider that following a successful provide MIU starl, the DG is running, and there is no longer a PP8 L willevaluate wording in SSES fSSESITS requirement for starting air. Consequently, with the ITS Bases and consider a statement and Bases DG cunning. receiver pressure less than the LCO limit hat identifies condition is not and new 3.8.3 s no impacL ap plicable because safety function is DOC LA.

performed.

NOTE: LCD ApplicabiTity is when DGs are required to be OPERABLE; Im, capable of performing their PAL has evaluated the current intended function. For the air start system, once the ording in the S SES ITS and DG has'started, it Is OPERATING, and the attempted to determine if a generic requirements for the air start system are no longer change to section 3.0 could address applicable. This same concept can be applied to the his issue. Atter discussion with fuel oil and lube oil systems. rs of the TSTF, it was etecmined that previous attempts to address this issue had been attempted and failed. The concern raised with a generic change is that not all allowances would necessarily cesult in a "safe" condition.

It is requested that the NRC reevaluate lhe acceptability of this change as a plant unique change.

11I20/97: PPL will provide specific note foc SR identifying that if DG is running SR does not need to be met.

HHC RAIi " SSE'S icccpcovucf l vcficcn ~ I Specific JI>cuca g4. Nov.97 Page 46 of 75

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~&.&.1& P.&

J NUR&G page 3At-LCO 3.8.3 Condition B - Change P.6 does not address the change to Required Action B.1. Is it the intent of SSES Lube oil tank is designed with a sight glass for verifying normal Closed (NRC closed is change to infer that the DG is inoperable if lube lube oil. Below the break point used 11nOISTI-oil is not visible in the sign glass? Ifthis is the case, for Lube Oil for Condition B is below PP4L will e proposed Condition B appears to be wrong. level of sight glass and cannot be provide INU Consider 1/4" of oil visible inthe sight glass equals readily verified by the operators. of JFD.

nough lube oil for 7 days, but no oil In the sight Therefore, based on the limited lass equals an Inoperable DG. Some additional ability to monitor lube oil level SSES planation la required here; Le., wino oil visible, oil desired to sknply declare the DG level Is Indeterminate. inoperable if lube oil level drops below the level of the sight glass.

FD P.6 will be modified to Identify Condition B.

SSES fmPrr&i&erf fmfiri&&ir h>&nrf&ait&ur&a 24 Noi 97 Page 47 of 75 NRC RAls

SECTION 3.8 NRG RAls SSES improved Technical Specifications ITEM 0: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS MIA OC Sources Operating

.8A41 NUREG LCO3.8A, Proposed Condition C 8 0-The proposed Short of identifying 3.0.3 is not Closed {NRC page 3.8- change reflects the SSES design and is, therefore, applicable Conditions C and 0 cover closed 6 acceptable as far as it goes. However, there Is no ll circumstances. Therefore, no 11IZOIS?)

default condition provkfed (such as Condition B and additional actions are determined to proposed Condition F). Absent a default condition, be necessary.

3.02 could be Invoked. Some additional work is required here. (See corrsnents re: Change A.6 for PP8 L has determined there is no er need for a default Condition.

~kdat2 ~PGrP3 [NU~REG u 1, G 1 PG, P 3.3ee couatuat re: lack of a default Repeat, see NRC RAI 3.8A41 Repeat, see

[page statemenl for proposed new Condition C and NRC RAI 3.8A-(

Conddion 0 in comments lo NUREG Markup. 01 t3.8A~3", P.6 NUREG SR 3.8A.3, Insert 3.8.2643 - Change P.6 is not clear. See NUREG MIU page 3.8-26. The Closed (NRC

'page 3.8- 'hat crderia will be followed when determining ords were added lo further define and clarify requirement. Need to closed 11IZO/&?)

j26 )

l"potential degradalion"? Where are these criteria found? What controls are associaled with the discuss what additional statenwnts criteria? These questions need to be answered are required. No additional before the change can be found acceplable. information required.

NRC RAIS - SSES Irrtprovrral Ted Intra af Spec rfr(afrorrs 24.Nov-97 Page48 of 75

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~JIA4l None~ NUNUG SR 3.8AA - No justification has been provided for the Clean and tight is a bracketed Closed (NRC page 8.8- deletion of "clean and tight" from the SR. Note also requirement and therefore is closed 26 frequency change from 12 months to 18 months. recognized by the NRC as being 11/20/87j-based on specific plant requirements, PP8L will nd no further JFD's are required. provide revised JFD PAL agreed to add JFD for P.10.

removing "tight".

It should be noted that PAL has provided a revision to the SSES ITS outside of the NRC RAls to incorporate several industry TSTFs Ich are current under review with NRC. The one, TSTF 189, relocates his SR.

11/20/87: PPI. has incorporated e~ddilional nedficanon In JFG p.\e.

)i.8A46 P.9 HUREG SR 3.8A.6, Insert 8.8 2641 - Change P.8 is Not As stated in JFD P.9, in/onnation Open JfRC to page S.8- I Acceptable. SSES CTS u>elude specilic acceptance relocated to maintain consistency in review for battery chargers Ii.e., amps and time) that presentalion with SR 3.8A.7. cceptability

26 ) Icriteria should be reta>ned in the ITS. Th e submittal should ofchange.

be revised accordingly. PAL has determined Ihat based on plant engineering experience, battery chargers do not experience degradation prior to failure, bul will lail due to shorl or open circuit which 0 result in total failure.

- SSES /rrilerddvuG/ frr /sdddl a/ spec/!dc ~ liudd 24-Nov 97 Page 49 of 75 NRC RA/8 ~

i SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM¹: DOC/JFD: TSLCO: DESCRIPTIONOFISSUE: NRC COMMENTS: SSES RESOLUTION'TATUS

~mwas f~ ~swats SR 3.8A.6 - Note the frequency change from 12 nths to 18 months.

current Licensing Basis Closed (NRC losed 11/20/87)

~SA4T ~PI MUREG insert 3.8-2741 - Change P.2 is Not Acceptable. The his note is consistent to the note Closed (NRC page 3JI- Note to SR 3.8.6.1 for Unit 1 states that the Battery proved for PBAPS ITS Submittal. closed 7 barge, Battery Service, and Battery Perfoanance 11/20/$ 7) ests are not required to be performerL However, the Unit 1 DC sources must be performed. However, the Unit 1 DC sources must be OPERABLE to support Unit 2, and OPERABILITYIs determined by performance of SRs. The proposed Note amounts to a blanket exception to the definition of OPERABlLITY and is, therefore. not acceptable. This portion of the submittal must be revised.

L3.8.448 Cl 6 M/U SR 4.8.2.t.e ~ Change L.6 is essentially acceptable. See NUREG 1433 page 83 847 The Closed +PAL Page However, the DOC includes a dehnition of a modified DOC is consistent with the statement o provide de in lhe third paragraph of M/U of SSES B3/4 $ .13 perfonnance discliarge lest which could be

<msinterpreted. Specihcally, the DOC states that the NUREG 1433 bases. ITS and M/U ilong tenn discharge is conducted at the "test rate of DOC.

'employed for the perfonnance test." This long term Add to statement in DOC that both discharge rate should be a function of the actual load currents will envelope lhe duty cycle such that it envelopes the largest emergency load of the battery.

~following Ihe 1minule discharge. The DOC should be revised to ensure that this distinction is included. 11/20/97: PPL will provide revised ording to change the description of dd Corianent re: deletion ol battery charger the modilied perfonnance test. The numerical acceplance criteria. (LA.3) ording will also be changed in the SSES ITS Bases description of the ified performance test.

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~ '

l

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS SSES RESOLUTION: STATUS

~WA4~9 (LA~ CTS M/U Page Change LA. Also, is the Note addressed by LA really pplicable to ITS SR 3.8A.8.

CTS M/U will be revised to eliminate reference to LA for SR 3.8A.8.

Closed (NRC closed B3/4 8-13 11/20/97)-

PAL will provide revised CTS M/U.

~sw-co fiant cvseu LCO 3.8.2.1.aA -Change LA.1 does not appear to be See NUREG 1433 Section 3.8A. 24 ClosedklRC Page3/4 acceptable. The DOC does not provide an adequate VDC subsystems have been removed o review 8-10 'ustification for the change. The DOC shouldbe from the Improved Technical acceptability revised to address the 4 Criteria Inthe Final Policy Specification because they only of change.

Statement with respect to the 24 Vdc battery. In provide support to the Nuclear PAL will addition, the DOC should address why it is acceptable Instrumentation. As such when provide M/U to delete the power source for SRMs and IRMs from these batteries are inoperable they of DOC LA.1.

TS while retaining in TS the power source for all other result in the inoperability of the

,insliumentation and the RPS. associated Nuclear Instrumentation.

lt was determined that there was no benelit to have a separate speciTication only for the 24 VDC batteries because their inoperability could be directly associated viith the inoperability of the Nuclear Instrumentation and therefore, the Nuclear Instrumentation LCOs provided sufficient guidance. This is similar to other support system requirements being relocated from S by NUREG 1433 such as the Mode and 8 requirements for the ESW system and RHRSW System.

PAL willrevise UL1 to identify that esting requirements for the 24 Vdc battery will be relocated to the TRM.

NHC RAls" SSES firiPlnvecf la Inua a/Specrficafimta 24.gov-97 Page51of 75

1

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SECTION 3.8 NRC RAis SSES Improved. Technical Specifications ITEM R DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~SA41 Lnn Q CTn MrU Page 3/4 LCO Ml2.1., Action f - Change A.6 is Not Acceptable.

so, the lTS that is reflected by this change is See CTS M/U Page 3/4 8-11. The CTS ions simply provide direction to Closed (NRC closed 8-11 incomplete. There is no default statement in the CTS restore the battery to operable slalus 11/20/Sl) or the ITS. Therefore, failure to hnplement the within the required time. The Required Actions within the allowed completion time elinination of this explicit statement results ln an unanalyzed Condition and entry Into is an NUREG 1433 convention.

LCD 3.0.3. This shoukt be corrected.

lt is also understood that there is no efault statement in the ITS for this ondition. Evaluate.

PAL has determined there is no need to change the way the Required ion ls stated.

f3.8W.12 CT8 MIU 7Quest~ ( Why rs d acceptable to wait for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to (. i fnnrreni ereensinn iresis. Closed (NRC Page declare DG E umperable <f the DC subsystem lor DG dosed E rs mop<<rible and DG E ts substduted for another 11/20/8T>

DG2 Does thun need lo be corrected in the ITS?

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SECTlON 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS'SES RESOLUTION: STATUS

~AA-15 PA NUREG SR 3.8A.1 PA Insert N.84443- See convnents re: he convention of using two OpenklRC to page ving the 14 days from the frequency column to the Frequencies for a single SR is review PPL's B3$ 44 e in CTS Markup. Corresponding Bases changes acceptable and an example is response.

ll be requlrecL provided in Section 1.4 (example 1A-

) for repetitive SRs. Furthermore, is same convention is used for other TS Sections such as 3.2 "Safety Limits", SR 3.1.7.6. SR

.$ .1.12, etc.

11/20J97r A question arose as to ther the identified change should modify the SR or the Frequency. The change as stated in the JFD PA, is being made to eliminate the need to "perform" the test during and following an equalizing charge because data taken during the perfonnance of the equalizing charge ould be acceptable but not representative. Because the battery is on an equalize charge, measuring the terminal voltage will provide no aninglul or trendable data. The SR requirements will be met during the equalizing charge therefore, compliance with the SR is not being aken exception tomnty the need to perform the test at the specified interval is being extended. (e.g. the SR will be met during the performance of the equalize charge.)

NHC RAls - SSES lrrrprovL'if 1 el Ilotcdf Sr il elfli dflolls 2'4.Nov-97 Page 53 of 75

SECTION 3.8 NRG RAls SSES Improved Technical Specifications ITEM¹:

~SA.5~4 ~

DOCIJFD: TSLCO:

CTS MlU Page 83f4 8-11 DESCRIPTIONOFISSUE:

Deleting the "restore" option is acceptable when viewed In a specific way. However, in doing so, the S become inconsistent, i.e, Action C.1 is not onslstent with Action A.1. It Is suggested that the "restore" option be retained in all the ITS even NRC COMMENTS: SSES RESOLUTION:

It is understood that the TS Required ons are inconsistent, but in the case of Condition A, the only Required Action is to restore the STATUS Repeat, see NRC RAI 3.8A-11 affected component, because the hought it exphcitly states what is already implicit in default action is to shutdown.

he LCOs. onditions C and D have another irect R uired Action.

SR 4jt.2.1~ Change L4 is acceptable in concept. is change was modeled after a Repeat, see Qs.l-1~ J LA CTS WU Page However, the frequency column in the ITS should be similar change reviewed and NRC RAI 3.8A-N/4 8-11 hanged. The 14 day maximum time that the SR may accepted by the Staff for PBAPS, 13.

be deferred should be included in the Note, not ln the refore, unless specific concerns frequency column. Also, the hcensee should expand re idenfiged the convention used is DOC LA to state why "meaningful results cannot be considered acceptable.

obtained when the battery >s or has recently been on an cqualung change, A clunge Per DOC L6 ~s <ndaaled m the CTS markup. However, there rs no OOC L.6 in lhe 3.8A secuon of the submdtal.

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SEGTlON 3.8 NRG RAls -- SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~IA-1$ [ ~ NUREG page B3.8-SR 3.8A2- The proposed Bases changes result in a Bases discussion that does not read well, and may be incorrecL The licensee should revise this Bases PP6L has reviewed these SRs and deterimined that the resistance limits provided in SR WA.2 provide the Iosed+P6L Il provide MIU SSES ITS.

discussion to more completely address the Operability linits for the battery and hought(s) that prompted the change. ill be incorporated into SSES ITS SR 3 JIA.5.

11/20l87: Revised wording provided in the SSES ITS Bases to redefine t consitutes a modified performance discha~re test at SSES.

[LSA-17 LCTS Ml+U (SR 4.8.2A.b.2 - Change L3 is acceptable in concept. See DOC 3$ A L3. The last sentence Closed- (NRC

[ [L~5 Page ~ However. DOC I 3 includes tlie term "negligible is a statement of conclusion based closed B3i4 8.1 I <<iipact." Wliat does tins mean? Can it be quantified? on the argument presented in the ttnOl87)PPaL Discussion of Change. Many of the il provide

'lies is a ueunic convnent that includes other such changes being made in the ITS revised DOC.

nva+UJutltkbie tcans 4$ significant Such terms conversion are "qualitative" are uiappiu pr iate lor use in a stall SE and, siiice the evaluations where no specific SE is based on licensee input, should not be included quantitative evaluation is possible.

in the bcensee submittal. The conclusion statement is presented in several of the DOCs.

'Theie is a serious probiein with change M.3. As proposed, the ITS would allow a liattery terminal For DOC M.3 see NRC RAI 3.8A-16.

resistance of 65 x 104 ohms (126Vdc) and 65 x 106 (260 Vdc) in the presence of corrosion. However, PP6L will revised DOC to state that proposed ITS SR 3.8A.5 requires a terminal there is no measureable affect.

resistance of ISO x 104I ohms (measured every 10 o.). If ITS SR 3.8A2 is perfoaned and leaninal resistance is found to be > 50 x 106 ohms even though it is c 65 x 104 ohms, lhe associated battery is inoperable. See SR 3.0A. ITS SRs 3.8AB and L3.8A.6 are not compatible. This inust be corrected.

24-Nov.97 Page 55of 75 NRC RAID -- SSES lailuovirrl Ta c.hniiuf Klwctftcifirii>>

SEGTlON 3.8 NRG RAls SSES Improved Technical Specifications ITEM 4: OOC/JFO: TS LCO: OESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS fSA-IS~A.S NURRG page SR 3.$ A2 P.S Insert B3.84I4i - See consnents re:

Change M3 on Page 3/4$ -11 ln CTS Marhup.

Repeat, see NRC RAI 3.$ A-16. Repeat, see NRC RAI 3.8A-B344l Proposed SR DA2 and SR 3AA.S appear to be in 16 onftfct with each other. The bases will have to be revised to reflect any changes made to resolve this corranenL LS.SA.IS J [L1 Q TS NIU SR IAl.2.1.CD - Change I 1 - Is deletion of torquing DOC L1 will be moditied fo either

] address Closed (NRC age requirements consistent with IEEE460 (1886)? If so, IEEE460 (1885) or cite closed B3/6 8-11 it should be stated in the DOC. a~ropriate reference. 11/20I87)-

PP6L will provide a MIU of DOC.

)AA 20 Ps HURK G SR 3 8 4 6 P 8 tsssert B3.845 - The proposed addition

~ tRepeaa, eee NRU RAI 3~6646. Repeat, see iu the tLsses ss <<ieptahte. athest unnecessary. NRC RAI MlA-tt3 844 Howesier the assssciated chaiigc to the NUREG SR is 06 ssut <<ceptable. Seeconvnentre: SR3.8A.66P.8in NUREG Martsup.

CA.b4 - Change LAAis Not Acceptable. Information was relocated to be Repeat, see P.8.6:21 ] CLAA ] CTS MIU Page SR AL8.2.1 T lie proposed change is not consistenl with NUREG-

)

consistent with Battery Loading NRC RAI MIA-B3/4 8-12 ti33, and DOC LAAdoes not provide a standalone profiles. Voltage values are correct. 05.

ustification for the change. Also, justification for changing 25$ .6Vdc to 2S56Vdc.

NRC HAfs " SSE S frr~ovvrf fee f>>>>r il bf PRa sficautrrts 24.Nov-97 Page 55 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~NA-22 ~PN NUNEG SR 3$ A.S PA - Deletion of the Mode constraint is not See JFD 3.&A PA. As stated this Repeat, See page acceptable. change is current licensing basis for NRC RAl 3.8.1-B3.8- SSES and has been demonstrated to 10.

t the criteria established by the NRC for performance of SRs on4ine.

SA-23 PAl NUREG SR 3.&A.7 P.& - Deletion of the Mode constraint Is not I Repeal, see NRC RAt 3'-17. A Repeat, See page acceptable. second sentence will be added to SR NRC RAl 3.8.1-B3.8- 3.&A.S Bases that "A modiged 10.

NOTE: A modified performance discharge test may be perlormance discharge test may be substituted for a service lest at any time. The substituted for a service test at any hcensee might wanl lo revise this section of the time."

lhas.

PPE L has determined to incorporate industry proposed TSTF-200.

Repeat. See NRC RAI 3.8.1-10.

PSW-24 CTS MIU SR 4.8.2.1.d.2 - Change LA.3 - What are the control convnitment willbe made thai the Closed INRC

[uCO ] Page hanisms associated with the TRM? RM will bogart of the SSES FSAR. closed B3I4 8-12 11/20/87)

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~6.4-26 622 i CTN 6NU SR Ada.1.d2.b,c - Change UI.3 - What controls are consnitment will be made that the Closed (NRC Page ssoctated with the TRM? RM is rt of the FSAR. closed 83/i 8-12 11/28/6?)

~NA-2~ J ~P.6 NUNNG SR 3.8A2. Insert 3.84642 P.6 - The proposed SR has Repeat, see NRC RAI 3.8A-16. Repeat, see page 3$ - serious problem and I$6 therefore, Not Acceptable. NRC RAI MA-26 s proposed, SR 3.8AL is in conflict with SR 3.8A.6. 16 See consnents re: Change MD on Page 3/48-11a in TS markup.

t3UBA.2? L'I CIS MLJ Cr6i66O66 L-1 pr oposed to make the Note from Unit I SR See NRC RAI 3.8A4? Repeat, see ITigc 36a 3 8.6 1 iIPI6bcibte to Urut 2 SR 3.8.6.2 when Unit I is in NRC RAI 3 JA-8 tti Modes 4 or 6. Ttus appeirs to be acceptable since 7 Unu 2 would ilsu be ns Mode 4 r6r 6. However, the etfects ol tins proposed change must be reviewed in

.detail is part ol the discuss>on on change M.2 for

'CTS SR 1.82A (ITS LCO 3.8A).

I HRC FcAI> .- SSES /rr>provvd Terr./6i6>6 i/ Specrfrc.shor>a 24-Hov-97 Page 58 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications (TEM ¹: DOCIJFO: TS LCO: OESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS SR 4.8%1 - Change M-2 would add SR 8.8A Jl

~SA48 J ~Ma C7S MIU page 314 nit2)TS. TheSRstatesthattheSRsfortheUnitl to the he Note is consistent with a similar Note incorporated into the PBAPS Repeat, see NRC RAI 8.8A-8- DC sources requued by Unit 2 are applicable. This Is ITS and accepted by the Staff. 07 ptable. However, the proposed SR indudes a Furthermore, testing does render the ote which essentially states that the required SRs Battery Source inoperable. This is need not be performecL This creates a problem. The y SSES Is designed with the Unit one batteries (DC Sources) must undergo capability to shift the common loads surveillance testing in order to establish o Unit 2 DC Source.

OPERABIUTY. However, these SRs can only be performed In Modes 4 or 8. With Unit 2 at power, the Note In proposed SR MA.8 would predude conducting the required SRs on the Unit I DC sources because in doing to the Unit I DC source must be Inoperable. This Note represents a btanket xception to the OPERABILITYrequirements for a safety system/component required by a ptant at power. This proposed SR and associated Note r uire further discussion.

I2.8A-2& cl s suU Ã8.2. actionb -As worded, Action b. allows the Yes this is correct. Any loss of a Unit Closed (NRC common loads to be transferred il the Unit 1 DC 1 battery would result in a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> closed page lsource to the Unit 2 DC source. The completion time Complelion Time therelore, no 11I20I87) lis 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.?Question? LCO 8.8.4 (ITS) has a benefit provided.

Condition for one DC subsystem inoperable with an Action to restore within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Failure to restore ithin the speciged time results in a Unit I shutdown.

There is no allowance tor tra>>sleiring common loads o the Unit 2 batterly- Is this correct?

NRC RAIs . SSES Irr~uve al Technriil SPecrfsifenS 24-Nov-97 Page 59 of 75

1t SECTION 3.8 NRC RAls SSES Im proved Technical Specifications ITEM 0: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS DC Sources Shutdown Kgga~l ~PJ NgggG Background Pg What are the deaignhaaia See NUREG M/U page B 3.840. losed (NRC e requirements for the battery chargers at SSES. SSES ITS description of a battery closed subsystem is consistent with that of 11/20/87)

NUREG 1i33. Need to clarify what additional information is rerLuired.

f3,8.aaZ LAi j CTS M/U age LCO 3.82.2.C.1 8 2 LCO 3922.d DOC A2 addresses DC power in MODES 14. This LCO covers Modes 8 i See DOC 3.8.5 A2. Second to last sentence states "ln addition, ITS Closed (NRC losed Nli 8-18 6, and A2 is Not Applicable. The submittal should be ensures this requirement is met...and 11/20/87)-

revised to provide the appropriatejustir/cation for the SSES ITS SR 3.8.8.1 to include PPLL to hange. erification that the Unit 1 and provide M/U.

ommon loads are powered from a of DOC.

Unit 1 source."

PPE,L will provide revised DOC A2 for 3.8.5 to simplify change and argument.

f3.8.6~O3 fLA2 ") CTS M/U The DOCs for LCO 3.8.6 include DOC MA. However, See Unit 2 CTS MIU Page 3/i 8-1?~a Closed (NRC Page there is no corresponding CTS markup for this DOC. closed B3li 8-17 hat is the purpose of this DOC? has something 11/20/97)-

been omitted from the CTS markup? PP6L will provide CTS M/U page.

NRC RAIs - KSi 5 IdtgfuuvVu Tag figuCtsf .'gfugg gfrg ~tggugs 2g Prov-97 Page 6Dof 75

SECTION 3.8 NRC RAIs SSES Improved Technical Specifications ITEM ¹: DOCIJFD'S LCO'ESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS NUREG SR 3.8.5.1 - The Note associated wilh this SR is not No differences identifiecL Closed (NRC page 3.8- orded the same as the comparable Note in LCO closed 3.82. What ls the reason for this difference? Note is not consistent with 3.8.2 11/20/87)-

note. PAL will revise notes to be PAL will consistent. provide M/U f SSES ITS.

~S.SW5 ~ suan page 3S-Insert 34-2843 - The submittal indicates that this insert is Included, but it does not show up anyplace ln he submittaL Insert willbe provided. Closed (NRC closed 11/20/87)-

PPR will provide inserL l3.8.6m P.2 HuitEG Ai.tions P.2 Insert 83.8C142 - The Bases addition See NUREG M/U page B3.841. SSES Closed (NRC page regarding LCO 3.0.3 seems to be incomplete. The ITS inserl will be changed to state: closed 83.84C ucensee should consider adding the material so that "The ACTIONS have been modilied 11/20/87)-

the who/e thought is captured. by a Note stating that LCO 3.0.3 is PAL will not applicable. This is acceptable provide M/U because LCO 3.0.3 would not specify I SS ES ITS.

any additional action while in MODE or 6 moving irradiated fuel assemblies."

NRC RAIs.- SSES I/riprvvird Tei/irrir ai Spvcrf/cuf/uvs 24.Nv v-97 Page 61of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 3.8.6 Battery Cell Parameters

.8.641 NUREG TS 4$ 2.1> requires verification of battery terminal Typo in SR 3.8.62 Bases will be Closed (NRC e voltage within 7 days of overcharge, ITS requires corrected. Also Discussion of closed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> no "M"Discussion of Change. Typo han e MD will be added to CTS M/U. 11/20/87)-

Inbases for SR 3.$ .62 shouldbe 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" not 24 PAL will hours days" provide M/U of SSES ITS and CTS M/U.

K$.64I j L.S CTS M/U able 4.8.2.1 Change LS is Not Acceptable for the PAL will review DOCs and ITS to losedPPLL Page 3/4 following reasons: the proposed change Is outside reference only one date of the ill provide

-14 the scope of ITS conversion the licensee references standard. After review of IEEE 460 no M/U of DOCs.

IEEERSO, 188S in this DOC, but references the 1887 reference requirement to temperature version for other DOCs, and, in one case, provides no could be found which would be revision reference at aII. The submittal should only onsistent with the technical reference one version of IEEEWO. discussion.

A cha~e A.S >s uMteated, but there is no DOC A.6. 11/20/87: PPL to review submittal C4nhcatm> a requued. and clarify that adopting IEEE 460 1996. DOC has been changed to reflect IEEE 460 1886.

HRC RAIs .- SSE.S I/r~ri>ver 7 v ~ /nnaJI!5fivcrhcabmts 24.Nov-97 Page 62of 75

SECTION 3.8 NRC RAls SSES improved Technical Specifications iTEM Ir: OOCIJf D: TS LCO: DESCRfp'flON OF ISSUE: flRC COMMENTS: $ $ f.~ RL OLUTIOk STATtiS

~6 C 643 j /LA 2 J PTS FNU SR 4.8.2.1.b.b Change LA.2 is Not Acceptable. lEEE- g fNo change has been made to the Ctoscd+Pa L Page 9I4 60 {1895] does not fnctude a definition of 'idcntifrwtion of the number of will provide La.1 ta representative cells," and does not appear to incfude ireprcsentalive cells. Therefore, this revised OOC.

any suggestions regarding the sample size. The is current ticensing basis submittal should be revised to retain the CTS requirement of 10 or 10 cells. PPtfLL volt revise OOC to identify why it is acceptable to remove fnfomvatfon -nd properly reference reformation about lEEE Standard.

1 tl2DI97: PPL to review subniittat nd clat ify that adopting IEEE 450

'l 995.

99604 P9 Huffier. l.<be ) u t I, F

~

ool>>>>It ta) - change P.9 references a iI>I

~

)

itti20I87: PPL to review submittal i ~Rcp at, sce NRC RAt X8.6-seal vcis~~c ol IFEC 460. Tins sta>>lard has been and elarily that adopting tEEE 460 ievaed. wats llic tate.l issue datert 1995. ls tttc 1995. Reference date has been 02 tac ~sti'.

ts02 ll

..h>>ge constslent wdh tl>>s 1996 version ol what changes lo thc suhInittal arc ichangcd lo 1996.

req>>>>edy v'.I..e Irtlf)Irrv 'lr I I ~,alt >>I >> all<>>Is 2t Nov gy PIrgrtr 63 Of 7<

9IMC ISItl+ ~ ~ ~ ~ ~~ r ~ f>s

SECTlON 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: OOCIJFO'S LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

.8.646 PA NUREG able 38.6-1, Footnote (b) - Change P. 4 is Not 11/20/97: PPL to review submittal Repeat, see ge 3.8- ceptable. This DOD references the 1996 version of nd clarily that adopting lEEE 460 NRC RAl ML6-3 lEEE460 whereas Change P.3 references the 1987 1996. 02 version os the same documenL Only one version is ptable as a Justification.

suming the 1996 version of IEEEXSO is used, this proposed change is still not acceptable because if oes not accurately rellect Annex /L3. The language of Annex A.3 would allow the requirement for level ection to be omitted provided the temperature corrected specilic gravity is within the range specifiedby the manufacturer. Annex A.3 is not a blanket deletion of level correction. This is nol ccurately reflected inthe proposed change. The submittal should be revised.

'/"

.$ .646 i PA NUREG i 'Table 3.$ .6-1 PA - The proposed deletion of level f ) 11/20/97: PPL to review submittal Repeat, see patte coiiection is not acceptable. See conviients re: PA and clarify that adopting lEEE 460 NRC RAl 3.8.6-B3 $ 4$ iii Nuitt G Matiiiploi Table 3.$ .6 1.

~ 1996. 02 NUREG Table 3.8.6-1 PA - The proposed deletion of Bases 11/20/97: PPL to review submittal Repeat, see

)386~7 ) GAPA )

NRC RAl Ml.6-

) 'ilge terial regarding level correction is not acceptable. and clarify that adopting IEEE 460 B3.849 See convnents re: PA in NUREG Markup lor Table 1996. 02 3.8.6-1.

- SSCS fniPruvad Iaah>>ice/ S~ificittwis 24 Noi/-g7 Page 64 of 75 NRC RAls

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS SSES RESOLUTION: STATUS

~9.64$ P.6 i NUREG able 3.8.6-1 Footnote (c) - Change P.6 is Not JFD P.6 will be corrected to: Closed+PaL MIU page eptable for the following reasons: 1. Correct typo, footnote (b) will be 'll provide 3.843 1. The DOD indudes a reference to verbiage in changed to footnote (c) MIU of JFD Footnote (b) which is not contained in the footnote, . Incorporate which revision to and see NRC The issue of unrestricted use of fioat current as a IEEE 460 is being used and provide RAI 3.8.642.

substitute for specific gravity measurements has not a o 'ate cross reference.

been resolved generically,

3. The DOD references IEEEE460, but does not specify a particular revision (l.e198?, 1996,?), and

. IEEE460 (1986) does not indicate that stabilized arging current is an acceptable substitute for all specific gravity measurements when determining the stat~ of charge of a battery. The submittal should be revised, accor .

NHC HAfs - SSES lrriprovvu fvLfuui ~i Stwalfll4lllul% 24.Nov.97 page 65of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM 0: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~asa~a ~m cTS MtU SR 4.8<1 m1 - Change LA would allow verification of 11t20I87: This is a repeat 11j20l&7i A review of the SSES ITS Open4$ RC to Page 3li ategory A limits every 7 days to be extended for up issue of NRC RAI 3.8A-13.

' tennined that there was a concern evaluate

-11a o 4 days ifthe affecled battery has been on e Frequency extension is the wording of SSES ITS LCO proposed uahzing charge, This appears to be acceptable for only identifying that during 3.$ .6, which states "..Mtteries shall change.

lectrolyte level and specific gravity. However, the an equalizing charge be within the limits of Table 3.8.6-1." PP6L will dditional 4 days for float voltage is not understoocL ingful data cannot be e concern with this statement is provide M/U ln LCO 3.8A, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is considered adequate time ottected. Therefore, the hat Table Ml.6-1 provides all three of SSES ITS.

for float voltage to stabilize following an equalizing note provide an exception to battery limits "category A. 8, and Repeat, see barge. What is different here? Also, the 24 days perform the test. The C". Category A and B Umits are NRC RAI 3JIA-limit should be moved up into the proposed Note - It Category A limits willbe met invoked through Surveillance 13.

is confusing in the frequency column. uring this period so no Requirements while Category C ception to the SR is limits are only invoked ifthe LCO is NOTE: This, and the corresponding change in LCO needecL not met. Therefore, the wording of 3.8A are beyond scope and should be perused as he LCO should be changed to state.

generic Issues by TSTF. hat the battery is within Umits and liow the Specilication SRs and NOTEiUThis submittal is poorly annotated. It is not ction Table to invoke when the possible to establish, with any degree of certainty, limits are applied. This change is al change are applicable Io LCD 3.$ A and what considered necessary to ensure a changes are applicable to LCO 3.8.6. consistent application of the SSES ITS.

NUREG Table 3.8.6-1 P.6 - Deletion of the Bases material is 11QOI97: PPL to review submittal Repeat, see f3.$ .6-10 'jP 6 (

) )

not acceptable because deletion of the corresponding and clarify that adopting IEEE 460 NRC RAI 3.8.6-page B3.8-70 TS requirements is not acceptable. See convnents 1996. 02 re: Changes to Footnote (c) in NUREG Markup for Table 3.$ .6-1.

- SSES lrriprovcrcf Tecfirn<<( hfic c chcifrcaus 26 Nov-97 Page 66 of 75 NRC RAls

SECTlON 3.8 NRC RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFO: TS LCO: DESCRIPTION OF ISSUE: NRC'COMMENTS: SSES RESOLUTION: STATUS K$.$ -1~2 ~PB MUREG page 3.8-31 SR 3.8.8.1, Insert EEL%

8.84141- P2 Need inputs from ~ No actions required. Closed

- SSFS Irrrprovwf Tc lirirci) Spec ific itrcirra 24*Nov-97 Page 6 7of 75 NRC RAls $

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEMi ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS 3.8.7 Distribution systems-Operating NUREG LCO 3.8.7 - Change P.1 is Not Acceptable. Proposed See CTS M/U page 3/4 8-17. All CTS Closed (NRC 3.$ .741 P.1 able 3.8.7-1 does not reflect NUREG-1433 or CTS Buses are included with the closed page 3.$ -

requirements regarding electrical distribution exception of the swing bus which is 11/21/87)-

subsystems (See CTS LCO 393.1+.1.bA) the overedby LCO3.5.1. Change in PAL will submittal should be revised to correct this problem. format was necessary to more clearly provide M/U define LCO requirements. of SSES ITS.

PAL lo correct SSES ITS Table reference correct voltages (Unit 1 000 2 200la 20 VAC va. 2 0 ala~80 VAC See NUREG M/U pages 3.848/38. Closed (NRC N UREG Action A. P.7 - The proposed addition to the Bases is I

described as an editorial change necessary to reflect rNUREG 1433 Specifications allows closed t/ie SSES design. The start does nut agree that this is the allowance described in the SSES 11/21/87)

LD 841 an editwiat change. to the contrary, addition of the ITS Bases revision. As stated the Bases were not as clear as the piutiused material, in c ombinauon with the Bases mateiiat proposed lor deletion, conshtutes a specification so small wording substantial/y less restnchve requirenient lhan CTS changes werc incorporated.

which has not be lustified. The hcensec should review this issue (including comments ont he CTS

,markup-sane subject) and provide a detailed ustification of why the less restriclive change is applicable to and appropriate for inclusion in the SSES ITS.

Page 68 r/

HRC RA)s - SSES0/lr>I/ruvr/d Terclrrnca/ SputifiL ~ fiiuia 24-Nov-97

SECTION 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUT(ON: STATUS

~8.743 PE NUREG LCO 3.8.7, Condition B - Change P.2 is Not Acceptable NUREG 1433 M/U will be revised to Closed (NRC page 3.8- because (1) DOD P2 does not appear on the markup properly cross reference JFD PA. losed 38 of LCO 3 Jl.7 and its applicability cannot, therefore, be JFD PD will be revised to clearly 11/21/97)-

lermined, and (2) the narrative provkled as DOD P2 state SSES is not designed viith vital Ppe,L will references LCO 3.8.7, Condition B, but the entire buses therefore, Condition B is not provide iscussion addresses something completely different a lica hie. revised han what Is in NUREG-1433. NUREG M/U.

nd M/U of FD P2.

~8.74l P.3 NUREG LCO 3.8.7, Condition DAE - Change P. 3 is acceptable Closed Evaluate adding default conditions. losed (NRC

] page 3.8- as far as it goes. However, there is not default closed ondition associated with Condition D and E. PPE L has determined that default 'l 1/21/97)

Consequently, failure to comply with the Required ondilions are not necessary.

tions of either Condition would result in entry into 3.09.3 This should be conected.

I3.8.74S NUREG NOTE: The 2nd parag<aph ol lhis Bases discussion propriate changes to the Bases Closed (NRC page Js not consistenl witlithe proposed change in the 1st ll be incor mrated. dosed B3.8~S iagraph. As proposed, this Aciton would allow 11/21/ST) ~

re than one DC bus lo be inoperable. That means PPSL will l more than one division could be without provide M/U uate DC power, but the Bases discussion (from I SSES ITS.

2nd paragraph on) only discusses a SlNGLE DC bus inoperability. This inconsistency should also be addressed if the proposed change lo the 1st paragra ph can be justified.

This Note is also applicable to the latter part of the Bases discussion for Action A1.

NRC RAIS .- S SF S /lire/roved Ta i /NNc ~ / S/Nrc itic'if/EEris 24 Noi/-97 Page69uf 75

SECTION 3.8 NRC RAIs SSES Improved Technical Specifications ITEM 0: DOC/ JFD'S LCO'ESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~$ .745 ~PA NUREG LCO 3.$ .7. Condition H - Change PA involves addNon See Unit 2 SSES CTS page 3/4 8-18a. Closed (NRC page 3.8- f Conditions H and L Condition H is identified In CTS Action d the closed 3$ understandable. However, Condition I does not make SSES ITS allowances are pari of 11/21/97) sense. Ifa required Unit 1 electrical power SSES Current Ucensing Basis. In distribuUon subsystem is inoperable AND the response to the above identified Required AcUons of Condition H are not met, how is questions this is a Unit 2 resulting plant status any different than that Specification. So for Unit 2 addressed in Conditkes A or 8? In this same vein, appropriate Actions need to be taken y should the Required Actions af Condition I be for the consnon loads.

'tferent than those in CondiUon B or B? The proposed change must be considered Not Acceptable Conditions A and B are different in unUI these uestlons are uatel answererL hat they only apply to Unit 2 Distribution Systems, while, onditions H and I apply to Unit 1 Distribution Systems which for Unit 2 nly supply the convnon loads. The al/owance of having cansnon loads ansfered temparartally to Unit 2 istribution systems is acceptable d provides the ability to maintain Unit 2 in operation.

f$ ,747 ][ )

NUREG page tion B.1lnsert B3.84641 - The insert states that Conditon 0 Is modified by a Note. Should this not NUREG M/U and SSES ITS Bases will Closed (NRC be modified to identify the correct referernce to conditions.

closed 11/21/97)-

B3.846 read Canditon B is modified?

PAL will provide M/U af SSES ITS.

NRC RAh - S Sf S /rripr uvrrcf Ter hi>>ca/ 5 pic /fir.itivria 24-Hov-97 Page 70 of 75

SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM I/:

~3,874$ ~

DOCIJFD: TS LCO:

TS MIU page 3I4

-19 DESCRIPTION OF ISSUE:

LCO 3.8.3.142 ?Question? Why is the DG E RVVdc bus retained In this TS? This DC subsystem only serves DG Fand Its failure means that DG E Is inoperable. The Note in proposed Condition H of ITS NRC COMMENTS: SSES RESOLUTION:

DG E Bus was retained because there are two possible conditions DG E can be in. Either supplying a required bus or not. In each case, the STATUS Closed (NRC closed 11/21/97)-

PPCLto LCO ML7 represents a potential 3.0.3 situation required actions are different and provide because the LCO does not indude an Action for DG E st be stated. revised n its DC bus ls Inoperable. This item requires NUREG MIU.

e discussion. phfs Item is also applicable to Unit NUREG M/U insert does not match

1. SSES ITS. Correct NUREG M/U.

8.749 NUREG he SSES ITS include Condition's A 4 B which use See NUREG M/U pages 3248/39. Closed (NRC page 3.8- the tenn "one or more" with respect to inoperable AC NUREG 1I33 Specifications allow the closed 39 and DC electrical subsystems, respectively. In allowance described in the SSES ITS 11/21/97) adddion, Condition F is added which addresses "Two Bases revision. As staled the Bases or more -- loss nf function." These Conditions ere nol as clear as the specification retueserif ~ substant& change (less reslrictive) from so small wording changes were C I S iequuemeots wtuch has not been adequately incor porated.

justified Abseiu an adequate iushlication, conwdeiaiion should be given lo deleling "one or moie from Conditions A4 B, and deleling Condition

,F enluely.

NRC RAls" SSES lrffprovutf Tt'cfirui.~ I Sffvc.rhcafrorrs 24-Nov-97 pago 71 of 75

SEGTlON 3.8 NRG RAls SSES Improved Technical Specifications ITEM¹: DOCIJFD: TSLCO: DESCRIPTIONOF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~87rt.0 ~Pl .NUREG SR 3.8.7.1 - The narrative of DOD P.7 indicates that See SSES ITS 3 8 7 DOC L2 As Closed (NRC page 3JI- proposed changes are editorial. This does not indicated, exact voltage levels are losed 3$ ppear to be the case. NUREG-1433 and the CTS not available for all AC or DC buses. 1 tl2157)-

both require a voltage check as part of this SR. A Therefore, the wording change was PAL wN oltage check is not the same as "indicated power necessary to ensure appropriate provide vailabNty as proposed by this change, and the understanding of the requirements. revised SSES, hange from voltage check to the proposed ITS.

requirement does not appear to be editorial in nature. PP8 L will provide option in SR to s part of the submittal should be revised either read indicated power or verify a r tel . yottte.

NRC RAls - SSES frr~overt Tec tnuc & 5 pecdK abcrrt s 24-Hov-N Page72of 75

k SECTION 3.8 NRC RAls SSES Improved Technical Specifications ITEM fl: DOCIJFD: TS LCO: DESCR)PTION OF (SSUE: NRC COMMENTS'SES RESOLUTION: STATUS Distribution Systems- Shutdown

~A$ 41 ~$ NUREG LCO 3$ Al, Condition 8 - Addition of Conditon Determine if alternative conditions Closed (NRC page 3AI- (Chagne P.8) is acceptable. However, Condtion 8 are required. closed oes not have a default Condition; Le., what happens 11I21I97) ifthe Required Actions of CondNon 8 are not met. PP8 L has determined that alternative e submittal should be revised to address this item. onditions are not r uired.

8.842 P.6 NUREG LCO $ .8.8, Conditon A - Change P.6 is confusing. lt Q Submittal will be corrected to identify Closed (NRC page $ .8i refemces Insert 3Al414L However. the submittal orrect inserts. losed includes insert 3 Jl-2841 which does not appear to 11I21I87)-

"fit"into LCO 3'.8. The submittal shouldb e PAL will reviewed and the correct insert provided. provide corrected UREG MIU.

I$ .8.84$

',. P.4 NUREG,SR $ .8.8.1 - Change PA >>>c~f Spvcrfrcabvns 24-Hov-97 Page 73 of 75

SECTION 3.8 NRC RAls SSES improved Technical Specifications ITEM ¹: DOC/JFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~g.m4l ~PS NUREG ctions P.'3 insert B3.84141- The proposed Bases insert B3.841 08 will be changed as Closed (NRC addition is acceptable. However, the Bases follows: "This Is acceptable because closed B3Jl41 iscusslon should be expanded somewtrat to more LCO 3.0.3 would not specify any 11/21/$ 7)-

completely address why LCO 3.0.3 should not be additional acbons while in Modes 4 PAL witt ppgcabie. or 6 moving irradiated fuel provide M/U assemblies." f SSES ITS da M/Uof 11/20/87: Incorporated changes to .BJ! JFD PD.

FD PD to Cari need for change.

NUREG page

$ 41 ions P.6 Insert B3.84141 The proposed Bases addition only addresses Unit 2. Where is the applicable language for Unit 12 The licensee shoWd

~ NUREG M/U will be annotated to showchan eforUnit1SSESITS.

Closed (NRC closed 11/21/87)-

provrdc t/us information. PPBL will provide revised UREG M/U.

P.846 jiM.1' CTS M/U LCO 3'.3.2.b - Change M.1 appears to be incorrect. The change addressed is the SSES Cfosed (NRC 3/4 'age Delelion of lhe word addi confusion with respect to ITS does not require a minimum losed 8- at DC power distribution systems must be number for the distribution system, 11/21/87)

OPERABLE. but instead specifies the equired buses must be available to support thc required equipment. The DOC M.1 addresses this chancre.

NRC RAls - SSES lrtrprovat 1 w irrrrc u 5 pecrfrc elena 24-Hov-97 Page 74 of 75

SECTION 3.8 NRG RAls SSES Improved Technical Specifications ITEM ¹: DOCIJFD: TS LCO: DESCRIPTION OF ISSUE: NRC COMMENTS: SSES RESOLUTION: STATUS

~asar ~~ crs attn LCO S.SABA.Ld, LCO 38.3-2.bAA - Change LA2 is Not Acceptable. See conxnents. re: change LIL1 for Repeat, see NRC RAI 3.8A-10. Repeat, see RAIMA-page 3I4 NRC LCO SAA. 10 Ksg4s /~ac rs attu LCO 3442, Action b, LCO S Jldd, Action c - Change hta DOC M.a ahanga waa maCh tn losed (NRC page SI4 M.1 is acceptable. However, there is a question onnection with the change to the sed

-21 regarding whether or not addition of the option'o LCO requirement. Although it is true 1tl21IST) e associated supported features inoperable is at this change alone can be re restrktive. Since this addition provides an that didnot previously exist, it would appear 's onsldered a less restrictive change, more appropriate to take this his change is actually less restrictive. A revision to change ln context with the change to e submittal to rellect this should be considererL the LCO whkh was determined to be More Restrictive.

PP8 L has determined that the presentation is sufficie~ntl clear.

NRC RAIs - SSES Inyuoved Techn~al Specrfrcrboria g4-IttIo v-97 Page75of 75

tl t 'd ~

gag 3. Q. I(--oi d

iggg 5.8. o~

AC Sources -Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System: and

b. Four diesel generators (DGs).

APPLICABILITY: MODES 1. 2, and 3, saic.ig r I~ f.rpe 4q

-NOTE---- oP When an OPERABLE ali nment of DG E diesel generator is placed in an inoperable status fa to or from the Class 1E distribution system, SR-8.~1

~.

prior entry into associ ted Cond t'o and Required Actions may be delayed for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> i~~ decl ~~

LPSBJ 6  % ~

o<~

vs

'r CONDITION REQUIRED ACTION COMPLETION T ICE A. One offsite circuit A.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuit.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> I'~See T ~ <' thereafter

~AN A.g Restore offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuit to OPERABLE status.

6 days from discovery of failure to meet LCO t~

(continued)

A.z>>ail~ p SUSQUEHANNA - UNIT 1 3.8-1 d d

gg.g gAX Ae.i-a~

XQ.l -oi AC Sources -Operating 8 3.8.1 BASES (continued)

ACTIONS The ACTIONS are modified by a Note which allows entry into associated Conditions and Required Actions to be delayed for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when an OPERABLE diesel generator is placed in an inoperable status for the alignment of diesel gener ator E to or from the Class 1E distribution system. Use of this allowance requires s v both offsite circuits pc4~e ko e. Entry into he appropriate Conditions and Required Actions shall be made imaediately upon the determination that substitution of a requir'ed diesel generator will not or can not be completed.

To ensure a.highly reliable power source remains with one offsite circuit inoperable. it is necessary to verify circuit the availability of the remaining required offsite on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

How'ever, if a second required circuit fails SR 3.8. 1. 1.

tl.e for second offsite circuit is inoperable, and Condition C, two offsite circuits inoperable. is entered.

T~so-4 63 8-C "i A~5 According to Regulatory Guide 1.93 (Ref. 7). operationexceed i:.ay continue in Condition A for a period that should not 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the plant safety systems. In this condition. however, the remaining OPERABLE electrical offsite circuit and CGs are adequate to supply power to the onsite Class lE Oistribution System.

the capacity The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completicn T:-..e takes into account of the re-aining sources, reasonable tim and capability AC

~

for repairs. and the l probability of a OBA occurring during this period.

The second Comoleticn T

-e for Required Action A.2 for any establishes a limit cn tre maximum time allowed Ax (continued) 9.6 Amendment SUSQUEHANNA - UNIT 1 B 3

Akc. gag S,e.<-aZ 3 9.I -O~

AC Sources -Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3 '.1 AC Sources -Operating LCO 3.8.1 The following AC electrical power sources shall be OPERABLE

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Four diesel generators {DGs).

APPLICABILITY: MODES I. 2. and 3.

ACTIONS s~l~l g ~ I

-NOTE When an OPERABLE diesel generator is placed in an inoperable status ali nment of DG E to or from the Class 1E distribution system. ~~1 C~~

prior entry into associ ted Cond t'o and Required Actions may be delayed for up to S hours sr~ ace CONDITION REQUIRED ACTION COMPLETION Tf4E A. One offsite circuit A.l Perform SR 3.8.1.1 I hour inoperable. for OPERABLE offsite circuit.

Once per S hours T&Sf.'R.T ~ ~'1 thereafter A~It A.g Restare offsite 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> circuit to OPERABLE status.

6 days from discovery of failure to neet LCO t~

(continued)

A, lit.f/tg SUSQUEHANNA - UNIT I 3. 8-1 d

INSERT 3.8-1-1 (NRC RAI 3.8.1-02):

A.2 Declare required 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> fram feature(s) with no discovery of offsite power available no offsite inoperable when power to one the redundant 4.16 kV required ESS bus feature(s) are concurrent inoperable. with inoperability of redundant required feature(s).

Alkc A.Qz 3,8. (-gZ AC Sources -Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C ~ Two offsite circuits C.l Restore one offsite 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> inoperable. circuit to OPERABLE status.

Alftp+' 8 ~ OI D. One offsite circuit D.l Restore offsite 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable. circuit to OPERABLE status.

AND One required DG inoperable. D.2 Restore required DG 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to OPERABLE status.

E. Two or more required E.l Restore at least 3 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> DGs inoperable. required DGs to OPERABLE status.

F. Required Action and F.l Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Associated Completion Time of Condition A. ~AN B. C. D. or E not met.

F.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> G. One require DG and G.l Ente applicable I iately two offsit circuits Co itions and inoperabl for one R uired Actions of 4.16 kV SS bus. CO 3 8.7, "Distr>bution Systems -Operati (continued)

SUSQUEHANNA - UNIT 1 3.8-3 Amendment A. 07/31/96

INSERT 3.8-3-1 (NRC RAI 3.8.1-02):

NOTE Enter spplioettle Conditions And Required Actions of LCO 3.8.7, Distribution Systems-Operating, when Condition D is entered with no AC power source to any 4.16 kV ESS bus.

AC Sources -Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TINE B. One required DG B.1 Perform SR 3.8.1.1 1 hour inoperable. for OPERABLE offsite circuits. AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter AND B.2 Declare required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from feature(s) supported

~ discovery of by the inoperable DG. Condition B inoperable when the concurrent with redundant required inoperability of feature(s) are redundant inoperable. required feature(s)

AND B.3.1 Determine OPERABLE 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> DGs are not inoperable due to common cause fai lure.

OR B.3 ' Perform SR 3.8. 1.2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for OPERABLE DGs.

OR 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to entering Condition B AND B.4 Restore required DG 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to OPERABLE status.

AND 6 days from discovery of failure to meet LCO t~

(continued)

I d ~ ~ d f

SUSQUEHANNA - UNIT 1 382 d d

AlA.C kAZ 3 S./-oy AC Sources -Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. One or more offsite ,H.l Enter LCO 3.0.3. Immediately circuits and two or more required DGs inoperable.

One required DGs an two offsite circuits inoperable SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Veri fy correct breaker alignment and 7 days indicated power availability for each offsite circuit.

(continued) g.) o~l(sf~r SUSQUEHANNA - UNIT 1 3.8-4 I A-.OilRIV

N Qc .gAg 3.8. I-oZ.

AC Sources-Operating B 3.8.1 BASES (continued)

LCO Two qual1fied circuits between the offsite transmiss1on network and the onsite Class 1E Distribution System and four separate and independent DGs (A. B. C and 0) ensure availability of the required power to shut down the reactor and ma1ntain it in a safe shutdown condition after an antic1pated operational occurrence (AOO) or a postulated OBA. OG E can be used as a substitute for any one of the four DGs A, B. C or D.

Qualified offsite circuits are those that are described 1n the FSAR, and are part of the licensing basis for the unit.

In addition. the required automatic load timers for each ESF bus shall be OPERABLE.

The Safety Analysis for Unit 2 assumes the OPERABILITY of some equipment that receives power from Unit 1 AC Sources.

Therefore. Unit 2 Technical Specifications establish requirements for the OPERABILITY of the DG(s) and qualified offsite circuits needed to support the Unit 1 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.7, Oistr1bution Systems -Operating.

Aore~

ore~~<

Each offsite circuit must be capable of maintaining rate frequency and voltage. and accepting required loads during an accident, wh1le connected to the ESS buses. offsit circuit consists of r~eeh4ve respective c g@KQQ ST No. 10 and No. 20 B< in 1

~ )] p transformers, and the including feed g Sag eakers t ~

Four of the five OGs are required to be Operable to sat1sfy the initial assumptions of the accident analyses. Each required DG must be capable of starting. accelerating to rated speed and voltage. and connecting to its respective ESS bus on detection of bus undervoltage after the normal and alternate supply breakers open. Th1s sequence must be accmelished within 10 seconds. Each OG must also be capable of accepting required loads within the assumed loading sequence intervals. and must continue to operate until offsite power can be restored to the ESS buses. These capabilities are required to be met from a variety of initial conditions. such as OG in standby with thestandby engine hot and DG in normal stancby conditions. Normal conditions for a DG mean that the diesel engine coolant and oil are being continuously circulated and temperature (continued)

SUSQUEHANNA - UNIT 1 B 3.8-4 Amendment A .,07AXAki Ili. ri t;i "~ ~

INSERT 83.~1 NRC RAI 3.8.W)2):

5o at least thrie of the .16 kV ESS bus f at least one of e two circuits d not provi power rrsno eof pro iding powerto all our4.16kV ESS uses, the the .16 kV E buses each ci it powers or is able of powerin cannot ai the arne(i...twofeed rbreakers noneUnit14k emergencybus nnotbe

'n rable)

Provide.ck uo 'l.l C. gV E,SS Icag 0 Le~ owe. Qtgeggygp 9~c,t itic.8 opsis) +

5+Pl gq~~ +~ ~ <<'~ I~g~

J 5t'c~ 4 cak~ om o&c f kV Ceeryuc.~ 4m~ ca~~o+ 4

>~opc bg)

Lca o

~g.g kAX >R.l-O~

~ 0.1 -oi AC Sources -Operating B 3.8.1 BASES (continued)

ACTIONS The ACTIONS are modified by a Note which allows entry into associated Conditions and Required Actions to be delayed for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when an OPERABLE diesel generator is placed in an inoperable status for the alignment of diesel generator E to or from the Class 1E distribution system. Use of this allowance requires loi.

v s

both offsite circuits p~~

e. Entry into z~~o.h,b~k he appropriate Conditions and Required Actions shall be made immediately upon the determination that substitution of a requir'ed diesel generator will not or can not be completed.

To ensure a highly reliable power source remains with one offsite circuit inoperable. it is necessary to verify the availability of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met. the However. if a second required circuit fails SR 3.8.1. 1.

second offsite circuit is inoperable. and Condition C, for two offsite circuits inoperable. is entered.

T+Scg+ 63.B-C-t A~5 According to Regulatory Guide 1.93 (Ref. 7). operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. With one offsite circuit inoperable. the reliability of the offsite system is degraded. and the potential for a loss of offsite power is increased, with a'ttendant Dotential for a challenge to the plant safety systems. In this condition. however . the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Oistribution System.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Tine takes into account the capacity and capability of the renaining AC sources. reasonable tim for repairs. and the lcw probability of a OBA occurring during this period.

The second Comoletion Ti".e for Required Action for any A.2 establishes a 'limit cn the maximum time allowed A~

(continued)

- UNIT 8 3.8.6 Amendment SUSQUEHANNA 1

Hite RAZ ~.8.[-og AC Sources -Operating 8 3.8.1 BASES 3

ACTIONS +A (continued) combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet

.the LCO. If Condition A is entered while, for instance. a OG is inoperable, and that OG is subsequently returned OPERABLE. the LCO may already have been not met for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This situation could lead to a total of 144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br />, since initial failure to meet the LCO. to restore the offsite circuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (for a total of 9 days) allowed prior to complete restoration of the LCO. The 6 day Completion Time provides a limit on the time allowed in a specified condition after.

discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and 8 are entered concurrently. The "AND" connector between the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 6 day Completion Times means that both Completion Times apply simultaneously. and the more restrictive Completion Time must be met.

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock."

This exception results in establishing the "time zero" at

'he time the'LCO was initially not met. instead of at the time that Condition A was entered.

To ensure a highly reliable power source remains with one required DG inoperable, it is necessary to verify the availability of the required offsite circuits on a more frequent basis. Since the Required Action only specifies "perform." a failure of SR 3.8. 1. 1 acceptance criteria does not result in a Required Action being not met. However. if a circuit fails to pass SR 3.8. 1.1, it is inoperable. Upon offsite circuit inoperability. additional Conditions must then be entered.

Required Action 8.2 is inte~ded to provide assurance that a loss of offsfte power. ."u.".ng the period that a DG is inoperable. does not result in a complete loss of safety (continued)

SUSQUEHANNA - UNIT 1 8 3,8 'mendment A. 07/31/96

INSERT B3.~1 (NRC RAI 3.8.142):

A,2 Required Action A.2, which only applies if one 4.16 kV ESS bus cannot be powered from any offsite source, is intended to provide as'surance that an event with a coincident single failure of the associated DG does not result in a complete toss of safety function of critical systems. These features (e.g., system, subsystem, division, component, or device) are designed to be powered from redundant safety related 4.16 kV ESS buses.

Redundant required features failures consist of inoperable features associated with an emergency bus redundant to the emergency bus that has no offsite power. The Completion Time for Required Action A.2 is intended to allow time for the operator to evaluate and repair any discovered inoperabilities. This Completion Time also allows an exception to the normal "time zero" for beginning the allowed outage time "dock." In this Required Action the Completion Time only begins on discovery that both:

a. A4.16 kV ESS bus has no offsite power supplying its loads; and

b. A redundant required feature on another 4.16 kV ESS bus is inoperable.

If, at any time during the existence of this Condition (one offsite circuit inoperable) a required feature subsequently becomes inoperable, this Completion Time would begin to be tracked.

Discovering no offsite power to one 4.16 kV ESS bus of the onsite Class 1E Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with any other emergency bus that has offsite power, results in starting the Completion Times for the Required Action.

Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before the unit is subjected to transients associated with shutdown.

The remaining OPERABLE offsite circuits and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection may have been lost for the required feature's function; however, function is not lost The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITYof the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occumng during this period.

h),kc. Rhg. Q,g (

AC Sources -Operating B 3.8.).

BASES ACTIONS

{continued)

Required Aetio G. 1 address the situation where the inoperability of multiple AC Sources results in the de-energization of one 4. 16 ESS bus. Although LCO 3.8.7, "Oistributi n Systems -0 crating." provid more appropriate ACTIONS fo this situat on, LCO 3.0.6 wo d permit pot entering he Distribu on System ACTIO even sources o one 4. 16 buses were if aN AC ESS noperable Therefore.

the Re ired Action . 1 specifies th when Con tion G iS enter with no AC ource to any E bus. ACTI S for LCO .8.7, "Oistr'tion Systems perating." must be red imediat y. LCO 3.8.7 rovides th appropr ate 'nt re trfctions fo one or more d energized .16 kV S buses i eluding requ rements that a ress the p tentia for loss of function. f more than o e 4.16 kV energized. Conditions E and H are appli able.

S bus 'e-Condition H corresponds to a level of degradation in which all redundancy in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore. no additional time is justified for continued operation. The unit is required by LCO 3.0.3 t:o comence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and REQUIREHENTS testing of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50. GOC 18 (Ref. 9). Periodic component tests are supplemented by extensive functional tests during refuelir g outages (under simulated accident conditions). The SRs for demonstrating the OPEP~BILITY of the DGs are in accordance with the recommendaticns of Regulatory Guide 1.9 (Ref. 3).

Regulatory Guide 1. 1CB (Pef. 10). and Regulatory Guide 1. 137 (Ref. 11). as addressed in the FSAR ~

The Safety Analysis for L'nit 2 assumes the OPERABILITY of some equipment that recei.es power from Unit 1 AC Sources.

Therefore. Survei liar ce requirements are established for SUSQUEHANNA - UNIT 1 B 3.8-13 d d t~ (continued) ii ft 4 li 7

(Q 3/4.8 ELECTRICAL POSER SYSTENS 3/4.8.1 A.C. SOURCES A. C. SOURCES OP ERAT INO LINITINO CONDITION FOR OPERATION LCO 3.8.1

~~

OPERA8LE:

-As a afnfeea, the folloving A.C.~ electrical povet e

sources 5 urcas sha sn ll beb Tva ph sica ndebendent cfrcufts betwen the ofi'site netvor an4 tne onsste ass 1E dfstrfbutian systaa transeission

'K Faut'f the five se arete an4 fndaEenden,~diesel and

~n.~

generators~,

l

.Se arete engfne counted day fuel tanas gP 3.8.).g of contafnfng a efnfeum of fuel, I I A s erato fuel storage systee containing a efnfaue SP.$ 8.3 I ,57 gallons. of fuel for dfesel generator of gallons for 4fesel generator E, and A, 8, C and 0; and QQ 3.E.l I M A separate fuel transfer puep. If ii APPLICABILITY: OPERATIONAL CONDITIONS 46ROI: Add Lao 3.KS A~

1, 2. and 3.

A,c DE~F.~Sr-v~ L r~

~.A Wfth one offsfte cfrcuft sources f noperable:

af the above 3.8..a required A.C. paver 3

A.4 Q. lid. 1 ~

Perfora Survefllance Requfreeent 4.8.1.1.1.a vfthfn and at leaat OnCe per 8 haurS thereafter, and one hour 20 For each f the ~ OPERA8LE, aWgned dfesel generators:

/

ao rf fy S ofllance R freeent 4..1.1.2.a.4 successf ly perfo vithfn last 24 ha,as arbee QL Perfo Survef 1 lane Reauireae 4.8.1.1.2..4 s tfa'lly an e diesel g nerator vith n 24 hdurs, and vfth Unf<

f dfatrfbutfon g

herod ror a parfo4 of efgic s stoa. If An OPBIASLE diesel generator eay be reaoved froe service rs a g vhen al fgning disso'I generator E to the Class 1E C of 4i sel genera ar s no e vft~Tn el ur the rfate TION vi foll ffe4 tfae

fn vfll be . The s 1 f ts ON ~ eeasu free t<ee al mant of df ~1 generator i gan, th the CaPtfan the f tfal perf Ce Oi'u efilande

'. equi eaent 4.

ithe eterafna Ll.a. The tf lf~ it for . ~ .1.1.1.a 11 be aces froe on that fesel g orator E l I not or c no he alf ed transfo no yo o c rcuf s fnoper fty o an r, only th dfesel rators a cfated v operable E transforms're nquf to be tes SUSQUEHANNA - UNIT 1 g/g tel

ucc Rhz 1 8i- s r DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING' M l4'Ag sr -oh T HN A HANG - R TR T V (continued) 7hi~ <~ye current practice at SSES which is to manually top off the day alctc 0Ja.o~ dig tanks every time the DGs are operated to satisf a desi n commitment in FSAR 9.5.4.2 that requires the day tank contain war Ls~ ~~"~~. ufficient fuel for one hour of operation at continuous o

rated load yr J~ T~M~ hich is based on tion 6 1 To

~IC ~

I im e current practice of manually topping of t e y e~brc o% anks every time the DGs are operated. the Bases for ITS SR o~c L<<r e pie,Q .8.1.4 will indicate that the acceptance criteria for this SR

~Ac. of +vc,L ~ il er-'yfd rovides approximately 45 minutes of operation at the post Geca sc. qa peWP ~w ~~ ~*>

g qua.4r

~s

ccident load. Prior to implementation of Improved Technical pecifications at SSES. FSAR 9.5.4.2 will be revised to take xception to ANSI N195-1976. Section 6.1. This change is

.Se4 + n <<a,/ acceptable based on the following: day tank level is verified 4+~ i g yves every 31 days which ensures that each OG will have sufficient fuel Or'4el 0L~ ~yg( J ail to start and operate for at least 45 minutes: day tank levels bc a r~sk are maintained automatically during DG operation by the fuel oil i OG Da~

duo~~ mu~rr.

transfer system which is tested every 31 days by SR 3.8.1.6: and.

low level alarms on DG day tanks are set slightly below this level and will provide adequate time for operators to investigate and correct or compensate for a diesel fuel oil transfer pump failure.

Additionally, calculations supporting 45 minutes of DG operation are based on fuel oil consumption calculations that are very conservative. Specifically. the DG post accident load for all DGs is assumed to be equal to the OG with the highest post accident load: OG fuel consumption rates're assumed to be equal to the highest consumption rate observed for any of the DGs: and, assumptions about fuel oil specific gravity included using the highest heat value fuel during observations of fuel consumption r ates (lowest fuel consumption) and lowest heat value fuel during accident conditions (highest consumption). Therefore. minimum day tank volumes based on 45 minutes of OG operation at the post accident load does not have a significant impact on safety.

HN A P T N The Bases of the SSES CTS for this Specification have been replace y Bases that reflect the format and applicable content of SSES ITS 3.8.1 consistent with the BWR STS, NUREG-1433..Rev. 1.

SUSQUEHANNA UNIT 1 AND 2 23 Revision 0. 07/31/96

INSERT (NRC RAI 3.8.1-02):

L.17 SSES CTS 3.8.1.1 requires two physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system. Although the SSES CTS does not define the specific lineup required for the offsite circuits, it is PP&L's current position that an offsite circuit is considered Operable when it can supply all four 4.16 kV ESS Buses. SSES ITS 3.8.1 also requires two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System, but in the SS rable source is only required to supply three of the .16 kV ESS buses needed to be powered or capable of being powered, provided that all 4.16 kV buses are supplied by acr Opereb!9 offsite circuit. This change is acceptable because it maintains the req irements of General Design Criteria (GDC) 17. GDC 17 specifies that "Each of o~c y<,'< ese circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shalt be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained." As stated, the SSES ITS Bases definition of what constitutes an Operable Offsite circuit will allow two of the four required ESS Buses to only have a single Operable Offsite circuit. Reviewing the GDC 17 requirements, it can be shown that this configuration will meet those requirements. First, in the loss of power event where all onsite power sources were lost, and the other Offsite Source is tost, the three available 4.16 kV ESS Buses will remain powered. For a Loss of Power Event assuming no other single failures, the three available 4.16 kV ESS Buses'are sufficient to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded.

Finally, with the automatic transfer capability provided for the Offsite Sources (tested in SSES ITS SR 3.8.1.8), one Offsite Power Source will be available (within the time assumed in the Accident Analysis) to assure that core cooling, containment integrity, and other vital safety functions are maintained.

The change also inv Ives adding SSES ITS Required Action A.2 to ensure that with an Offsite Circuit i rable no redundant required feature is inoperable such that a total loss of functi nII uld occur. Furthermore, a note is added to SSES ITS Required Action dentifying that if one offsite circuit and one DG are inoperabi ~

and it results in a total loss of power to a 4.16 kY ESS Bus then Actions per LCO 3.8.7 shall be taken. These. changes are necessary to ensure that the proper actions are taken with the loss of AC Sources considering the allowance provided by the definition of Operability.

Based on the fact that the allowed conditions meet GDC 17 requirements and appropriate modifications have been made to the SSES CTS Actions to ensure appropriate actions are taken with the ioss of AC Sources, this less restrictive change will have no measurable effect on safety.

I

ABRI', VZ I4.1-OY AC Sources-Operating B 3.8.1 SURVEILLANCE (continued)

REQUIREHENTS when OG E fs tested with a Unit 1 4.16 kV ESS bus. the attributes of the normally aligned OG. although not tested with the Unit 1 4.16 kV ESS bus. are tested with the Unit 2 4.16 kV ESS bus within the 24 month Frequency.

Under accident conditions. loads are sequentially connected to the bus by individual load timers which control the c ,~,~ ~ .,~ permfssfve and starttng signals to motor breakers to prevent over loading of the AC Sources due to high motor starting

~~+ 4 urrents. The load sequence time interval tolerance ensures

~>so iM hat sufficient time exists for the AC Source to restore req uency and voltage prior to applying the next load and

~ s~r~

S saet4 e~ that safety analysfs assumptfons regardfng ESF equfpment t time delays are not violated. Reference 2 provides a sLNrliary of the automatic loading of ESS buses. A list of

+ <S.r.r-/ the required timers and the associated set otnts are Secluded $ n the Bases as Table B 3.3.1-1. I)nit 1 and Umt 2 Load Timers. Failure of a timer identified as an offsite power timer may result tn both offstte sources being inoperable. Faf lure of any other timer may result fn the associated DG being inoperable.

The 24 month Frequency ts consistent wfth the recoirmendatton of Regulatory Guide 1.9 (Ref. 3}. takes into consideration plant conditions r equired to perform the Survefllance. and is intended to be consistent with expected fuel cycle lengths.

This SR fs modified by a Note that specifies that load timers associated with equipment that has automatic initiation capability disabled are not required to be Operable. Thfs fs acceptable because tf .the load does not start automatically. the adverse effects of an improper loading sequence are eliminated.

In the event of a 08A coincident with a loss of offstte power. the DGs are required to supply the necessary power to (continued)

SUS(IEHANNA - UNIT 1 8 3.8-30 Ariendment A. 07/31/96

AC

~a<

Sources -Operating a<z, 3.8.1 SURVEILLANCE REQUIREHENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.P -NOTES-

1. OG loading may include gradual loading as recomended by the manufacturer.

2. Homentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4 This SR shall be preceded by and imiediately follow. without shutdown, a successful performance of SR 3.8. 1.2 or SR 3.8.1.7.

5. OG E. when not aligned to a 4.16 kV ESS bus. may satisfy this SR using the test facility.

6. A single test will satisfy this Surveillance for both units if I~ 4 ~ot pong ~ I C.

synchronization is to the 4.16 kV ESS + W~

bus for Unit 1 for one periodic test Per

~C)+ o~ Ow.t and synchronization is to the 4.16 kV ot')t'ofer~<~4 ~

ESS bus for Unit 2 for the next periodic test. However. if a-4W~ IQ SL Qp t gi~sAJ 3.a,z.<,~

~<~

then the test shall be performed synchronized to the 4. 16 kV ESS bus for Unit 1.

Verify each DG is synchronized and loaded 31 days and operates for ~ 60 minutes at a load

~ 3600 kW and ~ 4000 kW.

(continued)

Ai <Il G ll 7 SUSQUEHANNA - UNIT 1 3. 8-6 4 4

\

~g~ kAX kki o7 AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS ARRI (continued)

Note 2 modifies this Surveillance by stating that momentary transients because of changing bus loads do not invalidate this test. Similarly. momentary power factor transients do not invalidate the test.

Note 3 indicates that this Surveillance should be conducted on only one OG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations.

Note 4 stipulates a prerequisite requi rement for performance of this SR. A successful DG start must precede this test to credit satisfactory performance.

Note 5 provides the allowance that OG E, when not aligned as substitute for DG A, B. C and 0 but being maintained Operable, may use the test facility to satisfy loading requirements in lieu of synchronization with an ESS bus.

Note 6 allows a single test (instead of two tests, one for each unit) to satisfy the requirements f'r both units. with the OG synchronized to the 4. 16 kV ESS bus of Unit 1 for cre eriodic test and synchronized to the 4. 16 kV ESS bus of e nit 2 during the next periodic test. This is acceptable because the purpose of the test is to demonstrate the ability of the OG to operate at its continuous rating (with the exception of'G E which is only required to be tested ~t the continuous rating of OGs A through 0) and this attribute is tested at the required Frequency. Each unit's circuit breakers and breaker control circuitry. which are only bei~

tested every second test (due to the staggering of the tests). historically have a very low failure rate. If a DG fails this Surveillance. the DG should be considered inoperable for both units. unless the cause of the failure In addition. if can be directly related to only one u the test is scheduled to "e performe on the other .Unit. aid the other Unit's TS alt: ance that provides an excepticn tv performing the test is .: 0 (i.e.. the Note to SR 3.8.2 I for the other Unit pre. .s an exception to performing this test when the other i.'"". s in MODE 4 or 5. or moving oC irradiated fuel asse c's in the secondary containment).

F40+ p~gLi +1~ then the test shall te -."~formed synchronized to this Unit s pcpFoc ~ 4.16 kV ESS bus. Tt e '. .'~g Frequency for this Surveiliance

~ <c>4 is consistent with Re;.'i:.ry Guide 1.9 (Ref. 3).

Cymes~~

a~ chili <c lip (continued)

~~dr ~ A.i (i 4'll 7 SUSQUEHANNA - UNIT 1 8 3.8.11

Each of the above required indspcadeat circuits between the otfslte transmission netwoth

'ad the oashe Chu lE distrtbunon system shall be:

i

~ Detsrmtned OPERABLE at least once per 7 days by vertfymg cotrets brewer alignments aad Indicated power availability. an4 Demonstrated OPERABLE at least once per 1 momhs SR 8 8 'i ' transferring, manually aad automatically. unit powes supply ftom the anttnai circua to the alternate ctrcutt.

a.g.l. L" Each of the above required diced generators shall be daamnstratad OPERABLE:

~ on TA by:

8R 3.8.1A Venfying the fud levd in the engiae-mounted day fud tanl 5 L 38.9.1 Verifying the fud levd ia the fud storage tank Verifying the f'ud transfer pump starts,aad transfers fud from the smrsge 8R 3.S.i.i. system to the eagine.moume4 day fuel Verifying the diesel starts from ambient condiYion tat~ 1 Q3.Z.l X The generator voltage and gg 3g.l.l fretptency shall e start si .

volts and csd g 3.0 Hz whhia 10 seconds shall be for this A.l o folio~'ignah:

b) oss ot offsite loss of o er by power njunctioa 'n ESF actuation Tn 6R3 g.t= d) signaL

~ ritying the

'at si diesel generator is s f

nized with the grid and fot

~R 3.8.<,> 0 loss 60 ttunutce at a hsad of to 4000 KN. I 4

LA.4.

Yarityirrgrrr4 rnrrrurr ia rll dirrrl rrrraaw rir rrrrr maivrrs r4 rre grrrrrr than or equal to 240 psig 3l L 3~

8R 3.8.1.5 At least once 31 days or

'quated to 1 hour e ere chechng for aad retnoving Q

water from the day fud tanks.

<44'f 3 f3 5

.~ >>~~>~ All planned for the putpose of these 'Ihacee may be p ede4 by prehtbe period ia accordance with vendor recommcadmma.

Q.r.i I&

Diesel generator ioadhtg may be preceded by a wartaup penod ia accotdance wih vendor 4'i. 3,g.t 5 Diced generator loading may be axemplished ia accordance <<hh 4 ob 1 vendor tecommeaiatioas.

This load is meam m guklaace to avoid tounne overloading of diced generatots-R$ 5.1.5 Momeatary tra¹aietna outside the loa4 range will ax utvalidate the tat.

a)A Z SUSQUEHANNA UNlT I 31e $ -3 Ame ~No. 1ay )

Cb loaded tn The enerator vo tage volts and state g N .0 r vol and within 10 shall be 'ithtn nds after th ese

~n. i The wing di generator lycttnut f starting ot operation when oot ~L~ 8 Engine verspeed.

b) G r dilferenti c) low lube o'essure.

6.

w) on a rotational basis substitute diesel generator E for diesel generator A, B.C. orD and

-1}- Simulate loss of ofhit! power by itself. and:

~

Verify deenergization of the emergency bus and load shedding from the emergency bus, h

Verify diesel generator E statts on the aut~tt signal, energizes the emergency bus wuh pertnanently connected loads wuhin 10 seconds and operatea lor th

~ ttual to 5 mieum while its generator is oaded with the shutdown loads. Alter energization y state voltage and frequency of the emergency bus shall be its and 60 ~

this ~

maintained at and Hz during Lf C Verify thar on aa ECCS muation ofhia lower,

~ signal, diesel generator E starts on the au~tats signal loss of and operates on standby for greater than or 1tage and ency shall 1 volts and 60 4 3. 8z 10 seco the start s

~geoenm voltage

'his iH}

maitnalned widun a 1 s

~

SL ~.

ants lututs Z t.tt. e.

and in conjunction with an ECCS M s Ct~t W Verify deeteergaxxa of the emergency shedding ftotn the emergency bus.

bus and load SUSQUHiANNA - UNE 1 3/4 tabb Ameztdmea No. 107

+Re. RA'L 3.8.1 -o8 3.8.1 PS(ER SYSTEIIS SURVEILUNCE RE UlREltEHTS Continued SIeulate an ECCS actuation test signal, without 1oss of offsite porer and verify that diesel generator E starts on the auto-start signal and operates on standby for greater than or equal to 5 sin The zR S.K,I. >2 erat nd frauen shall b 0 e iO H.LO vol an4 60 e . H s 4 r e a

and frequency shall e

be ea s e genera or voltage aaintained vithin these liafts

~HII.

during this test, and.

Fff) Sieulate a loss-of-offsite, pear in con)unction rith SR S.R.I. IR an ECCS actuation'est signal and verify diesel genera-tor E starts on the auto-start signal, energizes the sieulated emergency bus with simulated permanently connected loads ~lth 10 seconds, energizes the simu-lated auto-connected loads an4 operates for greater L l4 than or equal to 5 einutes while its generator is loaded Ath the sieuiated emergency loads. After energization, the steady state voltage and frequen

~a of the siaulated eoe ency bus are aaintained at g) volts and 60 z . Hz during this test and CB Verify that all automatic diesel generator trips, except engine overspeed, generator differential SR. 3.8.1,13 and engine lou lube oil pressure, are automati-cally bypassed upon'loss of voltage on the eeer gency bus concurrent with an,ECCS actuation sig nal, and vA i M~

SP9 S

F l..

6 E,E.l.l7 iv) On a rotational basis, substitute diesel generator for diesel generator generator and E

A, 8, C or 0 and verify diesel energizes the appropriate ewergenCy bus, E

~, Verify the diesel generator E's capability to:

0 ~ Synchronize rith the offsite pear source dphil ~ the generator is loaded with its emergency toads upon a simulated restoration of offsite peter, Transfer its loads to the offsite power source y and Se restored to standby status, and Verify that Hth 4iesel generator E oper in a test aode and connected to its bus, a sieulated actuation signal overrides the test code by ECCS (1) returning tne 4iesel generator ti standby operation and (2) autaaatically energizes the emergency loads N th of fsite power.

SUQNEHAWA - NI7 1 3/4 8-64 lseehent No. l03

QdL sees At least once per t" days free ne>> fuel oil prior i Ts z.s.9 an4 storage tanas by vet'5 fying Chat 4 Co ~ftfon to

>>5th AST15 D270 197$ has a water and aadfeent content of leaa chan or Q5'g equal te .05 vol~ percent and a kinematic vfacoafty I 40C of ster than or'qual to 1.3 but less than or equal,to or Q.3

~1.% but c4.1 for 20 oil when teated in accordance with ASTlt {575 77, a%i an futurity level of less than 2 eg. of insolubles per 100 el. when tasta4 fn accordance wf th AST15-D2gl4-70. X5'~

At least once per eonths by: 2A LB.i Wo Sub ect 4 eae Co pection fn aces ce with proc s prepared on)unctfon wf Ch 5 ufacturar'a 8R 98.I I ~ tfonsW chfa class of a f.~)Vert ty teethe dteael tooer r a

. greater than or equal te tlt

~ wh service te ro aea ~ load or h vo

~Au QL't volts and f ncy at 40 e Hx. El fly Italo+ 2 +~ 3.ee Verf fy5ng Che 4feael generator capability to re5ect a loa4 of los>>fChout tripping. The generator voltage shall not 4 volts during and fol1o>>fng Ch~lgLza)ectf

4. Sfmlatfng a loss of offsfte power by ftself, and:

~A,i {l,L ~ Verifying deenergfxatfon of the urgency busses ahe44fng fry the mergency busses.

oai A.l3 C. W Veri fyfng the 45esel generator starts on the auto-start signal, energizes the urgency busses with peraanently S'R 3.S'.{.ll connected loads>>ithin 10 seconds and operates for greater

~ GAS than or equal to S efnutes while its

>>5th the shutdown loads.

state voltage and r cor 5 1 r ene Cation che seas of the ~ busses shall H ll M8 . be aefntafned at s volta an4 S0 e Ha during th5a teat.

Verf fyfng that on an ECCS actuation at signa, t loss ZR 3.R,).n.

signal and operatea on

~ 5nutea. TlN ner a~

of offafCe power Che 45 ~ ael generator scarce on the auCO aCart for greater than or equal r eel cage and frequency shall H I 0 su a rt s state generator voltage and freqwncy aha be Oaf ntafned>>fchfn 11 ~ its 5 this test.

QAk 'SR 5 f I ~

R.io Diesel

>>fth nerator ndor Sng aey tio .

preceded Dfeael b~rae star loa4ing perl be accordafce~

~lfyei in a r4ance th vendo omendatf SUSIE}NNA eo {NIT I 3/4 I4 AeeaSent He. 103 NOV 15 iM

I 4-4 o I Ha.C aA Z 8URVIILLAff48 ftRONRfNINES g.g f Os (4ondnued)

Qg g g /'~q ~ Simufatrng . ~ Ioss~f~ffslte actuabon test agnsl, and:

powr' con~n wrth an ECCS i.g.r -'fC R i Q~ Q y ~ Veri~ deenergcation of the shedding from the emergency emergency busses.

Venfylng the diesel generator

~ nergcas the starts on the auto-stan emergency busses wnh signal, Ioads within l0 seconds. eneryixes thepermanently connect cl through the load timers and a~nnected loads operates. for greater than 5 minutes WILLI~ ita generator is or equal to After energization. the steady loaded with the emergency loads.

state voltage erne ncy busses shall be mintaned fre uency of (0 80 3. Hz during this teat. 4180 c 400 volta and

~ Verifying that al automaic diesel overspeedt generator dlfferendal generator trips. except engine and en ine low lube oil are automatically bypassed ofessUre upon 'sa of voltage on

~~

emergency bus concurrent with CCS actuadon signal. S~~ct Verifying that the diesel generator operataa for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. f9.<3 Sg, 5.K(.lg During the fi hours ot this teeL the diesel loaded to 440847 enarator shall be kW and during the re ' QOO teat. the diesel generator shall 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this be loaded 38 .Vv&

gener r vo ge arl ILW.

3.0 Hs widiin l0

~ qu y shall be 4 after the vo a 0- Lu gene signal: the ady state 3kd voltage a ~ quency sh II maintained ' these'imits g.. I this te

3. 'g.l. I g Wittun minutes o SR3'F I I< within S min after operating temperatures have W stabi of 800 - w. venfy the hot restart cap Irty 0 ced at e the lese

~ ~ ~ ~ tao ~

nnected lo to each ~I ge r clo ur rating 700 kW so sroooooe ~

may oo

~~

oMloolo e>> iooe w euieaoco lo ovee we no> oooolo roumo ee lool.

~~ or +em+ ~wwo.

Gf. 5'gl.tg SU$ 4UEHANNA ~ UNIT t 314 S S An~morlt Ne. 1>7, I 50

~~ Ms s.s.i- ctb OISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING T HN A HAN - H R R TR T V (continued)

SSEs ITS SR 3.8.1.12 (LOCA start test in 4.8.1.1.2.d.5, 4.8.1.1.3.d.6.a.ii. and 4.8.1.1.3.d.6.b.ff):

SSES ITS SR 3.8.1. 15 (hot restart test in CTS 4.8.1.1.2.d.8):

SSES ITS SR 3.8.1.19 (LOOP/LOCA test in 4.8.1.1.2.d.6, 4.8.1.1.3.d.6.a.iii. and 4.8.1.1.3.d.6.b.fii): and SSES ITS SR 3.8.1.20 (simultaneous start test in 4.8.1.1.2.e).

This more restrictive change is acceptable because introduce any operation which is unanalyzed while requiring more it does not conservative test acceptance criteria than currently required.

Therefore. this change has no negative impact on safety.

SSES CTS SRs require the DGs to achieve and mafntain a frequency of 60 a 3 Hz (a 5C) during DG start and load testing. The equfvalent SSES ITS SRs require that the DGs achieve a frequency between 58.8 Hz and 61.2 Hz. These values are equal to + 2L of the 60 Hz nominal frequency and are derived from the recomendations found in Regulatory Guide 1.9. Rev 3. Section 1.4.

n conjunctio with the more restrictive minimum and maximum steady state requency, SSES ITS S that include a DG start time requirement re modffied to incl e clarificatio that only the minimum vo age and frequency r uirements (vo age ~ 3793 V and frequency 58.8) must be met thin the all starting time ut ',

that min and maximum volt e and frequen y limits must be achieve after steady state nditions are cached. This accept ce criteria ensures hat DG testi verifies that t e new and e restrictive minim voltage and requency limits re reac within required me limits an that required st dy sta lim s are established d maintained Starting transi nts tha x the new and mor restrictive ximum voltage a frequ cy imits will not be co sidered fail e to meet accept ce cri eria.

e acceptance crite ia that the establish and intain teady tate conditions following the arting transient ensure that tarting transients do not tri the DG.

These additfonal restrictions apply to the following SSES ITS SRs SSES ITS SR 3.8.1.2 (steady state limits only) and SR 3.8.1.7 (DG Start test in USES CTS 4.8.1.1.2.a.4 and 4.8.1.1.3.a.4)

SSES ITS SR 3.8.1.9 <single load rejection test in SSES CTS 4.8.1.1.2.d.2 and 4.8.1.l.3.d.2):

SUSQUEHANNA UNIT 1 AND 2 10 Revision 0. 07/31/96

~c.c. aaX s.q.r DISCUSSION OF CHANGES ~M RAg ITS: SECTION 3.8.1 - AC SOURCES OPERATING T HN CA HANG - S R TR T V (continued)

~is C~-yc current practice at SSES which is to manually top off the day VCCC lie.iy dlC 4 tanks every time the DGs are o P crated to satisf a desi g n

~

commitment in FSAR 9.5.4.2 that requires the day tank contain dc) ig Ls<<o hhv~S. ufficient fuel for one hour of operation at continuous rated load dr ~~ oc,~wf-4 hich is based on tion 6 1 To

~z ta lcm 4'a ~ <

>C L~r'a.pa 4,e Q .8.1.4 will indicate that the acceptance criteria for this SR of +>>c.L ~ it ir-'ygd rovides approximately 45 minutes of operation at the post ccident load. Prior to implementation of Improved Technical OCQ. RCavLC '44. pecifications at SSES. FSAR 9.5.4.2 will be revised to take p np aw ~~+ %e<< xception to ANSI N195-1976, Section 6.1. This change is ts .See acceptable based on the following: day tank level is verified r hyv 'very 31 days which ensures that each OG will have sufficient fuel dP foal %1~ >>OAJ ~ be a r~sk wwii ail to start and operate for at least 45 minutes: day tank levels I are maintained automatically during OG operation by the fuel oi 1 04 Oa~ 7'awq transfer system which is tested every 31 days by SR 3.8.1.6; and. ~o~Q ~u->tl. low level alarms on OG day tanks are set slightly below this level and will provide adequate time for operators to investigate and correct or compensate for a diesel fuel oil transfer pump failure. 'dditionally. calculations supporting 45 minutes of OG operation are based on fuel oil consumption calculations that are very conservative. Specifically, the DG post accident load for all DGs is assumed to be equal to the OG with the highest post accident load: OG fuel consumption rates are assumed to be equal to the highest consumption rate observed for any of the OGs: and, assumptions about fuel oi 1 specific gravity included using the highest heat value fuel during observations of fuel consumption rates (lowest fuel consumption) and lowest heat value fuel during accident conditions (highest consumption). Therefore. minimum day tank volumes based on 45 minutes of OG operation at the post accident load does not have a significant impact on safety. T HN CA P F AT N L. lr ~<<~a t The Bases of the SSES CTS for this Specification have been replace y Bases that reflect the format and applicable content of SSES ITS 3.8.1 consistent with .the BMR STS. NUREG-1433.. Rev. 1. SUSQUEHANNA UNIT 1 AND 2 23 Revision 0, 07/31/96 a ~x a.e.t-op Z~si+. Several SSES Cl8 SurveBlance Requiremems hare been modified to only require the minimum voltage and frequency requirements (voltage 3793 V and frequcrtey 588) to bc met within the alhwed starting time, but that mininmm and maximum voltage and frequency limits must be achieved after steady state conditions are reachctL This change is acceptable because it ensures that DG testing verifithat the new and more restrictiv minimum voltage and frequency limits are reached within required time limits and that required steady state limits are established and maitrtained. The acceptance criteria that the DG estabHsh and maintain steady sate conditions following thc Carting transient ensures that starting transients do not trip the DG. Thc above describ change applies to thc following SSES IIS SRs: SSES IIS SR 3JL12 and SR 3%1.7 (DG Start test in SSES CIS 4.8.1.1~4 and 48.1.13~4) SSEa IIS SR 38.1.12 AVOCA Cart test in 4$ .1.12LS,4$ .1.133.6~ and 48.1,13%63ui); SSES IIS SR 3JL1.15 (hot restart test in CIS 48.1.1~); SSES IIS SR 38.1M (simultaneous start test in 4$ .1.1~). ')he Hi~c. rc ~<<r c.J io res c~ sM sM c, co ~dab~ ttcoL 'i% lo stao~g resfostc. *~ et'I Wrac,, IS ~cpa(< 4$ 504LK4JJ 4+qgsg I) ikey. g 5rt s rc sr'c N folk>c, A Freq~e Fo~ ~ OQ O see ceo ~ ~e1"'~ ~ ni'. +, ~d. <~ 5',dg sl k g ii sllov ~ '4<c. t HA4 LAL 1,g ( AC Sources -Operatina 3.8.i 48c SURVEILLANCE REQUIREHENTS (continued) SURVEILLANCE FREQUENCY SR 3.8. 1.4 Verify each engine mounted day tank fuel 31 days oil level is a 345 gallons for each OG. SR 3.8.1.5 Check for and remove accumulated water from 31 days each engine mounted day tank. SR 3.8.1.6 Verify the fuel oil transfer system 3l days operates to automatically transfer fuel oil from the storage tanks to each engine mounted tank. SR 3.8.19 NOTES-

1. All OG starts may be preceded by an

'7 engine prelube period.

2. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each OG starts from standby ~days condition and achieves, in s 10 seconds, i 58.8. voltage ~ 3793 V and frequency and after steady state conditions are reached. maintains voltage i i 61.2 3793 V and s Hz. 4400 V and T~+ > 8-7 ] frequency ~ 58.8 Hz and 3.8.1jf VerS fy automatsc and manual transfer of 24 months gR unit power supply from the normal offsite csrcuit to the alternate orrstte ctrcust. (continued) .2 i~IL~lqf I - UNIT 1 3.8-7 SUSQUEHANNA INSERT 3.8-7-1 (NRC RAI 3.8.1-10) -- NOTE This Surveillance shall not be Performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR. ~n.c t,hx x.8.q-<o AC Sources -Operating i e.~ -u 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1.g -NOTES-

l. All DG starts may be preceded by an engine prelube period.

2. DG E, when not aligned to a 4.16 kV ESS bus. may satisfy this SR for both units by performance of SR 3.8.1.11.c using the test facility to simulate a

4. 16 kV ESS bus. SR 3.8.1.1l.a and b may be satisfied with either the normally aligned DG or DG E aligned to 7t4stt 0 ~'

the 4.16 kV ESS bus. Verify on an actual or simulated loss of 24 months offsite power signal:

a. De-energization of 4. 16 kV ESS buses;

b. Load shedding from 4.16 kV ESS buses:

and

c. DG auto-starts from standby condition and:

l. energizes permanently connected loads in s 10 seconds.

2. energizes auto-connected shutdown loads through individual load timers.

3. maintains steady state voltage

~ 3793 V and s 4400 V.

4. maintains steady state frequency m 58.8 Hz and s 61.2 Hz, and supplies permanently connected 5.

i loads for 5 minutes. (continued) SUSQUEHANNA - UNIT 1 3.8-9 Amendment A. 07/31/96 INSERT 3.8-9-1 (NRC RAI 3.8.1-10) NOTE This Surveillance shall not be Performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR. ~ LAL > 8.l R3 >a.i-( o AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.1. -NOTES--

1. All DG starts may be preceded by an engine prelube period.

2. DG E. when not aligned to a 4.16 kV ESS bus. may satisfy this SR for both by performance of SR 3.8.1.19.c 'nits by using the test facility to simulate the 4.16 kV ESS bus. SR 3.8.1.19.a and b may be satisfied with either the normally aligned DG or DG E aligned to the 4.16 kV ESS bus. y~ i.e-tc,q Verify on an actual or simulated loss of 24 months offsite power signal in conjunction with an actual or simulated ECCS initiation signal:

a. De-energization of 4. 16 kV ESS buses:

b. Load shedding from emergency buses:

and

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads in s 10 seconds.

2. energizes auto-connected emergency loads through individual load timers.

3. achieves steady state voltage a 3793 V and s 4400 V.

4. achieves steady state frequency

> 58.8 Hz and

• 61.2 Hz. and

5. supplies permarently connected and auto-connected emergency loads for ~ 5 m:nu.es.

(continued) - UNIT 3.8-16 Amendment A. 07/31I96 SUSQUEHANNA 1 INSERT 3.8-16-1 (NRC RAI 3.8.1-10) NOTE This Surveillance shall not be Performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR. rulc. RA'T S.a.~- zy ~'8 ~l (4 AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS ~SR . ~ (continued) associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE. the fuel oil piping system is intact. the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE. The Frequency for this SR is 31 days because the design of the fuel transfer system requires that the transfer pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks. This Frequency allows this aspect of DG Operability to be demonstrated during or following routine DG operation. 2 r, R 81 e SR 3 .1. ~%7 Transfer of each 4.16 kV ESS bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. The 24 month Frequency of the Surveillance is based on engineering judgment taking into consideration the plant conditions required to perform the Surveillance. and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually sass the SR when performed on the 24 month Frequency. Yherefore. the Frequency was concluded to be acceptable fran a reliability standpoint. Credit may be taken for unplanned events that 'satisfy this SR. z >~ zs. n-I S . 6 Each DG is orovided witn an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the 7oss of a large load could cause diesel engine overspeed, which, if ercess>ve. might result in a trip of (continued) SUSQUEHANNA - UNIT. 1 8'. 8- '.9 Amendment A. 07/31/96 INSERT B3.8-19-1 (NRC RAI 3.8.1-10) This SR is modified by a Note. The reason for the Note is that, during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, plant safety systems. This Surveillance tests the applicable logic associated with Unit 1. The comparable test specified in Unit 2 Technical Specifications tests the applicable logic associated with Unit 2. Consequently, a test must be performed within the specified Frequency for each unit. As the Surveillance represents separate tests, the Note specifying the restriction for not performing the test while the unit is in MODE 1 or 2 does not have applicability to Unit 2. The Note only applies to Unit 1, thus the Unit 1 Surveillance shall not be performed with Unit 1 in MODE 1 or 2. Credit may be taken for unplanned events that satisfy this SR. t ~ C.c, c h x8. L - Z3 AC Sources -Operating ' B 3.8.1 BASES SURVEILLANCE SR ..1 (continued) REQUIREMENTS The reason for Note 2 is to allow DG E. when not aligned as substitute for DG A. B. C or 0 and not required to be Operable. may use the test facility to satisfy loading requirements in lieu of synchronization with an ESS bus. When tested in this configuration, OG E satisfies the requirements of this test by completion of SR 3.8. 1.11.c only. SR 3.8.1.10.a and 3.8.1.10.b may be performed by any OG connected to the associated 4. 16 kV ESS bus or by any series of sequential. overlapping. or total steps so that the entire connection and loading sequence is verified. Zvwp 6 '58.-Ã1-( SR .8. ]/ This Surveillance demonstrates that the DG automatically starts and achieves the required voltage and frequency within the specified time (10 seconds) from the design basis actuation signal (LOCA signal) and operates for a 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on a LKA signal without loss of offsite power. The requirement to verify the connection and power supply of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the loading logic for loading onto offsite power. In certain circumstances. many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance. ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow. or RHR systems performing a Cecay heat removal function are noh desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of the connection and loading of these loads, testing that adequately shows the capabi lity of the OG system to perforn these functions is acceptable. This testing may incus"e any series of sequential. overlapping, or total s:es so that the entire connection and loading sequence is ~erified. The Frequency of 24 .-cr..ns takes into consideration plant conditions required to ."er'.orm the Surveillance and is (continued) SUSQUEHANNA - UNIT 1 B 3 8-23 Amendment A.. 07/31/96 INSERT B3.8-23-1 (NRC RAI 3.8.1-10) The reason for Note 3 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This Surveillance tests the applicable logic associated with Unit 1. The comparable test specified in the Unit 2 Technical Specifications tests the applicable logic associated with Unit 2. Consequently, a test must be performed within the specified Frequency for each unit. As the Surveillance represents separate tests, the Note specifying the restriction for not performing the test while the unit is in MODE 1, 2, or 3 does not have applicability to Unit2. The Note only applies to Unit1, thus the Unit1 Surveillances shall not be performed with Unit 1 in MODE 1, 2, or 3. Credit may be taken for unplanned events that satisfy this SR. NILC. g.h g 2.8. I Q AC Sources -Operating 8 3.8.1 BASES SURVEILLANCE SR (continued) REQUIREMENTS ESF systems so that the fuels RCS. and containment design limits are not exceeded. This Surveillance demonstrates OG operation. as discussed in the Bases for SR 3.8.1.11. during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential. overlapping'r total steps so that the entire connection and loading sequence is verified. The Frequency of 24 months takes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length. +4rce This SR is modified by ~Notes. The reason for Note 1 is to minimize wear and tear. on the OGs during testing. For the purpose of this testing. the DGs must be started from standby conditions. that is, with the engine coolant and oil being continuously circulated and temperature maintained consistent with manufacturer recommendations. Note 2 provides the allowance that DG E, when not aligned as substitute for DG A, B. C or D, may use the test facility to satisfy SR 3.8.1.19 for both units. When tested in this configuration, DG E satisfies the requirements of this test by completion of SR 3.8.1. 19.c only. SR 3.8.1.19.a and 3.8.1.18.b must be performed by the DG connected to the associated 4. 16 kV ESS bus or by any series of sequential. overlapping. or total steps so that the entire connection and loadirig sequence is verifi + 4'3. 5- sl-/ R lf This Surveillance demonstrates that the DG starting independence has no: "een compromised. Also. this Surveillance demonstra:es that each engine can achieve proper speed within the soecified time when the DGs are started simultaneously. The 10 year Frequency is consistent with the recommendaticns of Regulatory Guide 1.9 (Ref. 3). (continued) SUSQUEHANNA - UNIT 1= 8 3.8-31 Amendment A, 07/31/96 INSERT 83.8-31-1 (NRC RAI 3.8.1-10) The reason for Note 3 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This Surveillance tests the applicable logic associated with Unit 1. The comparable test specified in the Unit 2 Technical Specifications tests the applicable logic associated with Unit 2. Consequently, a test must be performed within the specified Frequency for each unit. As the Surveillance represents separate tests, the Note specifying the restriction for not performing the test while the unit is in MODE 1, 2, or 3 does not have applicability to Unit 2. The Note only applies to Unit 1, thus the Unit 1 Surveillances shall not be performed with Unit 1 in MODE 1, 2, or 3. Credit may be taken for unplanned events that satisfy this SR. H A.C RAX. OC Sources -Operating 3.8.4 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3.8.4.6 Verify each required battery charger 24 months supplies its associated batteries at the voltage and current adequate to demonstrate battery charger capability requirements are met. SR 3.8.4.7 -NOTE- ~. The modified performance discharge test in SR 3.8.4.8 may be performed in lieu of the service test in SR 3.8.4.7 once per 60 months. I'~sr~ f-Verify battery capacity is adequate to 24 months supply, and maintain in OPERABLE status. the required emergency loads for the design duty cycle when subjected to a battery service test. (continued) A SUSQUEHANNA - UNIT 1 3.8-27 I INSERT, 3.8-27-1 {NRC RAI 3.8.1-10) NOTE ~ This Surveillance shall not be Performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR. Pled, kAg 3 8 ( gc, DC Sources -pperating 3.8.4 SURVEILLANCE REOUIREHENTS (continued) SURVEILLANCE FREQUENCY ZNhte4. 4.Q p SR 3.8.4.8 Verify battery capacity is ~ 80K of the 60 mon manufacturer's rating when subjected to a performance discharge test or a modified performance discharge test. 12 months when battery shows degradation or has reached 85K of expected service life with capacity < 1004 of manufacturer's rating 24 months when battery has reached 85K of the expected service life with capacity ~ 100K of manufacturer's rating oe li~ <<7 3.8-28 a a A-.IWalv SUSQUEHANNA - UNIT 1 INSERT, 3.8-28-1 (NRC RAI 3.8.1-10) NOTE This Surveillance shall not be Performed in MODE 1, 2 or 3. However, credit may be taken for unplanned events that satisfy this SR. O>I ill>p h W Qt'. RA't OC Sources Operating B 3.8.4 BASES SURVEILLANCE 4.7 (continued) REQUIREMENTS operations or at some other outage. with intervals between tests not to exceed 24 months. This SR is modified by a Note which allows the performance of a modified performance discharge test in lieu of a service test once per 60 months. The modified performance discharge test is a simulated duty cycle consisting of just two rates: the one minute rate published for the battery or the largest current load of the duty cycle. followed by the test rate employed for the performance test. both of which envelope the duty cycle of the service test. Since the ampere-hours removed by a rated one minute discharge represents a very small portion of the battery capacity, the test rate can be changed to that for the performance test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test. A modified discharge test is a test of the battery capacity and its ability to provide a high rate. short duration load (usually the highest rate of the duty cycle). This will often confirm the battery's ability to meet the critical period of the load duty cycle, in addition to determining its percentage of rated capacity. Initial conditions for the modified performance discharge test should be identical to those specified for a service test. Z~ie~+ 8 'X 8- <8- l A battery performance discharge test is a test of constant current capacity of a battery, normally done in the as found condition, after having been in service, to detect any change in the capacity determined by the acceptance test. The test is intended to Cetermine overall battery degradation due to age ard usage. A battery modified perfor. ance discharge test is described in the Bases for SR 3.9 4 7 Either the battery performance (continued) OR Iieet' SUSQUEHANNA - UNIT 1 B 3.B-SB I INSERT B3.8-58-1 (NRC RAI 3.8.1-10) The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the Electrical Distribution System, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance. Akc. R AZ g.e.i-g~ OC Sources -Operatings > "-z.> B 3.8.4 BASES SURVEILLANCE REQUIREMENTS ~R~4) (continued) discharge test or the modified performance discharge test is acceptable for satisfying SR 3.8.4.8; however, only the modified performance discharge test may be used to satisfy SR 3.8.4.8 while satisfying the requirements of SR 3.8.4.7 at the same time. The acceptance criteria for this Surveillance is consistent with IEEE-450 (Ref. 8) and IEEE-485 (Ref. 11). These references recomtend that the battery be replaced if its capacity is below BOZ of the manufacturer's rating. A capacity of 80Z shows that the battery rate of deterioration is increasing. even if there is ample capacity to meet the load requirements. The Frequency for this test is normally 60 months. If the battery shows degradation. or life if the battery has reached 85Z of its expected service and capacity is < 100Z of the manufacturer's rating, the Surveillance Frequency is reduced to 12 months. However. if the battery shows no degradation life. but has reached 85Z of its expected service the Surveillance Frequency is only reduced to 24 months for batteries that retain capacity m 100Z of the manufacturer's rating. Oegradation is indicated. according to IEEE-450 (Ref. 8). when the battery capacity drops by more than 10Z relative to its capacity on the previous performance test or when it is 10Z below the manufacturer's rating. All these Freauencies are consistent with the recommendations in IEEE-450 (Ref. 8). + 018 s~-, REFERENCES l. 10 CFR 50. Appendix A. GOC 17.

2. Regulatory Guide 1.6.

3. IEEE Standard 308.

4. FSAR, Chapter 6.

5. FSAR. Chapter 15.

6. Final Policy Stat~nt on Technical Specifications Improvements. July 22. 1993 (58 FR 39132).

SUSQUEHANNA - UNIT 1 B 3 8-59 I 4 t~ (continued)

4. I O'I lti I7)

INSERT B3.8-59-1 (NRC RAI 3.8.1-10) The SR is modiTied by a Note, The reason for the Note is that performing the Surveillance would remove a required DC electrical power subsystem from service, perturb the Electrical Distribution System, and challenge safety systems. Credit may be taken for unplanned events that satisfy the Surveillance. Each of the above required independent circuits between the ofhita ttansatlssion net<<art and dl onshe Qaaa l E distrtbutla system shall bc: Determined OpERABLE st least once per '2 days by vcrif+tg correct bradter P.oe ~ alignments aad utdicated power availability, and Demonstrated OPERABLE st least once pcr 1 months shutdo b SR 3 6 1 ~ transicrriag. maaually aad automatically. unit po~er supply from the normal circuit to the alternate clfcutf. 4.$ .l.l. Each ot the above required diesel generators shall be dcamnsaatad OpERABLE: ~ 04 by: ~ SR 3.8.1A Verifying the hd Icvd in the engine mourned day fud tank kl S P. 8 B.'3. > Verifying the fud lcvd ia the fud smrage tsar. Vcrif'ying the hd transfer pump starts and transfers tud from the smtage SR S.S.1.C, system to the cngiae.mourned day hd tank~ I Verifying the dicsd stans ham ambicm condition Jgs.f.l 4 The generator voltage snd frequency shall volts and 3.0 Hz within 10 seconds Sk 3$ .1:~ tt.>> cr e stan si . ctd g shall be for this o e foll 'ignals: b} 5 signal. osa of otfsite of cr by power 'oss njuactioa 'n ESF scmstion M > 6R3 g.t d} t<<t si itsdf critying the diesel generator is s need with the grid and for ZR 3.8.1.> << least 60 tniautm <<a load of to 4000 KW. I P: g LAc Verifying the pressure m all diced than or equal to 240 psig g~~ dr stan race~ S~ At least once 31 days ere 0 ~Le a or to l checting for aad tcmoviag ZR 38.L< accunntlated w<<cr from the eag~mted cay bet ants. akk Se. 3 c ~ f , All planned starts for the purpose of thee survcQlaacea may be preceded by a ptdube period in accordance with vendor recommcelations. gg.t.A. ~ Diesel gener<<or loading may bc preceded by a warmup pened ia accordance widt > tecommendadons. Diced gener<<or loading may be accomplahed in accordance <<1th .f~ 4$ SUSQUEHANNA UN 1 ))4 0 ARc. aAt i-L.L-<'L DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING TECHNICA HANG - M R R TRI T V (continued) SSES ITS SR 3.8.1.10 (full load rejection test in SSES CTS 4.8.1.1.2.d.3 and 4.8.1.1.3.d.3); SSES ITS SR 3.8.1.11 {LOOP start test in 4.8.1.1.2.d.4, 4.8.1.1.3.d.6.a.i, and 4.8.1.1.3.d.6.b.i); SSEs ITS SR 3.8.1.12 (LOCA start test in 4.8.1.1.2.d.5. 4.8.1.1.3.d.6.a.ii. and 4.8.1.1.3.d.6.b.ii): SSES ITS SR 3.8.1.15 (hot restart test in CTS 4.8.1.1.2.d.8): SSES ITS SR 3.8.1.19 {LOOP/LOCA test in 4.8. 1. 1.2.d.6, 4.8.1.1.3.d.6.a.iii. and 4.8.1.1.3.d.6.b.iii); and SSES ITS SR 3 4.8.1.1.2.e). '. 1.20 (simultaneous start test in This more restrictive change is acceptable because introduce any operation which is unanalyzed while requiring more it does not conservative test acceptance criteria than currently required. Therefore. this change has no negative impact on safety. T HN CA CHANGE - R TR CT V LA.l ES CTS 4.8.1.1.2 and 4.8.1.1.3 require that the DG testing wi a nominal fr ency of 31 days be more frequent (accelerated) whenever th number of test failures exceeds'imit listed in SSES C TS Table .8.1.1.2-1. S S ITS 3.8. 1 will maint n the required requenc at 31 days whi h is the nominal Freque cy for each of he tes governed by ilure history criteria n SSES CTS Table .8.1. .2-1 if there e 1 or fewer failures tart attempts. Re irements for accelerat testing based on the last 20 valid ail re history ar moved to the Technical equirements Manual ). This chan is acceptable because the requirement for p rability and sting every 31 days i maintained in the hnical Specif cations. The TRH wil maintain the existi g equirements f tracking. reporting nd implementing acc crated is change is made esting based n failure history. acilitate f ure implementation o recomnendations in eneric etter 94-0 . "Removal of Acceler ed .Testing and S ial eporting equirements for Dies Generators." whic allows icensee to reauest removal f TS of provisions for accelerated esting Justification for e imination of the r uirements for ccele ted testing will be eveloped separatel from the ITS onve sion Amendment Reque .'ntil the requi ements of 'Generic ett r 94-01 are implemen ed. requirements f accelerated testing an e adequately defin and con.rolled in he TRM. The level of afet of facility operation is unaffected y the change because SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 e DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING X.L i-Gg T CHN CA HAN - RE TR CT V (continued) 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before testing the other OGs. is based on guidance provided in Generic Letter 84-15. GL 84-15 recomended that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable time to confirm the Operability of DGs based on the desirability of minimizing DG starts. This change is consistent with NUREG-1433. L.5 SSES CTS 4.8.1.1.2.a specifies that OG testing be performed on a Staggered Test Basis. This restriction is not included in SSES F r W<.rc, K TS 3.8.1. This change is acceptable because the intent of a d.C...4.m. Of Sl >) equirement for staggered testing is to increase reliability of praW r)eaab )em$ ~ he component/system being tested; however. there is no evidence CM)tel ~ DISCS . taggered testing improves reliability or reduces the failure 1 a) C<~ av C4 mama ate. Staggered testing provides no additional assurance of s4)t-~f ~ reliabilit because the OGs are inde P endent and the p otential of 4 c~n cause failure ls evaluated promptly whenever any DG becomes erable Therefore. this change has no impact on safety and is consis en with NUREG-1433. L.6 he Surv llance Frequenci s for SSES CTS 4 8.1.1.2. .1 and 4.8. 1.1. .a. 1 (verifying evel in the DG y tank) d SSES CTS 4.8.1.1 2.a.3 and 4.8.1 .3.a.3 (fuel tr nsfer p ~ Operability) are cu rently governed y SSES CTS Tab 4.8.1. -1: therefore, the t t frequencies e subject to celerate testing based on " ail e rate of DG s rt tests. S ITS 'SR .8.1.4 and ~i>> ~t "Wv R .8.1.6 separat the required equency r these testsSSES from ITS lerated testi based on DG tart fail res because DG start 'vh m " "'vmb c lures are not ndicators of n inabil' to maintain level in da tank wh' these SRs erif . refore. accelerated testing o t e e par icu ar ea ures es not contribute to the objective of ccumulating xperience emonstrating OG starting has improved. and this c ange has no impact on safety L.7 SSES CTS 4.8.1.1 2.d.2 ~ and 4.8. 1. 1.3.d.2 establish accep ance criteria for OG voltage and frequency following a rejection of a load equivalent to the DGs largest single load. SSES ITS SR 3.8.1.9. relaxes the acceptance criteria as follows: a) The existing maximum acceptable frequency of 63 hertz is increased 64:5 hertz based on Regulatory Guide 1.9, Revision

3. which states that the load rejection test is acceptable if the increase in diesel speed does not exceed 75K of the difference between synchronous speed and the overspeed trip setpoint. or 15K above synchronous speed. whichever is lower. The SSES ITS value of 64.5 Hz is equivalent to 75K of the difference between nominal speed and the overspeed trip setpoint.

b) The existing requi rerrent that voltage be maintained within specified limits is relaxed in that the acceptance criteria for voltage is not required to be met until 4.5 seconds SUSQUEHANNA UNIT 1 ANO 2 19 Revision 0. 07/31/96 INSERT (NRC RAI 3.8.1-12) SSES CTS 4.8.1.1.2 and 4.8.1.1.3 require that the DG testing with a nominal frequency of 31 days be more frequent (accelerated) whenever the number of test failures exceeds limits listed in SSES CTS Table 4.8.1.1.2-1. SSES ITS 3.8.1 will maintain the required frequency at 31 days which Is the nominal Frequency for each of the tests governed by failure history criteria in SSES CTS Table 4.8.1.1.2-1 if there are 1 or fewer failures in the last 20 valid start attempts. Requirements for accelerated testing based on failure history are eliminated based on development and imp!erne SSES This change is ptable because the requirement for DG Operability and testing every 31 days is maintained in the Technical Specifications. This change is made to implement the recommendations in Generic Letter 9441, "Removal of Accelerated Testing and Special Reporting Requirements for Diesel Generators," which allows Licensees to request removal from TS of provisions for accelerated testing. The level of safety of facility operation is unaffected by the change because the maintenance rule requires evaluation and implementation of additional testing when repetitive equipment failures occur. Therefore, this change will have no impact on safety. Mc. SSES ae 4 < ce. r Ie P<ogra +t<t tafcel 4 co.np Ig <<+M ~ I ea uircr ~8 op I<cFR. So.(g a J rgFlcC+ CQ P~avac4J i Rc G v ~ 'I ICO a~g ~ombRr ) S o I Itc arly~ DISCUSSION OF DEVIATIONS FROM NUREG 1433 ITS: SECTION 3.8.1 - AC SOURCES - OPERATING P HAN (continued) which may reduce DG reliability. This change has been made to ensure that Improved Technical Specifications account for the SSES design where a single DG supports the operation of both Unit 1 and Unit 2. 'Therefore. this change does not represent a significant or generic deviation from NUREG 1433. (See ITS LCO 3.8.1. DX A.9) ~ P.9 Acceptance criteria in NUREG-1433. Revision 1, SR 3.8.1.2 and SR 3.8.1.7 (DG Start tests) SR 3.8.1.11 (LOOP start test): SR 3.8.1.12 (LOCA start test) SR 3.8.1.15 (hot restart test) SR 3.8.1.19 (LOOP/LOCA test) are modified to include clarification that only the minimum voltage and frequency requirements (voltage > 3793 V and frequency r 58.8) must be met w1thin the allowed starting t1me but that minimum and maximum voltage and frequency limits must be achieved after steady state conditions are reached. This change was made in conjunction with more restrictive changes to CTS acceptance criteria for DG voltage and frequency during the starting sequence. This acceptance criteria ensures that DG testfng verifies that the new and more restrictive minimum voltage and frequency 11mfts are reached within required time limits and that required steady state limits are establ1shed and maintained. Starting transients that exceed the new and more restrictive maximum voltage and frequency limits will not be considered failure to meet acceptance criteria. The acceptance criteria that the DG establish and maintain steady state conditions following the st'art1ng transi'ent ensures that starting transients do not trip the DG. This change is needed to accowiodate the adoption of SSCS more restrictive acceptance criteria than that in the SSES current ~$ + Ct&iCNC4+ Technical Specffications. (See ITS LCO 3.8.1. DX H.10 and H.ll) Therefore. thfs change does not represent a significant or generic Ch'W4h dCMCi+<g 3evfatfon from NUREG 1433. This change is consistent with NUREG Igloo 1433, Rev. 1. Generic Change BWROG-18 which is currently being +9 ~<ftMc Q of evaluated by the BWROG. >o c N 4'o.c c a~cL Surveillance Frequenc1es in NUREG-1433. Revision l. SR 3.8.1.2 (OG fhflcCQ Pto~~ ~ P.10 start test) and SR 3.8.1.3 (DG one hour load run) are modified to elfm1nate requ1rements for more frequent (accelerated) testing ~~~c I.Icy, ~ ~<HA~ whenever the number of test failures exceeds limits listed Table 3.8.1-1. SSES ITS 3.8. 1.2 and SR 3.8.1.3 will ma1ntain the 93 oi RcviLio~ required frequency at 31 days which is the nominal Frequency for each of the tests governed by failure history criteria in NUREG-1433. Revisfon 1. LCO 3.8. 1. Table 4.8.)-1 if there are 1 or fn the last 20 valid start attempts. Requirements for f~c'ailures lNCLca.f C J based on failure history are ~A .,c, ~e W~g 4P p4at controlle vgsb pc~ tc9~~$ e't ~ fac u wwhm~ L H R Li SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING ~T" ( dl recoirrrrendations. This is an administrative change with no on safety because diesel generator loading not specifically impact described in SRs will still be performed in accordance with plant procedures. A.11 SSES CTS 4.8.1.1.3. SRs for DG E when not aligned to the Class 1E System. does not specifically require the performance of a hot restart. SSES ITS SR 3.8. 1.14 does not make a distinction between DG A, B. C. 0 and E and requires satisfactory completion of the hot restart test before any of the OGs can be aligned and credited as Operable to meet the requirement of SSES ITS 3.8.1. This is an administrative change with no impact on safety because performing .the hot restart test on DG E when not aligned to the Class lE System is consistent with the intent of the CTS and ITS to perform any SR necessary to demonstrate the Operability of DG E should be substituted for another DG. it A.12 (Unit 1 Only) SSES CTS 3.8.1. Action a.3, is modified by a footnote that provides an extension to the allowable out of service time for offsite circuits during scheduled modifications to the T-10 230 kV switchyard. This footnote is no longer applicable and is deleted. A.13 SSES CTS diesel generator SRs specify that a simulated signal is used to initiate the following tests: loss of offsite power (LOOP) (4.8.1.1.2.d.4 and 4.8.1. 1.3.d.6.a i ); loss of coolant accident ~ (LOCA) (4.8.1.1.2.d.5 and 4.8.1.1.3.d.6.a.ii); LOOP/LOCA (4.8.1.1.2.d.6 and 4.8.1.1.3.d.6.a.iii); and, test mode override (4.8.1.1.2.d.6.c. 4.8.1.1.3.d.6.c, and 4.8.1.1.3.d.6.b.iv.b). The equivalent tests. SSES ITS SR 3.8.1.11. SR 3.8.1.12. SR 3.8.1.13. SR 3.8.1.17 and SR 3.8.1.19. allow the use of an actual or test signal to initiate the test. This change has the potential of reducing the number of required DG starts by allowing ~ credit to be taken successful demonstrations resulting from unplanned events or some other tests. This is an administrative change with no impact on safety because operability is adequately demonstrated by either an actual or simulated initiation'signal since the DG cannot discriminate between "actual" or "simulated" start signals. A.14 SSES CTS 4.8.1.1.2.e requires verifying diesel generator interdependence by starting all diesel generators simultaneously q hod.F ci4ei "after any modifications which could affect interdependence." eavtcl a+em+ This requirement is not included in the BMR STS. NUREG-1433. and i~ok pasJc 's not retained in the SSES ITS. An ti (w L~A~~A aa-) ys em componen as ee e y re ir. main nanc . or ~ m pc,, si, e lac nt of a c nent. st maintena e testin ra ilit f t."e s stem or c Explicit sow~ a~ y ost asiataaaace urvei ance equirements have %herefete been roe+ ~ ftS few~ ~s,~ leted from the SSES ITS. Entry into the applicable Nodes SUSQUEHANNA UNIT 1 ANO 2 Revision 0. 07/31/96 h4ILc. RhT X.l f l3 OISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING ~+stets~+> without performing this post be precluded except where m~~w testin allowed, as discussed in the 8as SR 3.0.1. This is an adminjstratjve change with no i safety because there is no chan e to th op ~4e 6 co,4e'o~ T HN A HAN - R TR T V M.1 (Unit 2 Only) SSES CTS 3.8.1.1 requires Ooerability of four diesel generators and the two offsite circuits that'upport the Unit's Class lE distribution system. SSES ITS 3.8.1 retains these requirements and. for Unit 2. adds a specific requirement for the OG(s) and qualified circuits needed to support the Unit 1 onsite Class 1E AC electrical power distribution subsystem(s) required b LCO 3.8.7, Oistribution Systems-Operating. This change is necessary because some equipment needed to meet Unit 2 accident analysis is powered from the Unit 1 AC Electrical Power System. Currently, SSES CTS 3.8.3.1 for Unit 2 recognizes this requirement by requiring Operability of those Unit 1 busses that support equipment required in the Unit 2 accident analysis. However. Unit 2 SSES CTS establishes requirements for the Unit 1 AC sources only to the extent that the definition of Operability requires the normal and emergency power sources of the Unit 1 equipment to be Operable. Therefore. for completeness. the Unit 1 AC sources required to support Unit 2 have been added to SSES ITS 3.8.1. This is a more restrictive change because specifying an explicit allowed out of service time and Surveillance Requirements for the Unit 1 AC sources make this an additional restriction on, plant operations. SSES ITS SR 3.8.1.21 and a Note to the Surveillance requirements have been added to ensure that the Unit 1 AC sources are properly tested and that the appropriate SRs are applicable for each units AC sources. These requirements are not being added to the Unit 1 SSES ITS because there is no AC equipment required by the Unit 1 accident analysis that is power from the Unit 2 AC Sources. This more restrictive change is acceptable because it does not introduce any operation which is un analyzed awhile establishing more complete requirements for AC sources than currently required. merefore. this change has no negative impact on safety. SSES CTS 4.8.1.1.2.d.12 requires verification that each diesel generator loading sequence timer shown in Table 4.8.1.1.2-2 is Operable with its setpoint within 10K of its design setpoint, except for the RHR pump timers. which may have a tolerance of + 20K. - 104. SSES ITS SR 3.8. 1. 18 expands this requirement to include verification of the load timers used to sequence ECCS loads when offsite power is available. The timers associated with offsite power serve the same purpose as the timers associated with the DG, i.e., prevent simultaneous equipment starting from SUSQUEHANNA UNIT 1 ANO 2 Revision 0, 07/31/96 AC Sources-Oper ating 3.8. i SURVEILLANCE REOUIREMEHTS continued SURVEILLNCE FREQUENCY SR 3.8.1. )1 NOTES l.. All 06 starts may be preceded by an engine prelube period. Q/lLaaik: 9g-to-or 2. urv ance hall no be o in l. 2, 3. r, c t may taken f II he a Verify on an actual or sirrrulated loss of 18 months offsite power signal: s4

a. Oe-energfzation of ~rergeney buses;

b. Load shedding fram e~eey buses; and

c. DG auto-starts froe standby condition and:

I. loads in S ~ energizes permanently connected seconds, energizes auto-connected shutdown ~Neer],

3. Naintains steady state voltage Vend<[ ) V, 44bb 37Co araintains steady state frequency Z [m.8> Hz and Z <81.2i Hz, and

5. supplies permanently connected and P.

auto-connected shutdown loads for h f5/ rainutes. (continued) BN/4 STS 3.8-10 Rev 1, N/07/95 ea.c C.A~ ~ B.r-(g AC Sources -Operating ~.~.i-lg 8 3.8.1 BASES <r SURVEILLANCE SR 3. . (continued) REQUIREMENTS is intended to be consistent with expected fuel cycle lengths. This SR is modified by two Notes. Note 1 specifies that DG E shall satisfy this SR while aligned to each of'he eight (four Unit 1 and four Unit 2) 4.16 kV ESS bus on a rotational test basis which also alternates between Unit 1 and Unit 2. This is performed as follows: UNIT IN OUTAGE DIESEL E SUBSTITUTED FOR 1 Diesel Generator A 2 Diesel Generator C 1 Diesel Generator 8 2 Diesel Generator D 1 Diesel Generator C 2 +et a<4L+4 W4 J 1 Diesel Generator D

• shd os ~ I'4 2 Diesel Generator A 4Q 1

~> gs neg el(csaasec~ C cJ de 6'chssH c~ SOceeC, 2 Diesel Generator 8 Ceno)+ pi ki ~c )g ote 2 provides an allowance that this SR does not have ~o+ 'o to e performed with the normally aligned DG when the cacti +cs cocci JC. ssociated 4.16 kV ESS bus is tested using diesel s<4 C<<ci4i generator E. The allowances specified in Notes 1 and 2 are ~~ < g ~cd~)o~ acceptable because the tested attributes of each of the five ~~ ~o~w< r ~~>diesel generators and each unit's four 4.16 kV ESS buses are ~<<erified ~ *'n .16 at the specified kV ESS bus is tested Frequency (i.e.. each DG every 24 months). S ecifically, DG E is tested with 4 Unit 1 4.16 kV ESS l>us. the ~ attributes of the normally aligned DG, although not tested ith the Unit 1 4. 16 kv ESS bus. are tested with the Unit 2 and each ~44 y c - ~i + 4.16 kV ESS bus within tti 24 month Frequency. 4 per4rw ideas ge fcC~ (6W a~ s~ pyoc ~ f E g ssp Pre f sess Et cs>safe w Ee vvag as t Cwe ~ L6 Of 4nw <+gg'iSC J fthka( (continued) SUSQUEHANNA - UNIT 1 8 3.8-28 Amendment A. 07/31/96 DISCUSSION OF DEVIATIONS FROH NUREG 1433 ~4+? x.S.<- I'7 ITS: SECTION 3.8.1 - AC SOURCES - OPERATING N N- P ANT F CHAN (continued) Completion time to allow taking credit for SR 3.8.1.2 as demonstration that a DG is not inoperable due to a comon cause failure if completed up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to entering Condition B. This change is needed to maintain an allowance in the SSES current Technical Specification 3.8.1.1.b.2.a. P.5 NUREG-1433, Revision 1, LCO 3.8.1. Required Actions 0.1 Note, which provides direction when Condition D is entered with no AC power source to any division, is modified to become SSES ITS 3.8.1. Condition G. The Required Actions 0.1 Note is not applicable to SSES because Condition 0. one offsite circuit and one DG inoperable. does not result in loss of AC power to any division. SSES ITS LCO 3.8.1. Condition G. provides equivalent direction by ensuring that the more appropriate Actions in LCO 3.8.7 for loss of power to an ESS bus are entered when an inoperable DG and two inoperable offsite circuits result in loss of power to one 4.16 kV ESS bus. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant or generic deviation from NUREG 1433. p.6 NUREG-1433 'evision 1. LCO 3.8. 1. Condition F. automatic load sequencer inoperable. is deleted because SSES uses individual load timers for sequential loading of the 4.16 kV ESS buses. Individual load timers are tested by each of the SRs that verify sequential loading of the DG or 4. 16 kV ESS bus and are calibrated as required by SR 3.8.1.18. The failure of an individual load timer would result in the associated OG or offsite sources being declared inoperable. as appropriate. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant or generic deviation from NUREG 1433. P.7 NUREG-1433. Revision 1, LCO 3.8.1. Condition H. is modified to describe the SSES specific conditions representing a level of degradation in which all redundancy in the AC electrical power supplies has been lost. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does rot represent a significant or generic deviation from NUREG 1433. (Se ITS LCO 3.8.1. 0 SL >.a.r A i.eC:A ir>t P.8 NUREG-1433, Revision 1. .!.2 and SR 3.8.1.7 start tests). SR 3.8.1.9 ingle load regect test), SR 3.8. 1.10 (full load reject test). R 3.8.'. !4 (load run test). and SR 3.8.1. 15 (hot restart test) were changed to include a Note that specifies . that "A single test at the s"e 'f ed Frequency will satisfy this Surveillance for both units. Eacn of these tests verifies OG Operability by testing DG attributes that are not associated with either Unit 1 or Unit 2. This change recognizes that performing the identical test twice once for each unit. does not provide a better verification of eraci l.t and auses unnecessar k)k.J i Nvc Lcei w aC t'ai M.r.> i~J Lail iw gu" SUSQUEHANNA UNIT 1 AND 2 2M 4$ 4i$ ~pe~ ic <>tr source rhfle the restoratfon of offsfte porer, t>>trgancy 1oads upon a sf>>ulateo b) Transfer fts loads to tht offsfte peer source. and c) de restored to fts standby status. ZR s.s.l.17 Vtrffyfng that rfth tht dftatl >>odt and connected to fta gentratO Optratfng fn a teat overrfdas the test >>ode by bus, a ated ECCS actuatfon sfgna1 to stanaby operatfon. and (1) returnfng the dftsel generator (2) autoeatfca11y entrgfzaa the ~ >>ergency Ioads rfth offsfte parer. Verff fn that tach dfeat1 R .LI.I7, < Ga S.s.i.!8 sn n a I~ ... ~ tn rator los fa OPERAdLE s rfth fts fthfn fch h ~ R p trffy that th ol1orfng djaael generator o preven tati generpa& startfng and/ 0 operat'I ea requf whtn a) E ne oversp b) enerator ferentfal. fne 1 1 ssurt At least once per 18 ars or tar SB 3.8.1.iO a c r~ generators a aultaneously, ur n en s by startfng all dfest dftsel generators accelerate to at least u and vtr n that a11 6 n eaa than or equal to 10 seconds. 'L.l'I At ea once pir yitP~~ sedf and clean) Irl the tank u tfg a sodf ~ alent so'lut . and 1or 5 or erfotefng a asure teat those po sfgntd to S fon III. s ectfonofId)theo theselAS% of 1 systaa ona fue 5n rdance rf fon XI Art5olt IIa0-5000. 4.8.LL3>> Oftael generator rhen not alfgned daaonstrated OJERAILE by: f te the Class IE Systae shel'1 be

a. ~ ng n o th the s T 1 4.8.1.1 Z L

'L The fuel'ltvel fn SR $ .8.1 0 the engfn~~ted day fuel tank. gg. %13.1 The fuel ltvtl fn the fuel storage tan 31 ~All planned starts for the purpose of these a prelubt perfod fn accordance rfth vendor survefllancts aay be preceded by rtc~ndatfona. SUSQJEHANA INIT 1 F488 Aae~nt No. 183 i,nv5 c DISCUSSION OF CHNGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING H A HAN TR T V (continued) license amendments to these Administrative Control reaufrements will be reduced. This change is a less restrictive ahainistrative change with no impact on safety. LA.4 SSES CTS 4.8.1.1.2.d.2 and 4.8.1.1.3.d.2 require that each DG maintaining the specified voltage and frequency when rejecting a load of greater than or equal to 1425 kW. SSES ITS SR 3.8.1.8 requires that each DG meet specified acceptance criteria when rejecting a load greater than or equal to fts associated single largest post-accident load. The descript1on nd the size of the largest single load w1ll be maintained in the ases or ~<~~LL~c SR 3.8.1.8. This change is acceptable because the requirement t o< 4 erform a load reject1on test with a load equivalent to the argest s1ngle load fs maintained 1n Technical Soecfficatfons. The descrfptions and size of the largest s1ngle ioad will be ~ ~)I g l~ maintained in the Bases'hich require change control in accordance with the SSES ITS 5.5.10. Bases Control Program. This approach provides an effective level of regulatory control and provides fo-a more appropriate change control process. The level of safety o facility operat1on is unaffected by the change because there is n~ change in the requirements. NRC and PPKL resources associated with processing license amendments to these Administrative w111 be reduced. This change is a less restrfctive Contro'equirements administrative change with no impact on safety. LA.S SSES CTS 4.8.1.1.2.d.l2 requires verifying that each diesel generator loading sequence timer listed in Table 4.8.1.1.2-2 is xi cia 9 4< operable with 1ts set P oint with1n 104 of fts desi g n s etpoint. moo kgb except for the RHR p timers which may have a tolerance of +20%, -10K. SSES ITS SR 3.8.1.17 requires verifying the interval +a4Q etween each sequenced load block fs with1n + 104 of design +~ 'nterval for each load timer except that the RHR pump timers must j<fyy)>>4p I>> e within +20K and -10% of the design interval. The list of N~< ndivfdual load timers and the allowable value for each load timer Ma 4t) 's relocated to the Bases for SSES ITS LCO 3.8.1. Remov1ng this coal)g) fey't Nl informat1on from Technical Specifications is consfstent with the w~y This change is acceptable because the 4'qau, MR STS NUREG-14 Q )~re %<M>>O4]y, equfrement to test the setpoint and tolerance for the individual cW>>y. e4c> load timers is maintained in the Technical Specifications. The ~ 44 tL)4 L~ 11st of load timers and the allowable values will be maintained in c4>>)i the Bases which require change control in accordance with the SSES 104'l~ ttq&~ TS 5.5.10. Bases Control Program. This approach provides an I>> Ttgsaeg ~l ggg~)~ ffective level of regulatory control and provides for a more-I ppropriate change control p rocess. The level of safet y of facility operation is unaffected by the change because there is no change in the requirement to perform the SR. Furthermore. NRC and PAL resources associated with processing license amendments to these Administrat1ve Control requirements will be reduced. This change is a less restrictive administrative change with no impact on safety. SUSQUEHNNA UNIT 1 ND 2 Revision 0, 07/31/96 x8i->r g C.i.-o' 0-sg - Lx AC Sources -Operating B 3.8.1 BASES lC SURVEILLANCE SR 3.8. (continued) REQUIREMENTS when DG E is tested with a Unit 1 4.16 kV ESS bus. the attributes of the normally aligned DG. although not tested with the Unit 1 4.16 kY ESS bus, are tested with the Unit 2 4.16 kV ESS bus within the 24 month Frequency. R 38 '7 Under accident conditions, loads are sequentially connected to the bus by individual load timers which control the c, ~,~ ~ ~< permissive and starting signals to motor breakers to prevent. overloading of the AC Sources due to high motor starting c +hgs p ~ "c'~ + ~ rr "~~4J urrents. The load sequence time interval tolerance ensures hat sufficient time exists for the AC Source to restore irr e c ~~ re uency and voltage prior to applying the next load and ~lay~ 4Q Q Ji that safety analysis assumptions regarding ESF equipment Va C time delays are not violated. Reference 2 provides a Tag+ ~tlag~ surtliary of the automatic loading of ESS buses. A list of the required timers and the associated setpoints are included in the Bases as Table B 3.8.1 1, Unit 1 and Unit 2 Load Timers. Failure of a timer identified as an offsite power timer may result in both offsite sources being inoperable. Failure of any other timer may result in the. associated DG being inoperable. The 24 month Frequency is consistent with the recommendation of Regulatory Guide 1.9 (Ref. 3). takes into consideration plant conditions required to perform the Surveillance, and Z~e t~a~ j loaok is intended to be consistent'with expected fuel cycle lengths. C~ 4lLSoCIg4al ~i~lw( +oui~ This SR is modified by a Note that specifies that load kvcW timers associated with equipment that has automatic., h~ owly initiation capability disabled are not required to be Si~grc. r~ J, Operable. This is acceptable because if the load does not start automatically, the adverse effects of an improper loading sequence are eliminated. SR In the event of a DBA c:incident with a loss of offsite power, the DGs are require to supply the necessary power to (continued) SUSQUEHANNA - UNIT 1 B 3.8-30 Amendment A. 07/31/96 eke Mz z.8.(-2Z AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY SR 3 '.1.2 ---------NOTES

1. Pe ormance of SR 3.8.1.7 sa sfies t s SR.

2. All DG starts may be pre ded by an engine prelube period a followed by a warmup period prior o loading.

A modified DG start nvolving idling and gradual accele tion to synchronous speed ay be used for this SR as recommende by the manufacturer. When modified s art procedures are not used. the time. voltage. and frequency tolerances of. SR 3.8.1.7 must be met.

4. A single test at the specified Frequency will satisfy this Surveillance for both units.

Verify each DG starts from standby 31 days conditions and achieves steady sta e voltage i 3793 V and ~ 4400 V an frequency ~ 58.8 Hz and ~ 61.2 Hz. (c ued) SUSQUEHANNA - UNIT 1 3.8-5 Amendment A. '07/31/96 fviM ~at 'y Q (~ gg AC Sources -Operating 3.8.1 SURVEILLANCE REQUIREHENTS (continued) SURVEILLANCE FREQUENCY 3.8.1.4 ify each SR Ver oil level is i engine mounted day tank fuel 345 gallons for each OG. 31 days SR 3 '. 1.5 Check for and remove accumulated water from each engine mounted day tank. 31 days SR 3.8.1.6 Verify the fuel oil transfer system 3l days operates to automatically transfer fuel oil from the storage tanks to each engine mounted tank. SR 3.8.14 NOTES AC All OG starts may be preceded by an engine prelube period. 7

2. A single test. at the specified Frequency will satisfy this Surveillance for both units.

3l Verify each OG starts from standby ~days condition and achieves. in s 10 seconds, voltage a 3793 V and frequency

• 58.8. and frequency i maintains voltage 58.8 Hz i i 3793 V and and 61.2 i

after steady state conditions are reached. 4400 V and Hz. Twcg+ > 8-7 I SR 3.8.1./ Verify automatic and manual normal transfer of 24 months unit power supply from the offsite circuit to the alternate offsite circuit. (continued) SUSQUEHANNA - UNIT 1 , 3.8-7 d t~ I~ /14llf r AR.c, RAY 3.8.t- R3 'C Sources -Operating B 3.8.1 BASES SURVEILLANCE SR REQUIREMENTS 15 (continued) These-SPgf help to ensure the availability of the standby electrical power supply to mitigate OBAs and transients and maintain the unit in a safe shutdown condition. To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs have been modified by a Note ( Note 1 t I 61 th t 11 66 t f th Surveillances may be preceded by an engine relube period . o oa ing. For the purposes of this testing, the OGs are started from standby conditions. Standby conditions for a OG mean that the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer. recommendations. n order o reduce stress and wear diesel engin Cooper- essemer. th diesel genera r manufacture , rec ds a modif ed start in w ch the starti speed of OGs i limited. w rmup is limit to this lowe speed, and the s are gra ally acceler ed to synchro us speed prior to oading. use of thes start proced es are the in ent of Not 3 which is nly applicabl when such t procedures are recomend b t ~ mo ified st anufactur SR '~~ starts requires that. I from standby conditions and achieves the minimum the OG required voltage and frequency within 10 seconds and maintains the required voltage and frequency when steady state conditions are reached. The 10 second start. requirement supports the assumptions in the design basis 66th st If I f 16th. 6 ir n <<6.3 13 f. 12). ed above is used 'es. ince SR .8.1.7 does uvre a 10 s ond start, t is more restric ive than SR 3 . 1.2. and it aj be perf med in lieu of SR .8.1.2. This procedure is he intent o Note 1 of R (continued) SUSQUEHANNA - UNIT 1 B 3.8-15 Amendment A, 07/31/96 4 kC n,Pi i.O.<-Z.~ AC Sources -Operating B 3.8.1 BASES SURVEILLANCE REQUIREHENTS SR 2~ 3. To minimize Ilt requirements each unit). intended to testing of for both t 11 uni (continued) s, 21 1 t. iiytt (instead of two tests, one for This is acceptable because this test is demonstrate attributes of the OG that are not associated with either Unit. If the OG fails this Surveillance. the DG should be considered inoperable for both units. unless the cause of the failure can be directly related to one unit. lt tldyy Regulatory Guide 1.9 (Ref. 3). e day Fr ency fo n cold c nsi eneric L ter 84-15 ( ef. use Frequenc rovid a equa e assurance o OG OPERABILITY. while minimizing degradation resulting from testing. SR 3.8 This Surveillance verifies that the OGs are capable of synchronizing and accepting greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source. Although no power factor requirements are established by this SR, the OG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while 1.0 is an operational limitation to ensure circulating currents are minimized. The load band is provided to avoid routine overloading of the OG. Routine overloading may result in more frequent teardown inspections inbotanical accordance with vendor recomendations in order to maintain DG OPERABILITY. Note 1 modifies this Surveillance to indicate that diesel engine runs for this S~.veillance may include gradual loading. as recommen"e" oy the Cooper Bessemer Service Bulletin 728, so that stress and wear on the diesel engine are minimized. (continued) SUSQUEHANNA - UNIT 1 B 3.8-1o Amendment A. 07/31I96 ~Ac. M1 s.e.i-zs 'R S.l -lg AC Sources -Operating . B 3.8.1 BASES SURVEILLANCE REQUIREMENTS ~SR ~6 (continued) associated storage tank to its associated day tank. It is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE. the fuel oil piping system is intact. the fuel delivery piping is not obstructed. and the controls and control systems for automatic fuel transfer, systems are OPERABLE. The Frequency for this SR is 31 days because the design of the fuel transfer system requires that the transfer pumps operate automatically in order to maintain an adequate volume of fuel oil in the day tanks. This Frequency allows this aspect of DG Operability to be demonstrated during or following routine OG operation. v~ccP 7 Transfer of each 4.16 kV ESS bus power supply from the normal offsite circuit to the alternate offsite circuit demonstrates the OPERABILITY of the alternate circuit distribution network to power the shutdown loads. The 24 month Frequency of the Surveillance is based on engineer ing judgment taking into consideration the plant conditions required to perform the Surveillance. and is intended to be consistent with expected fuel cycle lengths. Operating experience has shown that these components usually pass the SR when performed on the 24 month Frequency. Therefore. the Frequency was concluded to be acceptable from a reliability standpoint. Credit may be taken for unplanned events that satisfy this SR. 3-8.- <>- / R 5 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the, loss of a large lc d could cause diesel engine overspeed, which, if excessive, might result in a trip of (continued) SUSQUEHANNA - UNIT 1 ~ B 3.8-19 Amendment A. 07/31/96 \ ~Cc R.+T 3 8 l-Z.y AC Sources -Operating B 3.8.1 BASES BACKGROUND ST No. 10 and ST No. 20 each provide the normal source of (continued) power to two of the four 4.16 kV ESS buses in each Unit and the alternate source of power to the remaining two 4.16 kV ESS buses in each Unit. If any 4. 16 kV ESS bus loses power. an automatic transfer from the normal to the alternate occurs after the normal supply breaker trips. When off-site power is available to the 4.16 kV ESS Buses following a LOCA signal, the required ESS loads will be 'sequenced onto the 4.16 kV ESS Buses in order to compensate for voltage drops in the onsite power system when starting large ESS motors. t The onsite standby power source for 4.16 kV ESS buses A. 8 ~ C and D consists of five DGs. OGs A, 8, C and D are dedicated to ESS buses A. B, C and 0, respectively. DG E can be used as a substitute for any one of the four DGs (A. 8, C or D) to supply the associated ESS bus. Each OG INK p~ provides standby power to two 4. 16 kV ESS buses -one ssociated with Unit 1 and one associated with Unit 2. The four "required" DGs are those aligned to a 4.16 kV ESS bus i ollo~w) 4~ c to provide onsite standby power for both Unit 1 and Unit 2. 'tpap 0 ua4 ~ 5 %wc'4<Js A DG, when aligned to an ESS bus. starts automatically on a $ &PPc J. 5'ho~ loss of coolant accident (LOCA) signal (i.e., low reactor t4c l.ia 4'v ca ater level signal or high drywell pressure signal) or on an 644M ESS bus degraded voltage or undervoltage signal. After the i~ MdW 4'a OG has started. it automatically ties to its respective bus Kss &~s, I~~ fter offsite power is tripped as a consequence of ESS bus ndervoltage or degraded voltage. independent of or "'5 coincident with a LOCA signal. The DGs also start and operate in the standby mode without tying to the ESS bus on <<>f<c4w c'ss a LOCA signal alone. l~d ~~~ 'Wc~id i( ~ Jw4~d c.l t~ In the event of loss of normal and alternate offsite power supplies, the 4.16 kV ESS buses will shed all loads except co aft' the 480 V load centers and the standby diesel generators $ 4 -4>> ill connect to the ESS busses. When a DG is tied to its espective ESS bus. loaCs are then sequentially connected to ~<s~l he ESS bus by individual load timers which control the <cia~ ' ao permissive and starting signals to motor breakers to prevent Oucc. (agJ, P Q overloading the OG. In the event of a loss cf normal and alternate offsite power supplies, the ESS elec:rical loads are automatically (continued) SUSQUEHANNA - UNIT 1 B 3.8-2 Amendment A, 07/31/96 AC Sources-Operating B 3.8.1 BASES LCO (continued) gIn addition, ~ bus+ 'shall be OPERABLE.Q required automatic load ESF Sr pJo. I o c val ".ach offsite circuit must be capable of maintaining rated eo.xcp 7 /Ha frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses. Each offsite 3p q 0~ c connect to espective trans ormers, an r ective I'~ s ses. Feed r breakers from ch circuit pre required t the 2F ESF us; however, if SAT is co ected nd 2D SAT is co ected to 2 ~ o ESF b 2E (or 26) or 2E), a 3.I'A. i d. I Each G mus 4e capalge o artsng, cce er ing to a e sp d and oltage, d con ecting t its re pectiv SF us detec on of bu under oltage n cco 1 shed with n 12 conds. Each DG must also be capa e o accept ng require oads within the assumed Q ~ ~-H-0> loading sequence intervals, and must continue to o crate until offsite power can be restored to the uses. These capabilities are required to be met from a variety of initial cond)tions, such as DG in standby with the engine hot arid DG in standby with the engine at ambient condition. Additional DG capabilities must be demonstrated to meet required Surveillances, e.gue capability ef the DG to revert to standby status on an ECCS signal while operating in parallel test node. l.nuud: 'roper sequencing of loads, including tripping of nonessential loads, is required function for e, g g.ci is u a Dg OPERABILITY. The AC sources must be separate and independent (to the extent possible) of other AC sources. For the DGs, the separation and independence are complete. For the offsite AC sources, the separation and independence are to the extent practicil. A circuit may be connected to more than ~ie tSF bus with transfer capability to the other c rcul circuit that is not connected to an ave E E ~ RABL , and not v>olate separation criteria. bus s requ>re transfer interlock mechanisms to at-Ie'~ A o SF buses to support OPERABILITY of that circuit. pss (continued) BMR/4 STS B 3.8-4 Rev I, 04/07/95 AC Sources-Operating B 3.B.l BASES SURVEILLANCE ~RR .9 (continued) REQUIREMENTS

a. Tripping the DG output breaker w1th the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power, or Q(,n while solely supplying the bus; or

h. Tripping its associated singl ~ largest post-accident load with the DG solely supplying the bus.

3 As by KE~@ (Ref. ), e load rejectfon test fs acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip set oint, or IS% above synchronous speed, whicheve fs equivalent to 75K of the difference between nominal speed an the overspeed trip setpoint. t / The time, voltage, and frequency tolerances specified in thi SR are derived from Regulatory Guide 1.9 (Ref. 3) recoammndatfons for response during load sequence intervals. ~heee- seconds specified is equal to 6Nf of the load sequence interval associated with sequencing the ~~ secon concurrent with a LOCA. The voltage and frequency specif1ed are consistent with the design range of the equipment powered by the DG. SR 3.S.l.gea corresponds to the maximum frequency curs on, w i e . . . . steady Gl state voltage and frequency values to which the system must recover following load rejection. The..~ month/ Frequency is consiste t pith the recommendation of:,Regulatory guide (Ref. 0 . ~ This SR is modified by two Notes. The ason or te is a ul ln ea r critica performan Pih of is SR ld cause p urbatf s to the e ctrical str1bu n systems t coul hallenge tinued st y state eration an as a re t, plant fety syste Cred may be ta hfs r that the OG is tested under load conditions are a se o design basis conditions as possible, Note 2 requires that, if synchronized to offsite power; esting must be erformed using a power factor c This power factor is chosen to be representative of he actual.desig basis inductive loading that the OG woul experience. Zhhyhduay ' o.5~' 3,8-& f-Oi P.b (continued) BN/I STS B 3.8-2l Rev l, Ol/07/g5 ~M kW 3.8.i.4t'. DISCUSSION OF DEVIATIONS FROM NUREG 1433 ITS: SECTION 3.8.1 - AC SOURCES - OPERATING NON- RA K D PLANT SP F CHANGES (continued) P.14 The NUREG-1433. Revision 1, SR 3.8. 1. 18 was revised to reflect the SSES design which uses individual load timers versus a load sequencer as assumed in the NUREG. In conjunction with this change. the Bases for LCO 3.8.1 were modified to include a list of DG and offsite power load timers and their required tolerances. SrL 5,5.i.tt wgq Additionally. a note was added that specifies that load timers o 4o associated with equipment that has automatic initiation capability c,ls~ disabled are not required to be Operable because if the load does ~ h<gapi ~" et'~ ot start automatically. the adverse effects of an improper oading sequence are eliminated. Conversely. if a load timer will <boi.ii not start the required load. the more conservative actions associated with the loss of an AC source are required until the dy~Jgg ~ lg Algf associated load has automatic initiation capability disabled and ~ca,A ba>CP W e appropriate Conditions are entered for the loss of the ~s~ in iv u . This change is needed to ensure that SSES Improved Technical Specifications account for the SSES design and/or that the SSES design is accurately and completely described in the Bases. Therefore, this change is not a significant or generic deviation from NUREG 1433. P.15 The NUREG-1433. Revision 1. SR 3.8.1.13.d and 3.8.1.13.e. requirements for testing override features associated with high crankcase pressure and the start failure relay are deleted because SSES DGs do not have these features. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore, this change does not represent a significant or generic deviation from NUREG 1433. P. 16 The NUREG-1433, Revision 1, SR 3.8.1.14. requirement that the DG full load endurance run be conducted operating at a specified power factor is deleted. This change is acceptable because SSES endurance runs are conducted at DG power levels significantly higher than peak post accident DG loads. Therefore. SR 3.8.1.14. even if conducted at a unity power factor. is conducted at a kYA rating that exceeds the peak post accident kVA loading. This change has been made to ensure that Improved Technical Specifications account for the SSLS design which has DG ratings higher than the maximum post accident loads. Therefore. this change does not represent a significant or generic deviation 1433. fry'UREG P.17 NUREG-1433. Revision 1. SR 3 8 1.16 (synchronize and transfer power test) and 3.8.1.17 (test ~e override). are modified by t~o new Notes which maintain the current licensing basis allowances for rotational testing of diesel generator E in SSES CTS 4.8.1.1.2.d.l0, 4.8.1.1.3.d o a iv, and 4.8.1.1.3.d.6.b.iv.a and SSES CTS 4.8.1.1.2.d.6.c. 4 8 I 1.3.d.6.c. and 4.8. 1.1.3.d.6.b.iv.b. This c"~ ",e has been made to ensure that Improved Technical Specifica ic .s account for the SSES design. Therefore. this change does ro: represent a significant or generic SUSQUEHANNA UNIT 1 AND 2 5 Revision 0, 07/31/96 ~ ~0 ggr 'p 'W ~ ~ INSERT: B 3.8-26-01 To minimize testing of the DGs, Note 1 to SR 3.8.1.13 allows a single test (instead of two tests, one for each unit) to satisfy the requirements for both units. This is acceptable because this P~ test is intended to demonstrate attributes of the DG that are not associated with either Unit. If the DG fails this Surveillance, the OG should be considered inoperable for both units, unless the cause of the failure can be directly related to only one unit. Note 2 allows DG E to satisfy SR 3.8.1.13 for both units by using ttf test facility to simulate the 4.16 kV ESS bus. This is acceptable this test is intended to demonstrate attributes of the DG that 'ecause are not associated with either Unit. ~ <1 I 1~ 2 g t~gg AC Sources -Operating 3.8.1 khi z.g. i -vz. SURVEILLANCE REQUIREHENTS (continued) SURVEILLAttCE FREQUENCY SR 3.8.1.$ If perfo with th OG synchro zed th off te power. it shall b erfor d at a p r factor s A s1ngle test at the specif1ed Frequency will satisfy th1s Surveillance for both units. Verify each OG rejects a load greater than 24 months or equal to its associated s1ngle largest post-accident load. and: a.. Following load re5ection, the i frequency 1s 64.5 Hz; b.'ithin 4.5 seconds following load the voltage 1s 3760 V i and re5ection, s 4560 V. and after steady state condit1ons are reached.. maintains i voltage 3793 V and s 4400 V: and

c. Within 6 seconds following load rejection, the frequency is 58.8 i Hz and s 61.2 Hz.

SR 3.8.1.P - ------------NOT the sync ro z t offs1 e power. at a powe 1 shall factor b 0.89. IO .- er fo A single test at the specified Frequency will satisfy this Surveillance for both units. % A & % '0 % & % W % % & H & A && % % % % A \ ae&eO&e&Aaaa&A&a&a& '0 Q ' ~ Ver1fy each DG does not trio andfollowing voltage is 24 months a maintained s,4560 V during and load refection of ~ 4000 tQ. (contirue0'.,i ii lR ~ ) - UNIT I 3. 8-8 SUSQUEHANNA 411+1+ 0'gJ $ ~ j + ~ 'A)3 AC Sources -Operating B 3.8.1 NR.c. A.A4. 2 Q. I- vQ BASES StjRVEILLANCE {continued) REQUIREHENT'~ the engine. 'This Surveillance demonstrates the OG load response characteristics and capab1lity to reject the largest single load without exceeding predeterm1ned voltage and frequency and while maintaining a specfffed margin ta the overspeed trip. The largest sinale load for each OG is a residua] heat removal (RHR) puma ($ 425 kM). This Surveillance may be accomplished by:

a. Tripping the OG output breaker with the OG carrving greater than or equal to 1ts associated single largest post-acc1dent load while paralleled tb offsite pe er.

or while solely supplying the bus; or

b. Trfppfng 1ts associated sfngle largest post-accident load with the OG solely supply1ng the bus.

As recommended by Regulatory Guide 1.9 (Ref. 3). the load rejection'est fs acceptable if the 1ncrease in dfesel soeel does not exceed 75X of the d1fference between synchronous speed and the overspeed trip setpo1nt, or 15X above synchronous speed. whichever fs lower. For OGs A. 8. C. 9 and E, this represents 64.5 Hz. equivalent to 75X of tt'e difference between nominal speed and the overspeed trip setpoint. The time. voltage. and frequency tolerances specified in this SR are derfved from Regulatory Guide 1.9 (Ref. 3) reconliendatfons for response during load sequence fntervs's The 4.5 seconds spec1fied is equal to 60X of the 7.5 sec~ load sequence interval assoc1ated with sequenc1ng the ~~ umps dur1ng an undervoltage on the bus concurrent with I e XA. The voltage and frequency specified are consist~ with the desfgn range of the equipment powered by the QG SR 3.8.1.9.a corresponds to the maxfaam frequency excurs w while SR 3.8.1.9.c specifies the steady state voltage a~d frequency values to wtiich the system must recover foll@ load rejection. The 24 month Frequency is cons1stent with the recoaeencat w of Regulatory Guide 1.9 {Ref. 3) and is intended to be consistent with expected fuel cycle lengths. s if by two No s. Not t ensures are as ose at 1s tested u er load c t1ons (conti~.ed) - 3.8-20 A d SUSQUEHANNA UNIT 1 . B

4. J. 4d(a ~ Ifg

QF Q 'l'+g AC Sources-Operatfiig 8 3.8 y A)M 44> 7.p.<-yi . SURVEILLANCE REQUIREHENT~ design sis condft ns as possi le: therefor . testing st be per ormed usin power fa r ~ 0.89. 1s power actor is.c sen to be presentati of the a al desig asi ductive loadi Col To minfm1ze testing of the OGs.Pote g allows a s1ngle test to satisfy the requirements for both units (instead of two tests. one for each unit). This fs acceptable because this test is intended to demonstrate attr1butes of the DG that are not assocfated w1th e1ther Unit. If the OG fails this Surveillance, the DG should be considered ~inoperable for both units. unless the cause of the failure can be directly related to only one unit. iO Thfs Surve1llance demonstrates the DG capab111ty to regect a full load without overspeed trtppfng or exceeding the predeterm1ned voltage 11mits. The 6G full load re)ection may occur because of a system fault or 1nadvertent breaker tripping. Th1's Surveillance ensures proper engine generator load response under the simulated test condit1ons. This test simulates the loss of the total connected load that tre OG experiences follow1ng a full load refection and verifies that the OG does not trip upon loss of the load. These acceptance criteria provide OG damage protectfon. While tl c OG is not expected to experience this transient during an event. and continues to be available. this response ensures that the OG 1s not degraded for future applfcat1on. 1ncluding reconnect1on to the bus if the trip initiator can be corrected or 1solated. s fs 'f1ed by two Note o e a .eDG that are a lose t SR tested u er load cond1t1o esi~ 1s asfs con 1ons as possibl therefore. st1ng t be erfo using a power f or s 0.89. fs pow factcr lW os o be representa e of the a al desi basis nduct1 ve lo ld erfen To minimize testing the OGsQNote g allows a single test units (instead of t~ oS to sattsfy the requirements for both is acceptable because tiiis tests, one for each unit). This attributes of the DG that test fs intended to demonstrate (conti'd) - UNIT 8 3.8-2l ~ d SUSQUEHANNA 1 iC/sit)y mba ~g 'L.&.i-i DISCUSSION OF DEVIATIONS FROM NUREG 1433 ~~~ <4~ ~&. i-q~ ITS: SECTION 3.8.1 - AC SOURCES - OPERATING NON-BRACK T PLANT F HAN (continued) e+hr 9V-oi Weum~le4 ~ L ange is c P. 11 NUREG-1433, Revision 1. SR 3.8. 1.3 SR 3.8. 1.11, SR 3.8. 1; 12, SR 3.8.1.13, SR 3.8.1.14 and SR 3.8. 1.19 are modified by a Note that maintains the existing licensing basis permitting DG E. when not aligned to a 4.16 kV ESS bus, to satisfy these SRs using the test facility. The Notes to SR 3.8. 1. 11. SR 3.8. 1. 12 and SR 3.8.1. 19 include the additional clarification that portions of the test that verify attributes of the 4. 16 kV ESS bus cannot be performed using the test facility. This change maintains current licensing basis regarding use of the DG E test facility. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore, this change does not represent a significant or generic deviation from NUREG 1433. This change is needed to maintain an allowance in the SSES current Technical Specifications. P.12 Node restrictions in NUREG-1433. Revision 1. LCO 3.8.1. for performing surveillance tests are eliminated from SR 3.8.1.8 (transfer unit power supply from normal to alternate): SR 3.8.1.9 (single load rejection test): SR 3.8.1.10 (full load rejection test): SR 3.8.1.11 (LOOP start test): SR 3.8.1. 12 (LOCA start test): SR 3.8.1. 13 (bypass of automatic trips); SR 3.8.1.14 (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load run): SR 3.8 '.16 (synchronize and transfer power test). SR 3.8.1.17 (test mode override): SR 3.8.1.18 (intervai between load timers); and, SR 3.8. 1. 19 (LOOP/LOCA test). Except for SR 3.8.1.8 (transfer unit power supply from normal to alternate) where elimination of Node restrictions is justified in Discussion of Change L. 16 for LCO 3.8. 1. not incorporating these Node restrictions into the SSES ITS maintains the current licensing basis. Elimination of these Hode restrictions is acceptable for the following reasons: performance of the SR will not render any safety system or component incperable: plant experience has demonstrated that performance >>i'his Surveillance will nat cause perturbations to any of the electrical distribution systems that could result in a challenge to .: ady state operation or to plant safety systems: and. performarce 'f this SR. or failure of the SR. will not result in an Abnormal ..rating Occurrence with attendant challenge to plant safety syst $ ~o Y P.13 s ipulation i NUREG-1433 -".idion 1. SR 3.8.1.10. th t tte full load reje ion test be g~-i'.~~ at a s ecified powe factor is moved to Note associated 8 ~ '.he SR. This change as needed because wi the DG not. para'<~ -i:o th grid. the po er factor is deter ned by plant loa ~~ f ~'~ot adjusted. herefore. power 's ctor requirement . are i:;:ic i e only when e test is i perf med paralleled the;>r ] change pr vides additional detail an is inter'-.'~ s ts improve clar ty and ensure uirements are full und r rd consistently applied. SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 INSERT NRC RAI 3.8.1-42: P.13 NUREG 1433 SRs 3.8.1.9 and 3.8.1.10 specify that test be performed at or below a specific power factor to ensure the DG is tested under load conditions, that are as close to design basis conditions as possible. The same SRs for SSES ITS, do not include the power factor testing restriction. This deviation from a NUREG 1433 requirement is necessary because calculations show that placing the limiting load on the DG at a design power factor may result in the generator output voltages exceeding the setting of the overvoltage relay. Furthermore, there is a concern that operation requiring adjustment and maintenance of a specific power factor with the DG in parallel with the offsite source may result in undesired interactions with the automatic tap changer for the SU Transformer. To avoid this condition it would require the tap changer to be turned off which would limit the capability of the offsite circuit. The change is acceptable because although a the full load rejection test at the limiting power factor provides the most limiting test for the DG excitation system, the combination of other surveillance tests including the full load rejection test without the added restriction of the limiting power factor, the LOCA/LOOP Test, and the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run for the DG, including the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> run at the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the DG provide a comprehensive and representative testing methodology which ensures the DG is capable of responding to a Design Basis Event. The proposed alternative to the testing methodology established in NUREG 1433, is further supported based on the fact that power factor is not adjustable when the DG is operating in the emergency mode (isochronous). Finally, it is PPL's position that the specified surveillances would detect degradation of the generator or its excitation system through larger than normal voltage droPs, delayed voltage recovery or other operating voltage instabilities that would be observed during the performance of the surveillance. Based on the above discussion, the NUREG 1433 Surveillance Requirements have been determined to be not necessary based on the SSES unique design conditions. AC Sources Operating 8 3.8.1 SURVEILLANCE REgUIREHEHTS This Survei ance has been modified by 'otes. Note I states th momentary transients due to changing bus loads do not i alidate this test. Similarly, momentary poser factor ansients above the limit do not invalidate the test. e r son or o e s a ur n >on e e rea r crit al, pe rmance of his Su illance uld c se (g p rbati s to the lectrical istrib ion syste t sou challen continue stead ate o r a result lant s re t an may be taken for as np ann events that satisfy this SR. ~ 'ev This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal Surveillances the required voltage an requency s vn seconds. The second time is derived from the requirements of the accident analysis to respond to a design basis large break lOCA. The mont Fre uency is consistent with the recommendations of Regulatory u e . (Ref. 3 This SR is modified by Notes. Note I ensures that the test is performed with the diesel sufficiently hot. The requirement that the diesel has operated for at least@, hours Is 3,$ -$ 3'- 0 at full load conditions3prior to performance of this Surveillance is based on manufacturer recoamendations for achieving hot conditions. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance ~ith vendor reconeendations in order to maintain DG OPERABILITY. Nomenta transients due to changing bus loads do not nva a e s est. Hate 2 allows all OG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing. As required by Regulatory Guide I.l08 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and automatic load transfer fro~a he DG to the offsite source can be made and that the DG can be returned (continued) BN/4 STS 8 3.8-28 Rev I, 04/07/9S ea.c agz w..lw~ DISCUSSION OF DEVIATIONS FROM NUREG 1433 ITS: SECTION 3.&.1 - AC SOURCES - OPERATING N N- P ANT P F CHAN (continued) deviation from NUREG 1433. This change is needed to maintain an allowance in the SSES current Technical Specifications. P. 18 The Bases for NUREG-1433. Revision 1. LCO 3.8.1. are revised to describe the SSES design. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant or generic deviation from NUREG 1433. P.19 NUREG-1433. Revision 1. LCO 3.8. 1 Bases references to Regulatory Guide 1.108 as the basis for DG SR acceptance criteria and SR Frequency are changed to Regulatory Guide 1.9, Rev. 3. This change was needed to establish SR acceptance criteria consistent with current industry standards. s P.20 Editorial changes and additional design detail are incorporated as necessary to more precisely describe SSES current practice or design. These changes are self explanatory. This change provides additional detail and is intended to improve clarity and ensure the requirement is fully understood and consistently applied, There are no technical changes'to requirements as specified in NUREG 1433, Revision 1: therefore. this change is not a significant or generic deviation from NUREG 1433. IN RP RAT N R HAN T N R G-1433 R V, ~ ~( +s ~ E~) y~fo~+ None Ce ~5I a~ h0s4 4jkt ~ 4 ~ so) C.)c4 4(e.a~jc, 4) CH+ l.io ~ dcF aa ~ 6 <W ~i4 ~e ~i < c~c <C. Rcg- 4M.< etc A~ i+ Soap'I) s) ega<c.. SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 9-8' SultVaLLANCKaaaueaSaaee +++ 4.A I IContkt~l 3.Q.I -'f C sC 3'K.l l9 SimWating .a Iosswfsottsite actuation test vgnal, and: Power in conic~on w~ R > an QCCS ~ Verifying deenergislion ot shedding from the emergency the emerge~ b d I d busses. Verifying the diesel generator starts on the auto-~ ene'g~as the agency sgnal, busses wnh Permanendy loads wnhin 'l0 seconds, energises the a~nnected co~wed through the load timers and loads operates for greater than or 5 minutes while Its generator equal to is loaded with the Atter energaation. the steady emergency loads. ~ me state voltage fr uency of io ncy busses shall be maintained ~ 80 3; Mz during this test. 4l80 a 400 volts and ~ ~ Verifying that VI automatic diesel overspeed. generator ditterenbal are automatically byoassed emergency bus concurrent with a vsrittand that dte dieter uPon 't generator triPs. exceot engine and en Ine low tube oil Pressure, voltage on th 6CCS actuation signal. generator socrates tor at least 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. 9 il-S~~ct .I3 shiit. ottl,ttl Oudnd the ri haute ot thi ~ teat, Ole dieter loaded to 44~7 kW and during the rem ' enerator shall os 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> ot this QOO test. the 'diesel generator shall be loaded t 38 000 kW. .VvcQ gener or vo ge equ shVI be vo a I .u 3.0 Ma wltfiin 10 seco 0 = ge uri this te voltage atter the equency sh II signal; the maintained ady state n these'limits 3'.r3 S 3.$ .). Ig sf'.8 I lw Within minutes o within 5 min s after operatin ~ 4 w temperatures have stabl Ced at ot 800- We Verity tha hct reatart CaPablIIty 0 the dleae ~ ~ ~ ~ s ~ nnected lo 'to each el g ator do the 2 ur rating 700 kW Otocel I0NSdte ao pdocodce ~ ~ trusses nen dc dc tttcitOCOOhL eNI&ctor ITtCV 00 a 0CCodoCdt00 Velar, f Q ~~+ trtac Ioce lc dtaccor 00 evccdnco Io ~0~~~~~~~~~. cvocl rtxxeo o atccodhs 0I occcd oedtcdcc'odc. Mlcdatcdoav octtocdcc 5< 5t.l.tg SUSQUEHANNA UNIT l 3I41 5 Amenamere No. 197 150 1 \ AC Sources-Operating 8 3.8el 8ASES RENDU? SURVEILLANCE REHENTS (continued) l9 2 The M month+Frequency fs consistent with the recoamcndatfons of Regulatory Guide +-B8 (Ref. ), required to perform the Surveillance; and is intended to be consfstent with expected fuel cycle lengths. F,<1 This SR fs modified b ~Not . e reason ,e o e a orm>ng e urv ance uld rcmo a rcquir d offsi circui from s ice, p urb thc ectrfcal gg8- df b fbutio ystem, taken f unplan d d chall ge safet systems. event that sat f this S Qredft ma Under accident conditions loads ~ nenoe r~ nce control/ the permissive and starting sipnals to notor breakers to prevent overloading or the Sds due to hiph actor starting currents The -.8+jlk load sequence tine interval tolerance ensures thit suffkient tine exist for to restore frequency and voltage prior to S~/ app ying the next load and that safety ana'iysis assunptions regarding ESF equipment time delays are not violated, p,g Reference 2 provides a slmsaary of the automatic loading of ESF buses. t Q 3.E. >~ recoaeendatfons of Regulatory Guide . (Ref. ), ev requfred to perform the Surveillance; and fs intended to be consistent with expected fuel cycle lengths. PL This fs mo fie y Note. e reason or the No e s th perfo g.the S eillanc would re e a requ cd fsfte cf uft from ervice, rturb the lectrfca distrib on system and chal ange safet systems. Credi ma be take for unRi ne v n h ati this S Revfewe s Note: The>bove NSE rcstrfctfons may be deleted,- 6 35[-ao ff it an be demonstrated to the spiff, on a plagi specific bas , that perfo fng the SR we% the reactot~ any of e trfcted NDE can satisfy Cthe following cyfterfa, ap licab (continued) BN/4 STS 8 3.8-30 Rev I, 04/OT/9S y Pt INSERT: B 3.8-30-01 This SR is modified by two Notes. Note 1 specifies that OGE shal satisfy this SR while aligned to each of the eight {four Unit 1 and four Unit 2) 4.16 kV ESS bus on a rotational test basis whf also alternates between Unit 1 and Unit 2. This fs performed a shown in the Bases of SR 3.8.1.16. Note 2 provides an allowance that this SR does not have to be perfo with the normally aligned OG when the associated 4.16 kV ESS bus is tested using diesel generator E. The 'allowances specified in Notes 1 and 2 are acceptable because the tested attributes of each of the five diesel generators and each unit's four 4.16 kV ESS buses are verified at the specified Frequency (i .e., each DG and each 4.16 kV ESS bus is tested every 24 months). Specifically, when DG E is tested with a Unit 1 4.16 kV ESS bus, the attributes of the normally aligned OG, although not tested with the Unit 1 4.16 kV ESS bus, are tested with the Unit 2 4.16 kV ESS bus within the 24 month Frequency. INSERT: 8 3.8-30-02 A list of the required timers and the associated setpoints are included in the Bases as Table B 3.8.1-1, Unit 1 and Unit 2 Load 'Timers. Failure of a timer identified as an offsite power timer may result in both offsite sources being inoperable. Failure of any other timer may result fn the associated OG being inoperable. INSERT: 8 3.8-30-03 This SR is modified by a Note that specifies that load timers associated with equipment that has automatic initiation capability disabled are not required to be Operable. This is acceptable because if the load does not start automatically, the adverse effects of an improper loading sequence are eliminated. AJC.<<', Ithg $ ,Q,)>> g ) DISCUSSION OF CHANGES ITS..SECTION 3.8.1 Q~ RAg .~..0 Ac SOURCES OPERATING >-g.t -cg T CHN A CHAN - LES R STR T V (continued) Th<<l c>>L Jc current practice at SSES which is to manually top off the day tanks ever time the OGs are o p crated to satisfy a design <<<<<<cc <<i<<.i+ doe <<<< commitment in FSAR 9.5.4.2 that requires the day tank contain c4<<<<)~ ufficient fuel for one hour of operation at continuous rated load os~ hich is based on ion 6 1 To +<< it% I e current practice of manually topping off t e anks every time the OGs are operated. the Bases for ITS SR y c.~etc. o% el C Lao<<'a,t<< L<<g ~ .8.1.4 will indicate that the acceptance criteria for this SR <<<<f +ve.L ~ <<I <<0 'Try+ rovides approximately 45 minutes of operation at the post ( ccident load. Prior to implementation of Improved Technical oft, Qc4<<<<LL '44 pecifications at SSES, FSAR 9.5.4.2 will be revised to take pgplt<<4hl hl~JQ*O~ xception to ANSI N195-1976, Section 6.1. This change is is gc4 H ~w*i acceptable based on the following: da tank level is verified < ~"'4 '~- o> < ~<, +<~ o~(d ioil >> ~"') every 31 days which ensures that each DG will have sufficient fuel to start and operate for at least 45 minutes; day tank levels are maintained automatically during DG operation by the fuel oil transfer system which is tested every 31 days by SR 3.8.1.6; and. low level alarms on DG day tanks are set slightly below this level and will provide adequate time for operators to investigate and correct or compensate for a diesel fuel oil transfer pump failure. Additionally. calculations supporting 45 minutes of OG operation are based on fuel oil consumption calculations that are very conservative. Specifically. the DG post accident load for all DGs fs assumed to be equal to the OG with the highest post accident load; DG fuel consumption rates are assumed to be equal to the highest consumption rate observed for any of the OGs: and. assumptions about fuel oil specific gravity included using the highest heat value fuel during observations of fuel consumption rates (lowest fuel consumption) and lowest heat value fuel during accident conditions (highest consumption). Therefore, minimum day tank volumes based on 45 minutes of DG operation at the post accident load does not have a significant impact on safety. HN A P F AT N 8 T~aok L,. l4 '? <<'t ~ The Bases of the SSES CTS for this Specification have been replace y Bases that reflect the format and applicable content of SSES ITS 3.8.1 consistent with the BMR STS. NUREG-1433. Rev. 1. SUSQUEHANNA UNIT 1 ANO 2 23 Revision 0. 07/31/go crating 8 3.8.1 BASES SURVEILLANCE n snue REQUIREMENTS a Perfo nce of th S will not rend any safety system or c onent in e le; 6 b. rformance of the el in a ch 1 safet s t ge f cal tems; and e SR to steady will no distribut n cause perturbations systems that codld ate operation orito plant to any result r c P f ance of the, or failure of+he SR, will no + e, or resul n, an A00 with atiindant challen to ant safet s stems. In the event of a DBA coincident with a loss of offsite power, the OGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded. This Surveillance demonstrates DG operation, as discussed in the Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal in conjunction with an ECCS initiation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the OG system to perform these functions is acceptable. ~ This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified. The Frequency of months'akes into consideration plant conditions required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length. This SR is modified by two Notes. The reason for Note 1 is to inimize wear and tear on the DGs during testing. For the rpose of this testing, the 06s must be started from tandby conditions, that is, with the engine coolant and oil Qq,o (gL being continuously circulated and temperature maintained consistent with manufacturer recomnendations. e reas or oe a p orm>n e ur e> an e woul remov a re ui d of ice ertur the el ctriAl (continued) BMR/4 STS B 3.8-31 Rev 1, 04/07/95 lNSKRT B3-8-3SI TABLK B S.a. I-I (Page I 43f 2) UN!T l AND LINIT2 LOAD TlNKRS SERVING NOMINAL DEVICE ALLOWABLEVALUE TAG NO. SYSIEM LOADINGTIMER LOCATION (SCCoads) (stean(IS) 62A 23102 RHR  ?"-p 420 4.d c h.5 62A-20202 RHR P(' 3 4 2>>t an" s 3.6 62A-20302 RliR ?" p 1 03 a 2. ~ ana c 3.o 62A-20C02 RHR Pv p MCC 4 2. ano s 3.o 62A-20102 AHR P' 'p 2A 2A20 4 2 ~ 4nd s 3~6 62A 20 02 RHR P" p 23 <2 4 2. and c 3.6 62A 20302 RHR P('=p 2C 2A2"h 4.. c 3~5 62A-20C02 AHR Pr=p 20 2A2CC 4 2. ~ a..d s 3.c E h& K2028 RHil ?u p <<(0 5 ~ Pave 'ne ( '-"615 4 6. ~ an s 9. El> K120A RHR ?unp 1C (Of feist POve ". =. ~ -; 1C6 6' 4n>> s 9 ~ ~ 1~ K12C3 R.'iR Mp '>> (Of si ~ Pavt '  ! 614 44. a..dc 9. K2>>"2A R.'(R ?unp D (0 faire ?over . = ~ r> <<06',  ?.5 4 6 41d s E 1A i('20A RHR Punp 2 (0$ S'tt POver . der! ~ < 4 6 ' and c ,1 31Uri(2" 23 RHR Pudp 2" (0 <<s te Paver . =er. 2C615 7.0 4 C.S and c K KA K<<203 RHR PudP 20 (0 feist Paver -. =, ~ = 5 9 4 4.S 41C c i(2 02A RHR ? -p 20 :Offs te Paver t'=er ""6 I~< 4 4 4-" s 321A K 6A "$ Pu=p ~ :0525 4 9 ' ana c ~ . S Punp 13 61 0.5 49 ~ C4..>> c .c E21A K'2SA CS P" P h "c26 <<0 ~ S 4 9.C ar>> s . 821A K12S3 S ?un'p '"5 'Q.S 9,C ard c ~ 4 K21A K 16A CS P-p2A 20625 9~C 41d c ~ . Kh&-Klh63 CS  ?~ 23 ohh 10 ~ 5 4 9.4 and c .... K21A K<<25A CS ?'unp 2C 62o '>>.S 4 9.4 ar.d c '... K21A K12SS CS?( p 2D 20527 494 andc.'..: K2hJE-K16A CS PLL p 1A (Cf Site Pave i ~ i '0526 4 14.0 and c .4 E21A K168 CS ?u=p 18 (Of fs'e Pave . =tr: 52 '5 E>>1A i(25A CS P" pl'" (0 si 4 Pave i.t 1C525 I5 1C 0 4 d s 821A K253 CS?ep (0 fsitt Pover Ki=tr: 52 ~ 5 ~C ~ 0 4r s c E21A K'6A cs ?~p 2 (offsite Pover T =er 2"626 4 14.0 ana s lc 321A-3' CS ?udp 23 (Of!4'tt ?ovt .'~tr. 5 4 C,v 4 o c 321A K2 A CS Pu-p 2" (0 S te Pavtr .'-tr. 0 0 14 ~ 0 41 s ~ E21A K253 CS ? p 2D (Of s te Pover r'ner 52 4 14>>0 a..c c .4 62AX2 20109 Knerqercy Service i(ster CO 4 36 a1c c ~ ~ 62AX2 0208 K=erqercy Strv'ce Mater C>> 4 36 a c c 4~ 62AX 203<3 E trqtncy St vice Mate CC a 39.6 ana c Cc ~ 62AX2 20C03 ~o 4 qerCy SerViCt Hater A C 4 C3.2 ara s .'. 62X3 2040C Control Struc c ~ Chilled Ha t 5 4 SC S stex 62X3-20 04 Control $ tructure Cn'lied Hater 60 4 54 S stt(c 62X 20104 E-.erqercy svitch((ta Rn Coal ~ ." A ~ 6>>h 4 SC RHR SM Pano HCV'ran A 62X-2020C Enerqenay SvitCnqear R CaO'er 5 . 6v RHA SM K~o HCV ..an 8 62X-S65 DG Roon Exhaust rar. E3 00 4 SC 62X S 52A DG Roan Exha sts ran Ei ~ ~ ~ 4 Si 262X-20204 Ecerqency Svita:qear Rc Coal ~: 120 4 5~ 262K 0104 E(cerqency svitaqear (us Coo'er << 12 4 SC 62X 4 DG Rn Exh ian 0 <<3 4 SC DG Rn Exn ran '2< cC 62K 5 6 62X-526 DG R(c Exh rar. 3 2< 4 SC e INSKRT B3.8 33%1 TABLK B 3.$ .I-1 (page 2 of 2) UNIT I AND UNIT 2 LOAD TIMKRS NOMINAL DEVICE SEITING ALLOWABLEVALUE TAG NO. SYSIKH LOADINGTIMER LOCATION {seconds) {seconds) 62X-e16 30 8n Exh Pan A 035'6 2\ a 54 CRX 56 2A 00 Roon Supply Sans El and El ~ 03565 20 a SC 62X2 20410 control structure cnalled water 0CS 763 ec Svste 62X -2030C Ccr;.Oo'tructure Cn 'ed water 0CSO A ec a SC Svsten 62X1 20310 control strucrure cned ware QCSOSA 180 Svsten 62X'0404 con ol st actu ~ cnl'd wa ~ 0 5 130 a SC Sv5te-62X2 2030C co.. ro s uc " e cni lec wats 0085 7A 21" a 54 Svsten X2 2CCSC ccntro'r,= c: ." ~ cnled ware: 003~13 210 a SC S ste 2X 81133 aercenuy SwatC00ear 8" Conlrn; 203253e Ci a 54 Co"~ressor 8 62X-8 'A Ene penny Swltchsear nn CO nj 303250A 260 a 5C Conoressor A R+C- n.a X. S.a.i<n DISCUSSION OF CHANGES J. 'l. l~~ ITS: SECTION 3.8.1 - AC SOURCES OPERATING T HN CA HANG S - S R STR CT V (continued) license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on safety. SSES CTS 4.8.1.1.2.d.2 and 4.8. 1.1.3.d.2 require that each DG maintaining the specified voltage and frequency when rejecting a load of greater than or equal to 1425 kW. SSES ITS SR 3.8.1.8 requires that each DG meet specified acceptance criteria when rejecting a load greater than or equal to its associated single largest post-accident load. The description nd the size of the largest single load will be maintained in the ases or ~<r~ hF, ~g This change is acceptable because the requirement t a+ SR 3.8.1.8. ~ ~ erform a load rejection test 'with a load equivalent to the ~ argest single load is maintained in Technical Specifications. '-pl< >oQ The descri p.tions and size of the largest single load will be maintained in the Bases which require change control in accordance with the SSES ITS 5.5.10, Bases Control Program. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirements. NRC and PP8L resources associated with processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on safety. SSES CTS 4.8. 1.1.2.d.12 requires verifying that each diesel generator loading sequence timer listed in Table 4.8.1.1.2-2 is xi o.oo4l C< operable with its setpoint within 10K of its design setpoint. ~o k4 e xcept for the RHR pump timers wh'ich may ha e a tolerance of 20K. -10K. SSES ITS SR 3.8. 1.17 requires verifying the interval +~ ~gag MLQ etween each sequenced load block is within + 10K of design i'>+4'cJ +4 nterval for each load timer except that the RHR pump timers must St%~,k e within +20K and -10X of the design interval. The list of hw) yF li ndividual load timers and the allowable value for each load timer 4s,~) 4O s relocated to the Bases for SSES ITS LCO 3.8.1. Removing this coasl~gk~t wa+ nformation from Technical Specifications is consistent with the aO~aC.(, is>y MR STS NUREG-1 This change is acceptable because the Q4ga>i4 + I&45~ equirement to test the setpoint and tolerance for the individual g4r)g A4s 1 oad timers is maintained in the Technical Specifications. The ~4 tCWO m 1 ist of load timers and the allowable values will be maintained in c4~)i 4 +c he Bases which require change control in accordance with the SSES I ~ $ 1~ tci&~ TS 5.5.10. Bases Control Program This approach provides an te tea~ra i spagC~ ffective level of regulatory control and provides for a more ppropriate change control proc O ss. The level of sa fet y of is no facility operation is unaffected oy the change Furthermore. because there to perform the NRC and change in the requirement SR. PPBL resources associated witn processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive a~inistrative change with no impact on safety. SUSQUEHANNA UNIT 1 AND 2 13 Revision 0, 07/31/96 ~c,c, aha g.g l DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING TE HN CAL CHANG - S R TRICTIV (continued) there is no change in the requirement to perform testing. Furthermore. NRC and PP8L resources associated with processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on safety. Note that requirements for accelerated testing associated with some SRs are eliminated based on justifications provided in discussions of changes L.6 for ITS 3.8.1 and LE 2 for ITS 3.8.3 for the following tests: CTS 4.8.1.1.2.a.l. 4.8.1.1 2.a.2, and ~ 4.8.1.1.2.a.1.3 and CTS 4.8.1.1.3.a.l. 4.8.1.1.3.a.2, and 4.8 1.1.3.a.1.3. Therefore, the TRH will not include these in the ~ scope of tests subjected to accelerated testing. LA.2 SSES CTS 4.8.1.1.2.a.6 requires periodic verification that the diesel generators are aligned to provide standby power to the associated emergency busses. SSES ITS 3.8.1 does not provide a specific SR to perform this verification because this is an integral part of the Operability of the DGs as defined in the Bases for SSES ITS 3.8.1. Procedural controls on DG standby alignment and the definition of Operability in the Bases are sufficient to ensure the DG remains aligned to provide standby power. The Bases require change control in accordance with the SSES ITS 5.5.10, Bases Control Program. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there isNRCno change in the requirement to have DGs Operable. Furthermore. and PPSL resources associated with processing license amendments to these Administrative Control requirements will be reduced. ~eec ~ This change is a less restrictive administrative change with no s'~> ,q impact on safety. + LA.3 s . SES CTS 4.8.1.1.2.d.l and 4.8. 1.1.3.d. 1 require subjecting each << W, > diesel to an inspection every 18 months in accordance with p rocedures p. re p ared in con unction with its manufacturer's recossaendations for this ciass of standby service. This requirement is not included in the BWR STS, NUREG-1433, and is moved to the Technical Requirements Hanual (TRH). This change is acceptable because performance of the tests described in ~at betgsaoS ~ Regulatory Guide 1.9, Rev 3. are sufficient to demonstrate the Operability of the DGs. This inspection is part of the routine a l~~ >>ts zr bo reventative maintenance and is not a direct demonstration that a SSQ is ca able of erforming its intended safety function. The 4, requiremen o per orm accordance ith procedures prepared in ccfigJnction with its manufacturer's comendations will be maintained in the TRH. The level of dr safety of facility operation is unaffected by the change, because <sat there is no change in the requir~nt to maintain DG Operability. associated with processing C Furthermore. and PPIEL resources ~ NRC a ~ le~a~ r~r IT 1 ~ ~ og 2 Revision 0; 07/31/96 SUSQU Qi 3/4. 8 ELECTRICAL POSER SYSTEHS 3/4.8. 1 A.C. SOURCES A. C. SOURCES . OPERATTNC LIHTTTNG CONOITTON FOR OPERATION As a minfmum, the folio<<ing A.C. electrical pa<<er sources LCb 3.S.l OPERASLE: sna sn ll be b T<<o physica n ebendent circuits bet<<een the offsite ass lE distribution system, and transmissian ~ net<<or and the ons te lf. F our of the five sa arete and independen ~diesel generators~, LA.i ~r Se arate engfne mounted day fuel tanks contafning of fuel, a minfmum of gR 8.8,>.9 A s arete fuel storage system contafning a mfnimum of 8 R s.'E.E. l ,57 gallons. of fuel far dfesel generator A, 8, C and 0; and 0 48 gallons Qr diesel generator E, and QQ 3.5.l.l M A separate fuel transfer pump. tfi APPLICASILITY: OPERATIONAL CONDITIONS 1, 2, and 3. n~ <co ~.~.~, ~p.i< A(4L LQO 3.K3 A~ R ~ D ~~~ ~~ 633cg fifth one offsfte cfrcuit of the above 3.8.1.1.a required A.C. po<<er sources fnoperable: Q. Rd. A.l Perform Survefllance Requirement 4.8.l.l.l.a <<ithfn ane hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and

2. For each f the ~ OPKRASLE. aWgned

/ esel gener rs: rffy Su b a. succeisf Perfo s efllance ly perfo Survef 1 lane tfally on h Re frequent 4..1.1.2.a.4 <<ithin th last 24 ha s, or seouf reme diesel 4.8.1.1.2..4 nerator <<fth n 24 as bee Q ~ g h urs, and <<fth.llilff'nOPERAILE dfesel j hared far a generator may be removed from ptrf04 Of efgiit pyure <<hen aligning di~Sel generatar E tO the C1aSS 1E g dfstrfbut5on system. If alfgnmeht of diesel generatar E service Tetid <<fthin n e gan, fth the <<e ei t" houii, tfe approprfate ACTION <<f)l be (olla<<ed. caption the i tfal perf ~ sp ff ident of di ~ 1 generator nce of Su efllance me ts equi ament 4..l.l.a.- The tf li~ ft for 8.l.l.l.a 11 be meas ed i'ram Cl the etermfna on that fesel g arator E an e operable transfo E r, na y o only th <<o diesel transforme are. requir ~ o

1) not ar c

~ c rcu> erators a cfated << to be tes not he alf ed s inoper the ity o SUSQUEHANNA UNIT l 3/4 8 1 Ame~nt No. 103 4 ' a4M. e.lz 'S.t. l ebb 3.8. t 3.$ t (raa. boo. S.a,t aa M ~.rJ) 3 E.> Ot. Me The fief tranafac putnp starts an4 cQsfers fidel the storage system to 8P 3.8.1 0 the engueeeamad day hei tank. L.4 The dieael manuaGy stana hen A.a SR 3.8.1> .IO '~la trequmcy are start signaL Ha whhin H.] a@a ~3'he 5.~ The dieael gmemc to 3R 3.5.1,5 Kw an4 operate hc lead 60 minutea. A: 'lhe pcasare ht the di air be greater or 8k s.e.s.9 ~ qual to 240 ps . 3I ~3~ At least once (LL) 'ed 31 ~ 0 e 0 SR 8.8.I 3.II'.3 5'8 accunatiated a Iwt mme from th>> 4ay fuel tanks. per 92 days and!totn new hei oif R for and rattevittg m storage tanks that a sample obtained in accordance with ASTMCCTO 1975 haa a. s R. 3.t.s.s'erifying n to the . ~be.z , Agg ssBS wea and sedimeN colea of Iaa than oc equal m . vohtme an4 a H.3 hnenmic viscoalty 4 40'C of greater than oc equal m 3 a~i'~a I 7'5 4.5.~ or 1.9 but 4.1 fhc 2D oil when teated in accordance with ASTM-D975-77, and an ittqturity level ot laa than 2 mg of insoiublea per 100 mL when teated h accordance with ASTM-P2274;70. DÃ Verifying a least once per moaha lf SpecÃcatioa 4.g.f.ldA haa aa bean perform atL 2w LG. i 1 prepared n L~S 8R S.S'. l.'t il'o 'ect a load of The dieael than or to M~i AS while maintaining voltage voha an4 frequency a 60 McRc,2 ~ 3 The diesel ganaators capability to reject a load of gtaatac than or equal to MAc5 Aq 4ON Itw without tripping. The grocrator vo ex 4560 vota during tai ecnon pa. gg,g.g 1 I The dieaef gamatoc opera for at least 24 bouts the first 2 ~ [ baal el Ibla tw. 4aa 4taaat aaoaaooa aball be loa444 eetoaea baa ao4 during the rtanatnmg 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this teat. the diesel generator shall be Qkoo 4 ZE 3.F.I.q. tie%, t 4f VOO Sit. 3.tr, t.to aJeZa,b

a. t. 4.4 gR S.f.l.9. wW<

-¹¹0 j Theae tata may be conducted utiiiting the ~ hcday. 5R 3.g. <.t'I, a~ load ia maaN m guidance to avoaf maua overloading of dieaef generators [Momentaty tratsianta outside the loaf ange w4 ax utvalidate the tat. KNeael gcnaraac loading may be preceded by a mama's period in accordance with vendor aa SUSQUBfANNA - UNlT 1 3/4 $ 4a Amaadmea Ho. 107 ~c +hg $ $ ( 73 DISCUSSION OF CHANGES ITS: SECTION 3.8.1 - AC SOURCES OPERATING (continued) a change to the units of measurement and there is no change to the acceptance criteria. A.8 SSES CTS 4.8.1.1.2.d.8. the DG hot restart test, specifies that the hot restart be accomplished by performing SSES CTS This etc ~~ 4.8.1 1.2.a.4. the loss of offsite power test. SSES ITS SR i j ace+)4>> L'c, ~ 3.8.1.15, the ITS DG hot restart test. does not specify how the DG 4 ca ~g>>ll must be started to accomplish the hot restart test. The stipulation that the hot restart test must be initiated by loss of $ 4~ ),$ ~>>, ( , offsite voltage test is deleted because the method used to start the OG is not the attribute being tested by the hot restart test ~all C.~hvar(, (Regulatory Guide 1.9. Rev 3. Section 2.2.10. allows the OG to use I Qri~ Aa*~ either a manual or automatic start). This is an administrative Dao A fuel storage system contafnfng a efnfmm of 4,570 gallons of $g g ) fwl for dfesels A, b, C, and 0 and 60 480 aliens for dfesel generator E. Lc,o .g.S, SR 3 R.I.L, W A fuel transfer APPLICAbILITYr OPERATIONAL COreITIONS 4 p~. 5 and ctc4t. LCCr $ .g.3, kE s)crf 5 A~ FrcLi~ A.C. latm. . Rdk- A Nth less than .r1~ Ar ove requ red A.C. electrfcal pcnrer sources OPENAbLE, suspend CORE ALTENATIOrrS, handlfng of frradfat>>d fwl fn the secondary contafrment, ooeratfons Hth a potentfa1 ]~a.a for drafnf the reactor vessel so 0 ue a ~s a ane op ons n Qp, on, n th the wter lave less than 22 feet v r s v 1n t ate y n ate correctfve act on to restore the reqofred pear sources to OPERAbLE status as soon as practfcal. The provfsfons of Specf ffcatfon 3.0.3 are not applfcable. SURVEILLN5CE RE IREffBITS Lt deeonstrated At least the above requfred A.C. OPENAbLE 51'1 s ~ lectrfcal pcnrer sources a $ 111 .. shall and 1rhen frradfated fuel fs bef hand1 fn econda contafrmnt and R L TIDE~ ope ons ~ tfa dr ng re SUSOUEHANA NfIT 1 ~n~ne a. SZ OISCUSS ION OF CHANGES O.h Z 3. g.g-(p ITS: 3.8.2 - AC SOURCES SHUTOQW T CHN A CHANG - HOR RE TR T V (Unit 2 Only) SSES CTS 3.8.2.1 requires Operability of two diesel generators and one offsite circuit to support the Unit's Class lE distribution system while shutdown. SSES ITS 3.8.1 retains these requirements and, for Unit 2, adds a specific requirement for a qualified circuit between the offsite transmission network and the DG{s) needed to support the Unit 1 onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Oistribution Systems-Shutdown. This change is necessary because (Qadi~ I a~ some e ui ment ceded to meet Unit 2 accident analysis is powered om t e nit 1 AC Electrical Power System. Currently. SSES CTS CclM&04 tcl\J) 3.8.3.2 for Unit 2 recognizes this requirement by requiring Operabi lity of those Unit 1 busses that support equipment required in the Unit 2 accident analysis. However. Unit 2 SSES CTS establishes requirements for the Unit 1 AC sources only to the extent that the definition of Operability requires the normal ard emergency power sources of the Unit 1 equipment to be Operable. Therefore, for completeness'he Unit 1 AC sources required to Z+ c~~ support Unit 2 have been added to SSES ITS 3.8.2. This is a more su g>> p c ~ hL a.t. restrictive change because specifying explicit allowed out of c cid t<ea 4- > service times and Surveillance requirements for the Unit 1 AC au~a inc>>i sources make this an additional restriction on plant operations. SSES ITS SR 3.8.2.2 has been added to ensure that the Unit 1 AC speci& c.~ '4~ sources are properly tested and that the appropriate SRs are Per u>><4 I ~d applicable for each units AC sources. These requirements are ro: l~~s being added to the Unit 1 SSES ITS because there is no AC Lc. SL 1c S+C'aC*+< equipment required by the Unit 1 accident analysis that is power haec,m fr m the Unit 2 AC Sources. This more restrictive change is w~ oN.Wa~~l accep a e ecause i not introduce any operation which is ~f 4A C<r~CL, + C unanalyzed while establishing more complete requirements for AC yq 4P+gPS sources than ' currently required. Therefore. this change has no e ative ~o s.ei. Stop ac.b~a&c). ~> 0 ~+>y QiCM + oC c, gg yo 0 + ILL C44lv LS 0& ISO %Ct( s4 my', 4cS %4~~4~ c n inopera requirement to initiate corrective action to restore the required power sources to OPERABLE status as soon as practical " when in OPERATIONAL CONOITION 5 with the water level less than.22 feet above the reactor pressure vessel flange." SSES ITS 3.8.2. Required Actions A.2.4 and 8.4. are more conservative and require immediate initiation of action to restore required AC Source to Operable regardless of the Node and regardless of the water leve'n the reactor cavity. This rere restrictive change is acceptac'.e because it does not introduce any operation which is unanalyzed reouirina a more rnncorvwrivo rc cnnnz~ than ic rior re ntlv while WR.c f,g+ g,g g Diesel Fuel Oil. Lube 011, and Startl'ng'Air 3.8.3 3.8 ELECTRICAL POWER SYSTBlS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 The stored diesel fuel oil, lube oil. and starting air subsystem shall be within limits for each required diesel generator (DG). APPLICABILITY: When. associated DG is required to be OPERABLE. ACTIONS -NOTE-Separate Condition entry is allowed for each DG. CONDITION REQUIRED ACTION COHPLETION TINE A. One or more DGs with A.l Restore fuel oil 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> fuel oil level. in level to within associated storage limits tank ( 44.900 gallons and .> 38.600 gallons. B. One or more DGs with 8.1 Declare associated DG Imediately lube oil sump level inoperable. not visible in the sight glass. C. One or more DGs with C.l Restore stored fuel 7 days stored fuel oil total oil total particulates not particulates to within limits e4-SR witnin limits ef- .3. (continued) SUSQUEHANNA - UNIT 1 3.8-21 Amendment A. 07/31/96 gA i 3i; i@AX Diesel Fuel Oil. Lube Oil. and Starting Air 3.8.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. One or more DGs with D. 1 Restore stored fuel 30 days oil properties to S~~ ~ new fuel oil roperties not within within limits e t 4 E. One or more DGs with E.1 Restore starting air 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> one or both starting receiver pressure to air receiver pressures within limits of < 240 psig and SR 3.8.3.4. a 180 psig. F. Required Action and F. 1 Declare associated DG Inmediately associated Completion inoperable. Time of Condition A. B. C. D or E not met. One or more DGs with diesel fuel oil. lube oil. or startin ai C ~bag sw~ not within imits for reasons other than Condition A. B. C. D or E. - UNIT 3.8-22 Amendment A. 07/31/96 SUSQUEHANNA 1 tu n.c ~ ~-oq DISCUSSION OF CHANGES ITS: 3.8.3 - DIESEL FUEL OIL, LUBE OIL, and STARTING AIR T HN A HAN - R TR CT V (continued) . prevent DG operation in the short run. Additionally. DG + "~ ~ %halo~ rior 8perability is demonstrated every 31 days and changes in fuel oil operties are not expected to affect Operability during this riod. Action D allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore startin g air p r essure to declaring the DG inoperable provided capacity. for at %$ loc<E~ Mid east one start attempt remains . Action E is provided to declare ~ '<<M allow ~ the DG ino erable if revious Actions are not met t ese c anges ave no sign>>cant impact on sa ety. Therefore. L.2 The Surveillance Frequencies for SSES CTS 4.8.1.1.2.a.2 and 4.8.1.1.3.a.2 (verifying level in the DG fuel oil storage tank) and 4.8.1.1.2.a (verifying air receiver pressure) are currently governed by SSES CTS Table 4.8.1.1.2-1; therefore, the test frequencies are subject to accelerated testing based on failure rate of DG start tests. SSES ITS SR 3.8.3. 1 and SR 3.8.3.4, respectively. separate the required frequency for these tests from accelerated testing based on DG start failures because DG start failures are not indicators of an inability to maintain level in the storage tank or maintain adequate air receiver pressure. If either of these parameters causes a DG start failure. the problem can be verified to be corrected without the need for more frequent testing. Therefore, accelerated testing following failure of these particular feature does not result in accumulating experience demonstrating DG starting reliability has improved. This change has no impact on safety. L.3 SSES CTS 3.8. l. l.b.2 requires that each Operable DG have a separate fuel oil storage tank containing a minimum of 47,570 gallons of fuel for each DG A. B, C and D and 60.480 gallons of fuel for DG E. These volumes were calculated to ensure sufficien: fuel oil is available for each DG to operate for 7 days at the continuous rating. SSES ITS SR 3.8.3.1 requires that each Operable DG have a separate fuel oil storage tank containing a minimum of 44.900 gallons of fuel for each Operable DG with the same limit applicable to DG E. The values used in SSES ITS are calculated using the alternate method in Regulatory Guide 1. 137 and is designed to ensure a sufficient fuel oil is available for each DG to operate for 7 days at the maximum post accident load profile. This change is acceptable because use of the post accident load profile method for calculating minimum fuel oil nventory conforms to recommendations in RG 1.137. Specifically. Q45ctQc 8 he post accident load profile used assumes tha. the 60 minute 044,p coaabu+4J ost accident load is maintained for the full 7 days when actual ta.te. load will decline signi fican.ly: the DG post accident load for ccxsluua4~ < l~ a ll DGs is assumed to be equal :o the DG with the highest post 4g ccident load; DG fuel consurpticn rates are assumed to be equal o the highest cons tion ra:e observed for any of the DGs; and. Wci~c. grass Q + pro'.4c. +~ h teksg L(g. fu 04%~+ ~1 SUSQUEHANNA UNIT 1 AND 2 Revision 0, 07/31/96 Diese1 Fuel Oil. Lube Oil. and HRc, LAg Starting Air 1,P.g ~ B 3.8.3 B 3.8 ELECTRICAL POMER SYSTBlS 8 3.8.3 Diesel Fuel Oil. Lube Oil. and Starting Air BASES BACKGROUND Each diesel generator (OG) is provided with a storage tank having a fuel oil capacity sufficient to operate that OG for a period of 7 days while the DG is supplying maximum post loss of coolant accident (LOCA) load demand discussed in FSAR. Section 9.5.4 (Ref. 1). The maximum load demand is calculated using the assumption that at least three OGs are available. This onsite fuel oil capacity is sufficient to operate the DGs for longer than the time to replenish the onsite supply from outside sources. Fuel oil is transferred from storage tank to day tank by a transfer pump associated with each storage tank. Independent pumps and piping preclude the failure of one 4~ ~4eg pump. or the rupture of any pipe. valve, or tank to result CLM ~a ~~ in the loss of more than one OG. All outside tanks, pumps. Co~le.~ and piping are located underground. J ~+,+> pig eogg (C'>sag <tw <t. g~ cQ or proper operation of the standby OGs. it is necessary to ensure the proper quality of the fuel oil. Regulatory l."a Wee, Guide 1.137 (Ref. 2) addresses the recommended fuel oil Lr Pvr practices as supplemented by ANSI N195 (Ref. 3). The fuel q Lc.vd oil n . ese SRs ar peci e in eci cation+.5.9, iesel p i stin ro r The DG lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated OG under all loading conditions. The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation. Each engine oil sump contains an inventory capable of supporting a minimum of 7 days of operation. This supply is sufficient to allo~ the operator to replenish lube oil from outside sources. Cot, Z lo ~ ) ~ oe Each DG has an air start system with two air receivers ea of which provide adequate capacity for five successive start cycles on the OG without recharging the air start receivers. (continued) SUSQUEHANNA - UNIT 1 '8 3.8-42 Amendment ~~6 /.I aViii leg H~ KAQ g p,.3 Diesel Fuel Oil, Lube Oil. and Starting Air 8 3.8.3 BASES SURVEILLANCE R .3. REQUIREMENTS (continued) This Surveillance ensures that sufficient lubricating oil inventory is available to support at least 7 days of full load operation for each DG. The sump level requi rement is based on the DG manufacturer's consumption values. The acceptance criteria of maintaining a visible level in the sight glass ensures adequate inventory for 7 days of full load operation without the level reaching the manufacturer's recommended minimum level. A 31 day Frequency is adequate to ensure that a sufi'icient lube oil supply is onsite. since,DG starts and run time are closely monitored by the olant staff. R . 3 ropertie of new an stored fuel oil are veri fied to be g~ge l- within t e limits s eci fied in Specification 5.5.9. "Diesel 6 5.P-~1-0t Fuel Oi Testing P ogram." Tech cal requirem ts for diesel fuel 1 testing re specified n reference Spe fication .5.9 and ref ence 7 samp 'ng requir nts, t ting requ ements. and cceptance cr eria verif each of the followi g: acceptabi ty of key p perties of ew fuel oil for u prior to a ition to st age tanks: acceptab ity of, other properties new fuel 1 within 31 day following a ition to st age tanks: d. the acceptability of s red fuel oi every 31 d s. ~ a Normally, maint ning store uel within he speci ed limits. trendl,ng of stor='w uel oil sa e resul . and analysis of samples o'. n fuel oil ior to a ition to e storage tank allows suf-ic>>nt time to corre fuel oil ro erties prior to - ac"."a the limit of ceptabi lity. Failure to meet any = ".- 'imits for key properties of re fuel oil prior to aC"" =" to the storage tank is cause fc~ ~ rejecting the new fu=-':i'. "ut does not represent a fai1u e to meet the LCO conc r" s "ce the fuel oil is not added to the storage tanks. Within 31 days follmi"g :".e initial new fuel oil sample. the fuel oil is ana':y . > =: establish that the other properties specifi d  ;"eci fication 5.5.9 and Reference (continued) Al opal i /< - UNIT 1 8 3.8-'7 Amendment, 7Ti~r36 'USQUEHANNA INSERT B3.8-47-1: The tests listed below are a means of determining whether new fuel oil is of the appropriate grade and has not been contanunated with substances that would have an immediate detrimental impact on diesel engine combustion. Ifresults from these tests are within acceptable limits, the fuel oil may be added to the storage tanks without concern for contaminating the entire volume of Rel oil in the storage tanks. These tests are to be conducted prior to adding the new fuel to the storage tank(s),

a. Sample the new fuel oil

b. Verify

'TM but in no case is the time between receipt of new fuel and conducting the tests to exceed 31 days. The tests, limi llaai 15'C d a plicable ASTM Standards are as follows: W quC a ~ ie> D4057-88 (Ref. 7); the tests specified in ASTM D975-93 (Ref. 7) that the sample has a density at of a 0.816 kg/L and c 0.876 kg/L or an API gravity of z 30'nd c 42', a kinematic viscosity at 40'C of a 1.9 centistokes and c 4.1 centistokes, and a Gash point of ~ 52'C; and

c. Verify that the new Rel Water and sediment when tested (Ref.7).

'STM oil has a clear and bright appearance when tested

• • (4 1 77, 9 94DA( '979(D477991 D179643 (1990)

pogac. gl,g Diesel Fuel Oil. Lube Qil, and Starting Air 8 3.8.3 BASES SURVEILLANCE REQUIREMENTS are met ) )), f) for new fuel oil. The 31 day period is acceptable because the fuel oil properties of interest, even if they were not within stated limits. would not have an immediate effect on OG operation. This Surveillance ensures the availability of high quality fuel oil for the OGs. Fuel oil degradation during long term storage shows up as an increase in particulate, mostly due to oxidation. The presence of particulate does not mean'hat the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment. however. which can cause engine failure. z~~ >,I Atra~i g "'<<<cc oW conc ld be determined ~ ce . It is r ) J.'articulate acceptable to obtain a ie sample for su sequent laboratory testing in lieu of field testing. The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals. R .8 4 This Surveillance ensur'es that. without the aid of the refill compressor. sufficient air start capacity for each .~ is available. The system design requirements provide for s Surveys minimum of five engine start cycles without recharging. The pressure specified in this SR is intended to reflect: ~ est value at which the five starts can be accomplishe4. So. + Q, 'L.8 8-3 e 31 day Frequency takes into account the capacity. capability. redundancy. and diversity of the AC sources z~u other indications available in the control room. including rhea ((i~c alarms. to alert the operator to below normal air start '~ ~odiP a J 4g ci pressure. O~ V~4Ch BOCA ~1~~c. 4c. Kc. SRRh ~~ioci~+J gr H icrobiolo g ical foulir'3 is a ma J or cause of fuel oil degradation. There vie ~~-..erous bacteria that can grow in c~t+r iL fuel oil and cause f:uli~g. but all must have a water t~ c, 4" ~< OG <~ Ca.*J ~~ Sop i 4~i~ eg rr~~,J (continuedl r SUSQUEHANNA - UNIT 1 8 3.8 ~8 ) ) Az, INSERTB3~1: Wi4~~ 4-w quid< ~c c I-when tested I ASTM D975- {Ref.7), except that the analysis for sulfur may be performed 'STM D1552-90 (Ref. 7), ASTM D2622-87 (Ref.7) or ASTM D4294-90 (Ref. 7). INSERT B3.8-48-2: ASTM D2276-89 (Ref.7), appropriately modified to increase the range to > 10 mg/I. This method Involves a gravimetric determination of total particulate concentration in the fuel oil. This limit is 10 mg/I. +~ Ram Oiesel Fuel Oil. Lube Oil. and Starting Air B 3.8.3 BASES SURVEILLANCE (continued) REQUIREMENTS environment in order to survive. Removal of water from the fuel storage tanks once every 31 days eliminates the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition. it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources. including condensation. ground water. rain water. contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies are established by Regulatory Guide 1.137 (Ref. 2). This SR is for preventive maintenance. The presence of water does not necessarily represent failure of this SR. provided the accumulated water is removed during performance of the Surveillance. REFERENCES 1. FSAR, Section 9.5.4.

2. Regulatory Guide 1. 137.

3. ANSI N195. 1976.

4. FSAR. Chapter 6.

5. FSAR, Chapter 15.

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

7; a e rement~anya. - UNIT 1 B 3.8-49 I t 8-.8t8tt98 SUSQUEHANNA p,~ nhc Is> INSERT B3.8~1: ASTM Standard: D4057-88; D975-93; D4176-91; D1552-90; D2622-87; D4294-90; and D2276-89. NRf. Rhg g,g.g <g OISCUSSION OF OEVIATIONS FROH NUREG 1433 ITS: SECTION 3.8.3 - OIESEL FUEL OIL. LUBE OIL. ANO STARTING AIR PAT P F HAN P.1 This change is needed to ensure that SSES Improved Technical Specifications account for the SSES design and/or that the SSES design is accurately and completely described in the Bases. Therefore, this change is not a significant or generic deviation from NUREG 1433. Editorial changes and additional design detail are incorporated as necessary to more precisely describe SSES current practice or design. This change provides additional detail and is intended to improve clarity and ensure the requirement is fully understood and consistently applied. There are no technical changes to requirements as specified in NUREG 1433. Revision 1: therefore. this change is not a significant or generic deviation from NUREG 1433. P.3 NUREG-1433. Revision 1. SR 3.8.3.6 is preventive maintenance and does not affect directly the Operability of a OG. Sediment in the tank or failure to perform this SR does not result in an inoperable OG or storage tank. Other preventive maintenance SRs have been relocated from the TS and allowed to be under licensee control (e.g.. diesel generator teardown inspection). In addition. another government agency provides regulations for the maintenance of below ground fuel oil tanks. This change is consistent with NUREG 1433. Rev. 1, Generic Change BMROG-10 (TSTF-02) which is currently being evaluated by the NRC. P.4 The ases for NUREG-1433. Revision 1. SR 3.S.3.3, includes specific det ls about which ASTH standards governing sampling of esel fuel oil. SSES ITS Bases for SR 3.B.3.3 afg.'esting establish uirements for sampling and testing of diesel fuel ol' refere cing Specif'icat'on 5.5.9. "Diesel Fuel Oil Testing Program" and the Techni l Requirements Hanual (TRH). This char:" is acc table because cceptance criteria for properties of new and s red fuel oil d the Frequency for performing these tests are aintained in T hnical Specifications Section 5.5.9. Tec nical requir nts for sampling and testing .of diesel fuel ol' the governi ASTH standards are moved from one licensee ntrolled doc nt, the Bases. to a different licensee, control> : ~ ocument. the . This change is needed because the Pa'ses for 3.8.3.3 and pecification 5.5.9 do not provide suffi ient detaila'~ for implem tation of tiN~ fuel oil testing program therefore. reouireme s and impler(enting Cetails must be es lished in tte TRA. Ad itionally, t;Ke control room operators o not need these details and technici'ans performing the work wyll use the TRH. Therefore. there is no need to Cuplicate requirements in the TS Bases. This change does not result in any changes to the requirements established in NI.BEG-1433. Revision 1. therefore. ,thiS change does not represent a significant deviation from..- 'WRtGJuu SUSQUEHANNA UNIT 1 AND 2 Revision 0, 07I3If 36 p.pq NUREG 1433 SR 3.8.3.3 specifies the requirements for Diesel Fuel Oil sampling and analysis and specifically states that the fuel oil is sampled and analyzed "in accordance with" the applicablc standard. SSES ITS SR 3.8.3.3 specifies the required sample, but states that fuel oil is sampled and analyzed "following the guidelines of" the applicable standards..This change is necessary because thc NRC accepted Diesel Fuel Oil standards arc out of date with current laboratory requirements and require numerous exceptions which prevent thc verbatim compliance with the requirements. The following provides some examples of the exceptions necessary:

1) Tests are written for other types of fuel and applied to DFO which creates problems. An example of this is the particulate test standard which is written for Aviation Fuel. This test rcquircs a 10 liter sample to be filtered and then weighed.

Because of the difference iri fuel oils, the filter paper is clogged long before a 10 liter sample can be poured through. Therefore, a smaller quality of fuel oi! must be used. This represents a deviation.

2) Some standards reference use of specific equipment which is some times out dated or not the preferred equipmcnt. For example:

A. Mercury Thermometers are required for some standards. Mercury must be treated as a controlled substance at the power plant. Over the past several ars other measuring devises besides mercury thermometers are availabtc years ~ which provide. the required accuracy and do not represent a threat to personnel or thc power plant. B. Solvents which are no longer allowed for industrial usc such as chromi; acid are specified by some standards. Some standards require the usc of out dated testing equipment which hai been replaced with automated testing equipment which will provide morc accurate results. This leads:o less accurate analysis and more unneces>>ri costs to the utility requiring contracted testing laboratories to use labor intensive testing techniques.

3) Some stan S tandards are conflicting ~iih uher standards or instrument manufactur~:i, recommendations. For example:

A. Analysis s tandards specie the uw of certain groups of solvents for c eaning while standards for bottle preparation specifies other soliivcnls. An exception is needed to bc i~ken for one of thc standards to resolve '..": conflict. B. B Analysissis sstandards specity the um of acid for cleaning some instrumcmi lc thcc Instrument wh'le ils m mend usc of acids. Manufacturer does not recommen Exceptions should be taken to preserve the warranty t on thee instrument. in Based on the above cited examples and the recognition that there are other exceptions that are required, PPL has determined that it is necessary to change the wording of the SSES lTS to identify that the guidelines of the specified standards are followed and not state that samples are taken and analyzed in accordance with the standards. The change to the NUREG 1433 wording is considered acceptable because the exceptions to the standards willbe stated in the Diesel Fuel Oil Testing Program and controlled under 10 CFR 50.59 hich epresents an equivalent level of regulatory control as the SSES ITS Bases without adding an unnecessary and potentially confusing level of detail to the SSES l S. T. Therefore, based on plant specific concerns with the implementation of the requirements of the specified standards, the proposed change is needed for the plant specific implementation of NUREG 1433 at SSES. J 0.4 IO haO.e. PAg Oiesel Fuel Oil. Lube Oil. and Start~ing Air~ 8 3.8.3 BASES SURVEILLANCE (continued) , ~ 6 ~ ~-'i~-( REQUIREMENTS are met for new fuel oil. The 31 day period is acceptable because the fuel oil properties of interest. even if they were not within stated limits, would not have an itiiiiediate effect on OG operation. This Surveillance ensures the availability of high quality fuel oil for the OGs. Fuel oil degradation during long term storage shows up as an increase in particulate. mostly due to oxidation. The presence of particulate does not mean that the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment, however. which can cause engine failure. Z~vr~

• (law( )

<> < eagg Particulate conc ld be determined ~ e . It is acceptable to obtain a ie sample for su sequent laboratory testing in lieu of field testing. The Frequency of this test takes into consideration fuel oil degradation trends that indicate that particulate concentration is unlikely to change significantly between Frequency intervals. This Surveillance ensures that. without the aid of the refill comoressor, sufficient air start capacity for each OG is available. The system design requirements provide for a minimum of five engine start cycles without recharging. The pressure specified in this SR is intended to retlect tl e est value at which the five starts can be accomplish 8~.8- e-e 31 day Freauency takes into account the capacity. caoability, redundancy. and diversity of the AC sources and other indications available in the control room. including Thc Svtvci ([a ~~ alarms, to alert the operator to below normal air start pressure. mo~ Ligt<4 s 4c. Microbiological foulirg is a major cause of fuel oil ~~Roc +J degradation. There are numerous bacteria that cari grow in 'Q. 'Pl I $ fculing. but all must have a water ~CC ~ pQi,)~ Ip fuel oil and cause s< *4 >M s4% t f cia (continued) a))+~ v pci~~, j. - UNIT 1 8 3.8.48 SUSQUEHANNA INSERT 83.8"48-3: (NRC RAI 3.8.3-09) 5or ca~.l gal'I c)g.l~ g) ++~LJLa 4.J MlLJ 4Q The af r start f ng system capacity I. each cranking cycle duration should be approximately 3 seconds

2. consist of two to three engine revolutions, or

3. afr start requirements per engine start provided by the engine manufacturer; whichever air start requirement fs larger.

litt. Ihg 2.Q.g. Diesel Fuel Oil. Lube Dil. and Startinq Air .3.8.3 SURVEILLANCE REQUIRB1ENTS SURVEILLANCE FREQUENCY SR 3.8.3. 1 Verify each fuel ofl storage tank contains 31 days ~ 44,900 gallons. SR 3.8.3.2 Verify lube oil sump level is visible in 31 days the sight glass. SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with. and maintained within the limits of, Fuel Dil the Diesel Fuel Dil Testing Program. Testing Program SR 3.8.3.4 Verify each DG air start receiver pressure 31 days is > 240 psig. SR 3.8.3.5 Check for and remove accumulated water from 31 days each fuel oil storage tank. hlal tt NO+ ~vat4A W hc. Mf ~ho~ 04, aL op~+ . Ail Dflirh'7 SUSQUEHNMA - UNIT 1 3. 8-23 I t A-.WAIAS- pg+C, gA~ i 8. i- ~ fail Oiesel Fuel Oil. Lube Oil, and Start~ing Air 1 3.8.3 BASES SURVEILLANCE d) REQUIREMENTS are met for new fuel oil. The 31 day period is acceptable because the fuel oil properties of interest. even if they were not within stated limits. would not have an imediate effect on OG operation. This Surveillance ensures the availability of high quality fuel oil for the OGs. Fuel oil degradation during long term storage shows up as an increase in particulate. mostly due to oxidation. The presence of particulate does not mean that the fuel oil will not burn properly in a diesel engine. The particulate can cause fouling of filters and fuel oil injection equipment. however, which can cause engine failure. Z~vr~

• tlow(~~ Particulate conc n ld be determined M Q> dL e>c,c 0% ce . It is acceptable to obtain a ie d sample for su sequen laboratory testing in lieu of field testing. The Frequency of this test takes into consideration fuel oil degradation tr ends that indicate that particulate concentration is unlikely to change signi ficantly between Frequency intervals.

This Surveillance ensures that. without the aid of theeach OG refill comressor. sufficient air start capacity for is available. The system design requirements provide for a minimum of five engine start cycles without recharging. The pressure specified in this SR is intended to reflect the est value at which the five star ts can be accomplish Qt 8- e-e 31 day Frequency takes into account the capacity. caoability, redundancy. and diversity of the AC sources and including other indications available in the control normal room, air start Thc Svtvcg i(~ alarms. to alert the cperator to below '~ ~oats'4 pressure. 4g a ic~ do ~q~~c- w c s g + 4c. Microbiol ical foulirg; i -ajorbacteria cause of fuel oil degradation. There ar~ ..-erous that can grow in fuel oil and cause fcu" cut all must have a water t~ )tat,t~ suk J 0~ sag i f c,*~ (continued) ') prrR J - 8 3.8.-'8 I I SUSQUEHANNA UNIT 1 A.z DISCUSSION OF CHANGES ITS: 3.8.3 - DIESEL FUEL OIL. LUBE OIL. and STARTING AIR R (continued) consumption). Additionally. although fuel oil in the storage tank for the fifth diesel generator is not assumed to be available. the fifth storage tank is normally filled and transfer capability between this fuel oil storage tank and each of the other tanks is demonstrated to function very frequently. Finally. SSES is located in an industrial area that is easily accessible; therefore. additional diesel fuel will be readily obtained in less than 7 days following an accident. Therefore. this change has no impact on safety. Nkc. kaz 3.g.g The Bases of the SSES CTS for this Specification have been replaced by Bases that reflect the format and applicable content of SSES ITS 3.8.3 consistent. with the BWR STS. NUREG-1433. Rev. l. Revision 0. 07/31/96 SUSQUEHNNA UN?T 1 NO 2 Insert NRC RAI 3.8.3-10: L.4 SSES CTS 4.8.1.1.2.a.7 and 4.8.1.1.3.a.7 require that diesel generator air start receivers to be greater than or equal to 240 psig when the associated DG is required to be Operable. SSES ITS SR 3.8.3.3 maintains tlte same requirement but incorporates a Note for the SR which states that when the associated DG is running the SR does not have to be met. This is necessary because during and after a DG start, before the standby air compressors can restore air pressure, the air receiver pressure will be reduced such that the SR is no longer met. During this period, even though the DG is running and the DG air starting system has performed its safety function, the DG is inoperable. The note provides an allowance for the DG to be considered Operable if the DG is running. This change is acceptable because once the DG is running the safety function of the DG air start system has been completed. Therefore, this less restrictive change will have no impact on safety. OC Sources -Operating 3.8.4 SURVEILLANCE REOUIREHENT FREQUENCY SR 3.8.4. er at ery ina vo e s 0 V on oa char A.f.2. l .o..xb ~ SR 3.8.4.2 ~ ~ ~ Veri f o vi corrosion at ttery 92 days ~tel,t,2.i.~.'A erm nals a onnectors. 3t- Sot Verify battery connection resistance /is 1.5E-4 ohm] for inter.-dell connection 'T s-[1.5E-4 ohm] for ier-rack connec. s, .-~f cy> 1.5E-4 ohm] for inter-tier connections, and s [1.5E-4 ohm) for termioaT connections 3.8.4.3 Verify battery cells, cell plates, and SR racks show no visual indication of physical lg 6 8 Z.l'> p( damage or abnormal deterioration. SR-)s-ct 3.8.4.4 Remove visible corrosion and verify battery months cell to cell and terminal connections are is gq.g Z (c<) coated with anti-cotrosion material. SR 3.8.4.5 V if batter o connection resistance or in er-ce connec ion is ~ months gcf.g p i c y> . E-4 o for inte~ack co ctions, In S: 1.5E- hm for jeer-tier nnectg$ fs, and c .5E-4 ohy]"for terstina) s.s~~ co ctions (continued) 3.8-25 ~n-c mz ~.a.>~~ DISCUSSION OF DEVIATIONS FROH NUREG 1433 ITS: SECTION 3.8.4 - OC SOURCES - OPERATING N N- RA K P ANT P F CHAN (continued) to steady state operation or to plant safety systems: and. performance of this SR. or failure of the SR. will not result in an Abnormal Operating Occurrence with attendant challenge to plant safety systems. P.9 NUREG-1433 'evision 1. LCO 3.8.4. SR 3.8.4.6 includes detailed acceptance criteria for the performance of the battery charger performance test. SSES ITS SR 3.8.4.6 was modified to match the presentation of acceptance criteria used in NUREG-1433. SR 3.8.4.7 (battery performance test) and will require verification that "each required battery charger supplies its associated batteries at the voltage and current adequate to supply. and maintain in OPERABLE status. the required emergency loads for the design duty cycle." Detailed acceptance criteria for the performance of the battery charger performance test were moved to the Bases of SR 3.8.4.6. This change was made to provide a presentation of acceptance criteria consistent with the presentation used for SR 3.8.4.7. This change does not result in any changes to the requirements established in NUREG-1433. Revision 1. therefore. this change does not represent a significant or generic deviation from NUREG 1433. HAN T N R G- 43 R V, >~s,a+ P. (O N RP RATED N R None 2 Revision 0. 07/31/96 SUSQUEHANNA UNIT 1 ANO INSERT {NRC RAI 3.SAN): p.10 NUREG 1433 SR 3.8.4.4 specifies that the connections are 'tciean and tight, and/. SSES ITS SR 3.8.4.4 does not inciude this requirement. This change ls being im Iemented consiste with the recommendations of IEEE 450 {1995). The change Is ing made conslste ng the requIre of IEEE 450 {1995), therefore this change does not represent a significant or generic deviation from NUREG 1433, but is made to refiect the design basis of SSES. Ter. E, wc'IR)l +i$4+~$ ~ (c h c c.h ~ II go+ ~ g I ctvctc mi, c, cggr gt~ Sue.k ~~.l i ~i ) c'4 co gg4 I c +Q ~It ape J COrrce.h c a~+,~ 'I 0 <O'Ior) vip or cl~w ig aC. ~AX.. 3 g 'r-ag ARt RA%. 3.8.(- ) o OC Sources-Operating B 3.8.4 BASES SURVEILLANCE (continued) REQUIREMENTS operations or at some other outage. with intervals between tests not to exceed 24 months. This SR is modified by a Note wh1ch allows the performance of a modified performance discharge test in lieu of a service test once per 60 months. ~ lu ~ aaZ i g.>>O e modified er ormance ischarge test is a simu ated duty ycle consi ing of just wo rates: the one minute rate published or the batt y or the lar st current load of the duty cyc , followed the test r employed f the perform ce test. b h of which elope the y cycle of the se ice test. ince the am re-hours r ved by a rated one nute disch ge represen a very sm portion o the bat ry capacit . the test r te can be nged to th for h performan test witho compromis g the resu s of the erformance scharge te . The ba ry termina voltage or the fied perfor ance disc ge test sho d remain bove the inimum bat ry termin voltage sp if1ed in the battery service test for the duration of t1 e ual to tha f the service Wmodified discharge test is a test of the battery capacity 'and its ability to provide a high rate.cycle). short duration load (usually the h1ghest rate of the duty Th1s w1ll c&en confirm the battery's ability to meet the critical period of the load duty cycle. in addition to determining 1ts percentage of rated capacity. Initial conditions for the modified performance discharge test should be ident1cal to those specified for a service test. 7<~g 1 f3 $ Q s8 A battery performance discharge test is adone test of constant normally 1n the as found curretit capacity of a battery, service. to detect any condition. after having Ceen in the acceptance test. change 1n the capacity Cetermined by battery The test 1s intended to cetermine overall degradation due to age ar d usage. discharge test is described A battery modified perfc~wce in the Bases for SR 3 8 4 'ither the battery performance SUSQUEHANNA - UNIT 1 B 3.F 58 d t~ (continued) l~ m o8 lNSERT (NRC RAl 3.8.~ The meed performance discharge test is a simulated duty cycle consisting of two differenttest period The Qrst test p riod Maoists of the rate published for the batt ry or the largest current load of the duty cycle, followed by a second test period which employs the test rate for the arge test, of which both test periods, jf necessary, envelope the duty cycle of the service test. Because the ampere-hours removed by the first time period of the test are accounted for in determining the battery capacity or in the case of a one minute test perio represent a very sm po on of the battery capacity, the test rate can be changed to that ior the small portion rf d'arge test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain vc tte ttermin the minimum b attery rminal voltage speci6ed in the battery. service test for the duration of time equal to that of the service test. orman test with a test period greater than one minute, the battery capacity Forthem odifi d pe rformance is calculated as follows: %capacity at 25'C (75 F) = P'7,](100)(1/K) where T, is the actual time of test to reach specified terminal voltage T> is the time of the Service Duty Cycle plus the calculated time of the performance '.cw to reach the speci6ed terminal voltage 'ate K Temperature Correction Factor from IEEE 450 The acity is calculated horn the temperature corrected time in accordancece wi with IEEE 450 'bl (1975), because it is not possi e to cone ct the discharge rate without impacting the Service Tc~ Loads. H4L kg& L%.'c-oq DISCUSSION OF CHANGES ITS: SECTION 3.8.4 - DC SOURCES OPERATING V (continued) L.5 SSES CTS 4.8.2.1.e/f requires that a performance test be performed ~ every 60 month and that the performance test can'e performed in lieu of the service test. In SSES ITS SR 3.8.4.8 an allowance to perform a modified performance discharge test in 'lieu of a performance discharge test has been added. The'modified performance dischar e test is a simulated duty cycle consfstin of ~ w mnu e er or the largest rrent load of t duty cycle. ollowed by t test rate f r the erfo nce tes S ce the amper hours removed by a rat msnu e isc arge rep sent a very ma11 portfon the battery cap city. the tes rate can be hang to that fo the performance est without c r resu s of he e ormance dischar test. ince e modified per ormance tes oun s ormance st and the service test. SSES ITS SR 3.8.4.7 Note 1 has been added to allow the modified performance test to be performed in place of the service test. This less restrictive test provides a performance option with no impact on safety since the modified performance test bounds the requirements of the service test and the performance test. T N AT N The Bases of the SSES CTS for this Specification have been replaced by Bases that reflect the format and applicable content of SSES ITS 3.8.4 consistent with the BMR STS. NUREG-1433. Rev. 1. ND 2 Revision 0. 07/31/g5 SUSQUEHNNA UNIT 1 INSERT NRC RAI 3.8.4.08: o f two different test periods, The first test period consists of the rate published for the battery or the largest current load of the duty cycle, followed by a second test period which employs the test rate for the performance discharge test, of which both test periods, ifnecessary, envelope the duty cycle of the service test. Because the ampere:-hours removed by the first time period of the test are accounted for in determining the battery capacity or in the case of a one minute test period represent a very small portion of the battery capacity, the test rate can be changed to that for the performance discharge test without compromising the results of the performance discharge test. The battery terminal voltage for the modified performance discharge test should remain above the minimum battery terminal voltage specified in the battery service test for the duration of time equal to that of the service test. alaC. taX C.a.w-esp Speech' tatei~ 3 B,g Qannd 'A 2D6l0: hr 60 seconds 'f 323 96 for tbe remainder of 4 boor tat B banary 2D620: I es hr 60 seconds 'f 324 anperes for the the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> test .C batay2 97 ampcres for 60 IO ampercs for thi the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> test Channd D battery 300 ampctes for seconds I3 ampcrcs for e remainder of the 4 tat

9) Channd H byway OD59$ :

253 For the first 60 seconds 75 for th<<remainder of 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> test c) For 25(bett I

1) bank 1D650:

11 amperee hr 60.0 soqfnds / anperse hr 29.0 scR 99 ampercs hr 120. minuta Cff<o7 27 amperce for . minutse Battery bank 117 396 '0.0 1 hr 9.0 seco 366 amperee hr 20.0 'ee 325 anperes for 90.0 157 amperee hr ll . minuue anperee hr .0 seconds 'Stt S.o.v, Q ~ 1eeet Ntc>> per 60 tnonths by vggjfying that the battery capacity is K leew  % of the +hen subjected to a pashrtnance or tat. pet 60 month mtaval, ct I ed 4 y 3.Q.g.7 Ngy~g ~RSy bO sctvice ~IHiro p 4 Aaaaal perfottnatc>> dlsdmIe ~ ot battery capacity shaO be Ilvset as eEy betsery tha sbotrs signa ot degradatia>> or hae reached I5% ot the +s4 eenrke Ne expected hr the L42 agre 0% of eeerege or is OC 0M aow4 g 44l tk Zi)iiply ~spry >@a C toO7y of aowoFeg~t rLOJita 4ffi. Ik tA, ~,A. oge.9 h 't 144 ~ e ~>s ras~j AemlsasNo. 110 QSCR g5QUEHANNA- UNK 1 3/4 I-13 [ DISCUSSION OF CHANGES 4RC Lhg 'Z.L't-lO ITS: SECTION 3.8.4 - DC SOURCES OPERATING T HN HAN TR V (continued) chargers. but the SSES ITS definition of Operable-Operability requires that all normal or emergency electrical power is also capable of performing it's related support function. The elimination of the specific requirements for the 24 volt subsystems is acceptable because the requirement to maintain th Operability of the SRMs and IRMs is maintained and the 24 volt battery requirements do not impact the requirement to ensure the 4i-. SRMs and IRMs are Operable. Therefore. this information n e d I 1 dff d d 11df re This approach provides an effective level of regulatory control and h,,~ ~, provides for a more appropriate change control process. The leve of safety of facility operation is unaffected by the change because there is no change in the requirement to maintain the SRMs and IRMs Operable. Furthermore. NRC and PP8L resources associated with processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on the margin of safety. LA.2 SSES CTS 4.8.2.1.f requires an annual performance discharge test of battery capacity for any battery that show signs of degradaticn or has reached 85% of the service life expected for the application. SSES CTS 4.8.2.1.f also defines when degradation is indicated. SSES ITS SR 3.8.4.8 requires an annual performance discharge test. but does not define "a degraded condition." This is acceptable because the specification of the condition when the battery has degraded does not impact the requirement to perform the performance test on an increased frequency. This definition can be adequately controlled in the SSES ITS Bases which requires change control in accordance with SSES ITS 5.5. 10. Bases Control Program. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement to perform the performance discharge test. Furthermore. NRC and PP5L resources associated with processing license amendments to this design information will be reduced. This change is a less restrictive administrative change with no impact on safety. LA.3 SSES CTS 4.8.2.1.d requires the performance of a battery service test and specifies the r equired emergency loads for the design duty cycle. SSES ITS SR 3 8 4.7 requires the performance of a battery service test. but Coes not specify the details of the required emergency loads fcr .ne design duty cycle. This is acceptable because the defin:tion of the required emergency loads for the design duty cycle coos not impact the requirement to perform the service test. F..:hermore, the Operability requirement for the DC electtical power subsystems is maintained in SSES ITS. Therefore. this information can be adequately defined and controlled in the TPB. This approach provides an effective level of regulatory control and provides for a more SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 ma~ RAT 3 8'i lg QQ Sources -Operating 3.8.4 SURVEILLANCE REQUIREHENTS (continued) SURVEILLANCE FREauENCV SR 3.8.4.2 Verify for each battery terminal and 92 days connector: No visible corrosion. +4lc,~k J Battery terminal and connection resistance %vera~ I'gg,Li Atg zo.o &C bid hei) s (0 4( ( h s: ~DR d Oo

b. s E-6 ohms ba44erkos.

SR 3.8.4.3 Verify battery cells. cell plates. and 18 months racks show no visual indication of physical damage or abnormal deterioration that could potentially degrade battery performance. SR 3.8.4.4 Remove visible corrosion and verify battery 18 months cell to cell and terminal connections are coated with anti-corrosion material. 18 months SR 3.8.4.5 Verify the battery connection resistance log, foe. v~g ca~glc <oumeh~ 'fhc operas $ aP'~ 4gth~~ hatting: and c 5 4. (j ( e q y ~~ i o

b. . -6 ohms r tr 2 t ieK (continued]

(((.oui f SUSQUEHANNA - UNIT 1 3.8 '6 Amendment ~ ~7 QR.c. P,At OC Sources Operating B 3..a.4 BASES (continued) SURVEILLANCE REQUIREMENTS K 'LIL~4 Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the charging system and the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required .to overcome the internal losses of a battery (or battery cell) and maintain the battery (or a battery cell) in a fully charged state. The voltage requirements are consistent with the initial voltages assumed in the battery sizing calculations. The SR must be performed every 7 days IEEE-450 consistent with manufacturer recomendations and (Ref. 8). However . this Frequency is modified by a Note that allows the Frequency to be extended for upbeen to 14 days when the battery is on equalize charge or has on equalize charge any time during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change recognizes the routine 7 day Frequency must be extended until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after an equalize charge is completed so that meaningful results are obtained for this SR. The 14 day Frequency is not modified by the Note. therefore. the SR must be performed every 14 days regardless of how often the battery is placed on equalize charge. Pr ouiiit. 4~ o CCcf) iu~(C, i >>r>>i Q 4 Couuto i" ~ Visual inspection to detect corrosion ofresistance the battery ce11s and connections: or. measurement of the of each of inter-tier. terminal connection 'Ii > <'ii'C. Sip J4 inter-cell. inter-rack. and an indication that there is corral<<, with visible corrosion, providesdeterioration that could 4~1 L~ gI iF no physical damage or abnormal I tentially degrade battery performance. ~+iiuiFtg ~O 4liJi 4i~i oc ~i ~ Ja ~ J t~) vrg The connection resistance limits established for this SR dLI ifv vi u sa e> o +~<~> i,><'g OP o > 55 - ohms f 2508 cep a e f ~ +~ ly V r a as establi ensure at t bat y c Hcavy 4~,t erfo its desig unct limit. n even a ll onn ion re at he ceptance c teri +4 Quare Vcr) C which can detect re~irk.ci F ~ The Frequency for these inspections. losses due to resistance oatee<a 4d conditions that can cause power Frequency is considered heating. is 92 days. This oiC.+rasig J i4 based on operating experience related to acceptable

3. <. t.s'ou etecti corrosion trends. t a~<)

ua'~c.. c . ~, ~: v ~ 54m C4 Jv ~ Cc ontinued) gr>' 4 4>> 'To dc C C, ~ aJ <<>>4 >. I.'t. V'.o~ m <a ~>rJ A,r i, i c% gk) en to~c 4~> n NA - UNIT I B A.t rrlgr i WQ.c IlA~ 1.6.q-i g OC Sources -Operating 8 3.8.4 SURVEILLANCE 58 'L9.~4'i REQUIREHENTS (continued) Visual inspection of the battery cells. cell plates. and battery racks provides an indication of physical damage or abnormal deterioration that could potentially degrade battery performance. The presence of physical damage or deterioration does not represent a fai lure of this SR. provided an evaluation determines that the physical damage or deterioration does not affect the OPERABILITY of the battery (its ability to perform its design function). The Frequency of this SR is acceptable because other administrative controls ensure adequate battery performance during the 18 month interval. Furthermore. operating experience has shown these components usually pass the Surveillance when performed at the 18 month Frequency: therefore. the Frequency is acceptable from a reliability standpoint. 4 R 4. Visual inspection and resistance measurements of provides inter-ceil. inter-tier, terminal connections an inter-rack. and deterioration that ind1cat1on of physical damage or abnormal could 1ndicate degraded battery condit1on. The good ant1-corrosion material is used to help ensure deter1oration. electrical connections and to reduce isterminalnot intended to The visual inspection for corrosion inspection under each terminal require removal of and connection. l'miM SPwiAeJ I ah ~~ Thc The removal of visible corrosion is a "+'< <<c Lira+ ao L~ <i, SR. The presence of, visible corrosion prevent1ve maintenance does not necessarily +elhi vo)4g represent a failure of this SR. provided visible corrosion is removed during performance of this Surveillance. Thethe ~~oP acr >i +-'C, limits for this SR must be below connect1on resistance co tgh ~L Ca~a<>i 4 lo ~LC. <Qu~g ~~ The Frequency of this SR is acceptable because other +ic04~ j battery performance administrative controls ensure adequate interval. Furthermore. operating ~)Pc- 4 '.i- br <+~q dur ing the 18 month these components usually pass the A$ 4$ 44 (g Pleach g experience has shown Frequency: when performed at the 18 month ~ pss>a4 L'i og ck o~~>~ 4 ~C. Surveillance therefore. the Frequency is acceptable from a reliability standpoint. over h~h~~ C4uu L ghMJ~ (continued) 8 3.8-56 t A.-SRBtRS SUSQUEHANNA - UNIT 1 Asl Jl /gi cy ~ OISCUSSION OF CHANGES ~Cc. LA g ITS: SECTION 3.8.4 - OC SOURCES OPERATING T HN A HAN - R TR T V (continued) degradation prior to expiration of expected life. and still be within the required capacity to meet Operability requirements. In this event, a Frequency less restrictive than the 12 month Frequency is justified. The 24 month Frequency is consistent with the BWR STS. NUREG-1433. Revision 1. SSES CTS 4.8.2.1.f is required to be performed every 12 months when a battery shows degradation or has reached 85K of expected life with capacity < 100K of manufacturer's rating and every 24 months when a battery has'eached 85K of expected life with capacity i 100K of manufacturer's rating. Since battery capacity is still verified to be equal to or greater than 100K manufacturers rating, this less restrictive change will have a negligible impact on safety. SSES CTS 4.8.2.l.b.2 requires that once every 92 days and within 7 days after a battery discharge...there is no visible corrosion at either.terminals or connectors or6 the connection resistance of these items is less than 150 x 10'hm. SSES ITS SR 3.8.4.6 requires this same verification to be performed only once every 92 days <except that acceptance criteria is modified as explained in OQC H.3). This is acceptable because a significant discharge will not cause an increase in the corrosion rates and will not impact the connection resistance. Both of these problems are related to the environment in which the battery operates, not the batter load. Therefore. this less restrictive change will have f L.4 SSES CTS 4.8.2.1.a requires verification of battery terminal voltages every 7 days. SSES ITS SR 3.8.4.1 requires verification of battery terminal voltages "when on float charge" and provides a new allowance that permits the 7 day Frequency to be adjusted to allow the Surveillance to be deferred if the battery is on equalize charge or has been on equalize charge any time during the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This change is needed because the intent of the SR is to ensure the battery voltage is acceptable when on float charge: therefore, meaningful results cannot be obtained when the battery is on or has recently been on an equalizing charge. After completion of an equalize charge (performed following the battery being on float charge). the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowance to the Frequency provides time to perform the test and to ensure the SR obtains battery voltage that is representative of a float charge. This change is acceptable because the SR is deferred onlv when the battery is on or has just completed an equalizing charge which is the battery condition in which the battery is most likely to meet SR 3.8.4.1 requirements. The 14 day limit in the Freauency ensures the SR is performed at least ever 14 days. regardless of how often the battery is placed on eeua/1ze. SUSOUEHANNA UNIT 1 AND 2 Revision 0, 07/3II'95 OISCUSSION OF CHANGES ITS: SECTION 3.8.4 - DC SOURCES OPERATING HN A CHAN TR T V (continued) The purpose of these tests is to ensure the availability of necessary power to ESF systems from Class 1E battery sources. Two division of batteries are required for the mitigation of an accident during conditions in the event of a loss of all offsite power and a worst case single failure. Extending the surveillance interval for these Surveillances is acceptable for the following reasons: the design, in conjunctions with Technical Specification requirements which limit the extent and durations of inoperable OC sources, provides substantial redundancy in OC sources; battery parameters such as float voltage (which verifies battery charger Operability). electro]yte level. and specific gravity are monitored during the dperating cycle to verify battery Operability and will provide prompt identification of any substantial battery degradation or failure: batteries are not discharged except for the performance of the operating cycle test demonstrations of Operability, so there is minimal risk related degradation: battery attributes subject to degradation due to aging such as terminal corrosion and cell deterioration are monitored during the operating cycle. Therefore, any substantial degradation of the will be evident prior to the scheduled performance of these tests. Based on the above discussion, the impact. if any. from the surveillance test frequency increase on system availability will be small. A review of the survei llance test history for each of these Surveillance requirements was performed to validate the above conclusion. This historical review of the surveillance test history demonstrates that there are no failures that would invalidate the conclusion that the impact of this change. if any. on system availabilitgls small. L.1 SSES CTS 4.8.2.1.c.2 requires that once every 18 months the cell-to-cell and terminal connections are "clean, tight" as well as free of corrosion and coated with anti-corrosion material. SSES ITS 3.8.4.4 requires that visible corrosion be removed and that gQ* the connection are coated with anti-corrosion material. Requiring ~~~glaw the connections to be "tight results in a requirement to torque ~ C the connecting bolts. This application of a torque to confirm iahtness results in unnecessary stress being applied to the 'LN4 bolted connection. If the connection satisfies the resistance gq, requirements of SSES ITS SR 3 8.4.5 (performed at the same 4%14 Frequency), it can be assumed to be sufficiently torqued. The the' "clean" .requirement" has been deleted since it is redundant to cor re ui~~~ This less restrictive change wil have a neg igi e impact cn safety. L.2 SSFS CTS 4.8.2.1.f specifies :"at if the battery reaches 85K of the expected service 5fe ar a. oval performance test is required. SSES IB SR 3.8.4.8 modifies :~is requirement to allow a longer surveillance frequency if t>e ".a.tery'capacity is greater than or equal to 100K manufacturer's a:ing. A battery can show SUS(IEHANNA UNIT 1 AND 2 Revision 0, 07/31/96 'DISCUSSION OF CHANGES ITS: SECTION 3.8.5 - DC SOURCES SHUTDOWN AHN TV A. During the Susquehanna Steam Electric Station (SSES) Improved Technical Specifications (ITS) development certain wording preferences or conventions are adopted which resulted in no 1'2 technical changes (either actual or interpretational) to the SSES current Technical Specifications (CTS). Editorial changes and a new numbering system are adopted to make SSES ITS consistent with the Boiling Water Reactor (BWR) Standard Technical Specifications (STS) NUREG-1433. R~v. l. bSES CTS 3. 2.2 LCO. footnote "~". and Action c recognize the SSES desig capability to al n some, but not all. 125 VDC Unit 1 and corno loads from eith a Unit 1 or a corre ponding Unit 2 ,source. However. Unit 1 ES CTS 3.8.2.2. Act n d. prevents a Unit 2 ource from powe ng the Unit 1 and c n loads for more than 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> after t Unit 1 source is r tored to Operable 'stat . This restri ion ensures each u t's loads are fed from the corresponding it's batter y. The SAR analysis states that t batteries sh not be shared be een the units (i.e. nit I ads shall not e powered from th Unit 2 battery). U 1 SSES ITS 3.8.4 enf ces the same requ ements by requirin nly Unit 1 sources to b Operable. This acceptable becaus . just as in the CTS. o y Unit 1 sources re required for Un 1 operation in Codes 1, and 3 and any f ure of a Unit 1 s rce will require yppropri te Unit actions. In addition, ITS sures this requir nt is met by ifying the Bases Unit 1 and 2 for SS=S ITS S 3.8.7.1 and SS ITS SR 3.8.8.1 include verification that the Unit 1 and on loads are ered from a Unit 1 source unit 2 SSES ITS 3. .5, Action A. is dded to allow the los a snit 1 source. s maintains th current allowance i nit 2 USES CTS 3.8.2.1. Action b. Bas on the above di sions, the .requirements in SSES CTS are consistent with the ~ N 1I dWI '". ES ITS and A.3 SSi.S CTS 3.8.2.2'. Action g (f U/2). and Action h (g U/2) provid an allowance to restore battery bank to Operable status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. SSES ITS 3.8.4 Acticn B (C U/2) and Action C (D U/2) co not specify this option, but it is always and option and is implied. Therefore, this change is a presentation preference which is an administrative change with no impact on safety. A.4 SSES CTS 3.8.2. Action g (f U/2) identifies that diesel generatci E should be verified not rur ning hen the ESW valves (cooling ~ water valves) are closed. :-S.S iTS 3.8.4 Action 8 (C U/2) does not require this verificat =n verifying the condition of equipment prior to and after ."erforming an operation such as closing cooling water valves is not typically specified in eithert". the SSES CTS or SSES ITS. Tii's tyoe of information is part of e duties of an operator arid psri "f normal plant operation. This s a presentation preference i" :ne SS=S ITS. Therefore, this char g is an administrative change ~"." o impact on safety. Revision 0., 07/31~9~ SUSQUEHANNA UNIT 1 AND 2 INSERT (NRC RAI 3.8.5%2) A.2 SSES CTS 3.8.2.2 LCO, footnote" ', and Action c recognize the SSES design capability to align some, but not all, 125 VDC Unit 1 and common loads from either a Unit 1 or a corresponding Unit 2 source. However, Unit 1 SSES CTS 3.8.2.2, Action d, prevents a Unit 2 source from powering the Unit 1 and common loads for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the Unit 1 source is restored to Operable status. This restriction ensures each unit's loads are fed from the corresponding unit's battery. The FSAR analysis states that the batteries shall not be shared between the units (i.e., Unit 1 loads shall not be powered from the Unit 2 battery). SSES ITS maintains the same requirements and allowances through different LCOs. First, Unit 1 SSES ITS LCOs only require Unit 1 sources to be Operable. This is acceptable because, just as in the GTS, only Unit 1 sources are required for Unit 1 operation and any failure of a Unit 1 source will require appropriate Unit 1 Required Actions. For Unit 2, as required in SSES GTS, some Unit 1 sources and distribution systems are required therefore, they are specified in SSES Unit 2 ITS. This ensures that all required loads for Unit 2 are powered from the appropriate source. To provide the same flexibilityprovided in the SSES ITS, Unit 2 SSES 1TS LCOs 3.8.4, 3.8.5, 3.8.7 and 3.8.8 provide Conditions and Required Actions which allow the transfer of Unit 1 and common loads to Unit 2 sources and distribution systems. Furthermore, SSES Unit 2 ITS SR 3.8.7.1 and SSES Unit 2 ITS SR 3.8.8.1 include verification that the Unit 1 and common loads are powered from a Unit 1 source. Based on the above discussions, the requirements in SSES CTS are consistent'with the SSES'ITS and therefore the changes are administrative witn no impact on safety. ~gas (Ceehsned) %hh de nquitad diesel E chatict ~etaSe ant 4lcscl gcnctasot E fee ailgae4 co the lE 4isaibadon syacm, 4cmasccam ao 0 KITY of ha bmscty by @ning ltequltemea 4.$ 2.1 1 eihh 1 bout al once pcr f bouts . Ifany A lhnis hs T!M 4.12.1-1 not mcc, de banacy 3.$ 22L lnopctabl and uhe the A ON ~ by,' gg g.g,g,j ~~ As least the above tcquira4 basscty and chatgat shall be dcmonsuatc4 ppHLABLE pet Sutveillasee Requitement 4.$ 2.1. Adel M. 0. C.Z.y 3/4 I-lTa Ama(ndmcssi No. H QgqUEHANNA - UNG' 4kt'A I X.B.f -gq DC Sources -Shutdown 3.8.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 0 TE-------------------- The following SRs are not required to be performed: SR 3.8.4.6. SR 3.8.4.7. and SR 3.8.4.8. For DC sources required to be OPERAHLE the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.&.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8. SR 3.8.4.3 SR 3.8.4.6 - UNIT 3 8-32 Amendment A. 07/31/96 SUSQUEHANNA 1 INSERT 3.8-2943 (Unit 2 Only) SR S.'S.S.2 NOTE When Unit J ls in MODE 4 or 5, or moving Irradiated fuel assemblies in the secondary containment, the Note to Unit $ SR 3.8.5.5 is applicable. For rectulred Unit 1 DC electrical power ln accordance subsystems, the SRs for Unit l Specl8cadon with applicable 3.8A are applicable. SRs ~ +c. th s - Shutdown i.g.s'-gr DC Sources 8 3.8.5 BASES APPLICABILITY . b. Required features needed to mitigate a fuel handling (continued) accident are availabl e:

c. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available: and

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

The DC electrical power requirements for NODES 1, 2. and 3 are covered in LCO 3.8.4. ACTIONS The ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. 1 i'-ef~ a 4is Sf@<<~Q ia <<~g Kg<<<. btc%>>i,g L,~ cL1 f <<>>q eddsll<<>><<l Wh&$ &s g i'>> f Meso 65K V or S 'md(<<eral foe,l <<gc<aio~~ A A A, A., an If more than one Unit I DC distribution subsystem is required according to LCO 3.8.8, the remaining operable Unit I DC subsystems may be capable of supporting sufficie"t required features to allow continuation of CORE ALTERATICNS fuel movement. and operations with a potential for draining the reactor vessel. Therefore. the option is provided to declare required featur es with associated DC power sources inoperable which ensures that appropriate restrictions are imp'lemented in accordance with the affected system LCOs'CTIONS. In many instances. this ootion may involve undesired administrative efforts. Therefore. the allowance for sufficiently. conservative actions is made (i.e.. to suspend CORE ALTERATIONS. move-ent of irradiated fuel assemblies. and any activities :ra: could result in inadvertent drain ~ of the reactor vessel: Suspension of these activities shall not preclude c~~'etion of actions to establish a sa'.e conservative conditi".~ These actions minimize the probability of the o" . ence of postulated events. It is further required to .~~."iately initiate action to restore (continued) SUSQUEHANNA - UNIT 1 B 3 S.".3 Amendment A. 07/31196 MR(. QPg ~P g c( Battery Cell Parameters B 3.8.6 8ASES (continued) SURVEILLANCE REQUIREHENTS This SR verifies that Category A battery cell parameters are consistent with IEEE-450 (Ref. 4). which recommends regular battery inspections including voltage. specific gravity. and electrolyte temperature of pilot cells. The SR must be performed every 7 days. unless (as specified by the Note in the Frequency) the battery is on equalizing charge or has been on equalizing charge any time during the previous 4 days. This allows the routine 7 day Frequency to be extended until such a time that the SR can be properly erformed and meaningful results obtained. The 14 day requency is not modified by the Note. thus regardless of how often the battery is placed on equalizing charge. the SR must be performed every 14 days. K 'ULE? The quarterly spection of specific gravity and voltage is consistent wi IEEE-450 (Ref. 4). In addition, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a battery discharge < 110 V for a 125 VDC battery an < 220 V for a 250 VDC battery or a battery > 300 V for a overcharge ~ 150 V for a 125 VDC battery and to meet ~ 250 VOC battery. the battery must be demonstrated Category 8 limits. Transients. such as motor starting transients. which may momentarily causeandbattery voltage to drop to ~ 110 V for a 125 VOC battery i battery 220 V for a discharge 250 VOC battery. do not constitute a provided the battery terminal voltage and float current return to pre-transient values. This inspection is also recomoends special consistent with IEEE-450 (Ref. 4). which or overcharge. to inspections following a severe discharge of the battery occurs ensure that no significant degradation overcharge. as a consequence of such discharge or l~l that the average temperature This Surveillance verification witn of representative cells is within limits is consistent that the (Ref. 4) that states a recoamendation of IEEE-450 representative cells should temperature of electrolytes inbasis. The number of be determined on a quarterly determined to be 10 cells for representative cells iias been for a 250 VOC battery. a 125 VDC battery and 20 cells (continued) 0'%It (c Al $ I . 4 i lit Nf -'NIT 1 8 3.8-69 SUSQUEHANNA -Fnctp.(go ~ I 0 OOC 3i tf 'g V~( ~ 5 PCC ~ Ft fg1oo ELECTRICAL %VER SYSTENS LlltITIlC CONDITION FOR OPERATION Conttnuad ACTION: (Conttnued) dasi$ nscr OPERA81 ITY of fts assocfated battery bank by erforefng urvefllanc Raqufreeen a.8.2.1.a.1 tthfn 1 h ur an at least o ce per 8 urs tnereaf r. If any tagory A f ~ ft fn Table 4.8 2.1-1 fs n he ACTI N re t set, dec re the batt tnoper e, and tak SURVEILLANCE RE IREXENTS Each of the above requfred 24 v t 125-volt and 250-volt battertes and chargers shall be deeonstrated 0  : L.A,t At least once per 7 days by verffytng that: 7 ~ The parameters fn Table i.8.2e I 1 eeet the Category A lfetts and to ~ fs co~ brea4r ~ lf a4nt t the bakery c attery era~na vo tage i rea r n or aqua ~ LA I ZP. 3 8" i 129, 258-volts on float charge. )Jest At least once per 92 days and <<fthtn T days after a battery dfscharge I 'y <<ith battery teratnal voltage bolo<<22- 10 or 220 volts, as applfcable, or battery overcharge <<fth battery teretna voltage above 150 or 300 volts, as appltcable, by vert fyfng that: LA.f 38.L.2 W The Par~ters fn Table a.8.2o1 1 eeet the Category 8 ltafts, gp Q Qqs w. Tnooo is.no otstsl ~ eooooslon ot ~ itnoo torninsls oo eonnoetoos,~(g or ton resfstance of these tteas ts less than ~l. x 10-e ota, and ~ ~ 4 S.t.~ ~ The average electrolyte t~rature of 1 or as applfcable,, of connected calla for the 125 and 250 vo tertes fs above'0 F. r(frC 'Lot Ls,k,gi ~Ai 3 5 ~ TO I SUSQUEHANNA UNIT 1 3/a 8 Ile ITS: DISCUSSION OF CHANGES SECTION 3'8.6 - BATTERY CELL PARAHETERS ~ a<Z, ~.iL.g-c ~ - H T V SSES CTS Table 4.8.2.1-1 footnote (c) allowance to correct the Category 8 float voltage limit for temperature has been deleted in SSES ITS Table 3.8.6-1. The deletion is consistent with the recorrmrendations of IEEE-450. . The change reflects the current requirements for battery esting and therefore. this more restrictive change will have no n ative impact on safety. i "~c, 8~~~/, SSES CTS Table 4.8.2.1-1 footnote (1) and footnote (2) allow deviation from the Category A and 8 limits provided parameters are restored. SSES ITS Action A requires the restoration of battery limits and adds Required Action A.l for when a Category A or 8 limit is not met. This Required Action requires a check within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> that the pilot cell electrolyte level and float voltage are within the Category C limits (SSES CTS Table 4.8.2.1-1 Category 8 allowable values). This ensures that if the pilot cell is below Category C limits. the battery will be declared inoperable imediately. Therefore. this more restrictive change has no negative impact on safety. H.3 SSES CTS 4.8.2.1.b.1. the quarterly verification of specific gravity and voltage against Category 8 limits. includes a requirement that battery must be demonstrated to meet Category 8 limits within 7 days of a significant battery discharge. SSES ITS SR 3.8.6.2 requires the same verification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a signtficant battery discharge. This change is needed because confirmation of battery Operability following a significant discharge must be made promptly and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allows sufficient time to plant for an unscheduled Surveillance'nd complete the performance of the surveillance of cell parameters without excessive haste. Since this confirmation of Operability is revised to make the determination sooner. the change has no negative impact on safety. T H SSES CTS Table 4.8.2.1-1 footnote (b) requires the + 24 volt batteries and associated,chargers to be Operable. These batteries and chargers provide power to the intermediate range monitor (IRH) and the source range monitor (SRH) instrumentation. They are a support system for the IRH and SRH instrumentation. SSES ITS 3.3.1.2. require the Operability of the SRHs, and SSES ITS 3.3.1.1. requires the Operability of the IRHs. SSES ITS does not specifically require the Operability of the + 24 voltofbatteries and associated chargers. but the SSES ITS definition Operable-Operability requires that all normal or emergency electrical power is also capable of performirg ;t s related support function. The elimination of the specific requirements for the 24 volt subsystems is acceptable becar.se the requirement to maintain the Operability of the SRHs and I.Hs is maintained and the ensure. 24 volt battery requirements do not i-.act the requirement to the SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 DISCUSSION OF CHANGES Akz, z.g.r. ou ITS: SECTION 3.8.6 - BATTERY CELl PARAHETERS 3. 94, 4% T H A HA TR (continued) SRHs and IRMs are Operable. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement to maintain the SRHs and IRMs Operable. Furthermore. NRC and PPKL resources associated with processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on the margin of safety. SSES CTS 4.8.2.l.b.3 requires that the average electrolyte temperature of 10 or 20. as applicable, of connected cells be verified above 60 F. SSES ITS SR 3.8.6.3 require the electrolvte temperature be verified, but does not define the number of cells to be measured. SSES ITS 3.8.6.3 requires a "representative" cells be verified within the limit. This is acceptable because the requirement to verify the temperature is maintained in SSES "I" ITS and the number of cells verified does not impact this ". Th defines the surveillance requirements for the battery testing. Therefore. the detail relating to the plant specific determination of "representative" is proposed to be relocated to the Bases. Therefore, this information can be adequately defined and controlled in SSES ITS Bases which require change control in accordance with SSES ITS 5.5.10, Bases Control Program. This approach provides an effective level of regulatory control and provides for a more appropriate change control process. The level of safety of facility operation is unaffected by the change because there is no change in the requirement to perform the SR. Furthermore. NRC and PAL resources associated with processing license amendments to these Administrative Control requirements will be reduced. This change is a less restrictive administrative change with no impact on the margin, of safety. L.l SSES CTS 4.8.2.1.b.3 requires that once every 92 days and within 7 days after a battery discharge. the average electrolyte temperature is verified to be above 60 F. SSES .ITS SR 3.8.6.3 requires this same verification to be performed only once every 92 days. This is acceptable because a large discharge of the battery wi ll tend to heat the battery electrolyte not reduce the temperature. The requirement to Yeasure electrolyte temperature is not necessary. Therefore .nis less restrictive change will have no impact on safety. iqc$ L.2 SSES CTS Table 4.8.2.1-1 s ilies that the electrolyte level be maintained in a specified n",e SSES ITS Table 3.8.6-1 footnote (a) allows for a temporary electrolyte level increase during and following an equalize char e. a"d is based on guidance from Appendix A to [EEE-450, . Tt e level excursion is due to gas generation during an equaliti..g charge and would be expected to SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 ~M 4hZ. s.a.( gg DISCUSSION OF DEVIATIONS FROM NUREG 1433 ITS: SECTION 3.8.6 - BATTERY CELL PARAMETERS P ANT P F HAN (continued) excursion is due to gas generation during an equalizing charge and normally returns to normal within 3 days following completion of the equalizing charge. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore, this change does not represent a significant deviation from the intent of NUREG 1433. NUREG-1433. Revision 1. LCO 3.8.6. Table 3.8.6-1, footnote (b). requires that specific gravity measurements be corrected for level and temperature except when the battery is on float charge. SSES ITS LCO 3.8.6, Table 3.8.6-1. footnote (b). does not require level correction for soecific gravity regardless of the status of the float charge. This change is needed and acceptable based on the recomnendations of the battery manufacturer and is specifically permitted by IEEE-450 . 1995. Annex A.3. IEEE-450 . 1995 'nnex A.3. states that "if the electrolyte level is between the high ar d low level marks and the temperature corrected specific gravity of the electrolyte is within the manufacturer's specific gravity range, it is not necessary to correct the specific gravity of the battery for electrolyte level. This change has no impact on safety because. as determined by the manufacturer with the concurrence of IEEE 450. battery specific gravities that are not corrected for level provide an adequate indication of the state of the battery. This change has been made to ensure that c'harge Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant deviatior from the intent of NUREG 1433. C P.5 NUREG-1433, Revision 1, LCO 3.8.6. Table 3.8.6-1. footnote gfl. allows using float charge to satisfy requirements for speciiic gravity measurements "following a battery recharge. for a maxima of 7 days. When charging current is used to satisfy specific gravity requirements, specific gravity of each connected cell shall be measured prior to expi ration of the 7 day allowance. SSES ITS LCO 3.8.6. Table 3.8.6-1. footnote (c). allows accepting a stabilized charger current is an acceptable alternative to . siiecific gravity measurement for determining the state, of charge This change is needed because specific gravity gradients are produced during the recharging process and delays of several days may occur while waiting for .ne specific gravity to stabilize This change is acceptable because IEEE-450 recognizes that a e stabilized charger current is an acceptable alternative to sp cific gravity measurement for aeterminin th off& te of charge P.6 NUREG-1433, Revision 1. 'LCC . 8 6. Bases were revised to incluce an explanation of the LCO K:i-~s Note allowing separate condit entry. SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31'96 f4Lc. ~g g g ( Battery Cell Parameters 3.8.6 3.8 ELECTRICAL POWER SYSTEMS 3.8.6 Battery Cell Par ameters Battery cell parameters for the Class lE LCO 3.8.6 Class 1E a 5 V batteries shall be within . .6- ~ limits~ 250 V batteries and APPLICABILITY: When associated DC electrical power subsystems are required to be OPERABLE. ACTIONS --NOTE-Separate Condition entry is allowed for each battery. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more batteries A. 1 Verify pilot cell 1 hour with one or more electrolyte level and battery cell float voltage meet parameters not within Table 3.8.6-1 Category A or B Category C limits. limits. gg} A.2 Verify battery cell 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> parameters meet Table 3.8.6-1 Category C limits. Once per 7 days thereafter A.3 Restore battery cell 31 days pa. ameters to Category A and 8 1 >rr.Its of Table 3.8.6-1. (continued) SUSQUEHANNA - UNIT 1 3.8-33 Amendment A. 07/31/96 >RC. C.AX 1.B.7 Q I Distribution Systems-Operating 3.8.7 Table 3.8.7-1 (page 1 of 1) Unit 1 AC and DC Electrical Power Distribution Subsystems TYPE VOLTAGE DIVISION I DIVISION II AC Buses 4160 V 1A201 (Subsys. A) 1A202 (Subsys. 8) Load Groups 1A203 (Subsys. C) 1A204 (Subsys. 0) 480 V 18210 (Subsys. A) 18220 (Subsys. 8) Load Centers 18230 (Subsys. C) 18240 (Subsys. 0) 480 V 08516 (Subsys. A) 08526 (Subsys. 8) Hotor Control 08517 (Subsys. A) 08527 (Subsys. 8) Centers 18216 (Subsys. A) 18226 (Subsys. 8) 18217 (Subsys. A) 18227 (Subsys. 8) 08536 (Subsys. C) 08546 (Subsys. 0) . 08136 (Subsys. C) 18246 (Subsys. 0) 18236 (Subsys. C) 18247 (Subsys. 0) 18237 (Subsys. C) 08146 (Subsys. D) 2OB/~ Oistributibn Panels V ]YP16 (Suhcys. A) 'veau subsvs. l v, lY226 (Subsys. 8) lY246 (Subsys. 0) DC Buses 250 V Buses 10652 1D662 10254 10264 10274 125 V Buses 10612 (Subsys. A) 10622 (Subsys. 8) 10614 (Subsys. A) 10624 (Subsys. 8) 10632 (Subsys. C) 10642 (Subsys. 0) 10634 (Subsys..C) 10644 (Subsys. 0) DG E DC Bus 125 V Bus OD597 - UNIT 3.8-41 Amendment A. 07/31/96 SUSQUEHANNA 1 fstrfbutfon Systems -Operating 3.8& 7 3.8 ELECTRICAL POWER SYSTEHS 3.8 jF Dfstributfon Systetns -Oper ng 7 ('~) LCO 3.8.P' [ fsi~ 1 and gNvfsfon AC, OC, nd AC vf~ usj~ ec~cai owe@ dfstrfb on subs ems shal~e OPERASLE.. r 'C > 8.'E. APPLICABILITY: HOOE I, 2, and 3. ACTIONS RE(VIREO ACTION CONPLETION TINE A. One o more AC A.l Restore A electrical 8 hours .Sl i ~ elec ical power power distribution dis fbution subsystems to ~ C4l 0 os ~AN su ystems inoperable. OPERABLE status. 16 hours from discovery of /y~~ ~ ji failure to met W 3,S 3 0> ~SJt.'1 . One or more vital B.1 Re tore AC vital bus 2h rs buses fnope able. strfbutfon ubsystems to OPERABLE status. 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from discovery of failure to met LCO

g. On or mo t P.l Restore OC electrical 2 hours 3. 4.g. f e electr cal power dfstributfon hchi~ g pow fstrfbutfon subsystems to ~AN subsystems inoperable. OPERABLE status.

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from lj~ l ~uf discovery failure to of,Pp<< meet ~< LCO~gg y (continued) 3.8-38 QA.g ii*y DISCUSSION OF DEVIATIONS FRY NUREQ 1433 ITS: SECTION 3.8.7 - DISTR!BUTION SYSTENS OPERATING P AN P F HAN P.1 NUREG-1433. Revision 1. LCO 3.8.7. was revised to include a reference to Table 3.8.7-1. Unit 1 [or 2g Distribution Subsystems. which identifies each of the distribution subsystems required to be Operable. These changes provide additional detail and are intended to improve clarity and ensure requirements are fully understood and consistently applied. There are no technical changes to requirements as specified in NUREG-1433. Revision 1: therefore. this change does not represent a si nifi an deviation from <<~~sos o ~i> 4u NUREG 1433. l:u> 4 + + +i ++ ~4 i> J P.2 NUREG-1433, Revision 1. LCO 3.8.7. Condition . was not include e;. ~~ in the SSES ITS because the SSES design with 4 ESS buses makes i ~i,.u acceptable to have an inoperable ESS bus for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. is change is needed to maintain an allowance in the SSES current Technical Specifications. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant or generic deviation from NUREG 1433. P.3 NUREG-1433, Revision 1, LCO 3.8.7. was revised to include Conditions and Required Actions D and E for distribution subsystems supporting the Operability of diesel generator E depending on whether or not DG E is aligned to support a 4.16 kV ESS bus. This change has been made to ensure that Improved Technical Specifications account for the SSES design. Therefore. this change does not represent a significant or generic deviatio~ from NUREG 1433. This change is needed to maintain an allowan"e in the SSES current Technical Specifications. P.4 NUREG-1433, Revision 1, LCO 3.8.7 was revised to include ~ Conditions and Required Actions H and I governing the ability to temporarily transfer Unit 2 loads powered by Unit 1 sources to Unit 2. Additionally . surveillance requirements for Unit 1 distribution subsystems that support Unit 2 were added to the Unit 2 Technical Specifications. This change has been made to ensure that Improved Technical Spec~ficati.ons account for the SSES design. Therefore. this change does not represent a significant or generic deviation from NUREG 1433. This change is needed to maintain an allowance in the SSES current Technical Specifications. P.5 The Bases for NUREG-1433. Re~ision 1. LCO 3.8.7. were revised to describe the SSES design. This change is needed to ensure that SSES Improved Technical Specifications account for the SSES design and/or that the SSES design is accurately and completely described in the Bases. Therefore. :h~s change is not a significant or generic deviation from NUREG I-'33 p.6 The Bases for NUREG-1433. Revision 1. LCO 3.8.7. were revised to eliminate references to tie breakers because SSES does not have UNIT 1 AND 2 REV OC. 04/23>'96 SUSQUEHANNA OCC <<> I 0:t-ap Distribution Systems -Operating 8 3.8.7 BASES ACTIONS (continued) With one or more Unit 1 DC buses inoperable. the remaining OC electrical power distribution subsystems may be capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition. assuming no single failure. The. overall reliability is reduced. however. because a single failur e in one of the remaining DC electrical power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore. the required OC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by powering the bus from the associated batter or c r er. r wu tie, Mb~c> Condition B represents one subsystemwit out adequate OC power. potentially with both the battery significantly degraded and the associated charger non-functioning. In this situation the plant is significantly more vulnerable to a loss of minimally required OC power. It is. therefore. imperative that the operator's attention focus on stabilizing the plant. minimizing the potential for loss of power to the remaining divisions. and restoring power to ti e affected division. This 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> limit is more conservative than Completion Times allowed for the majority of components that would be without . power . Taking exception to LCO 3.0.2 for components without adequate OC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is acceptable because of:

a. The potential for decreased safety when requiring a change in plant cordi ions (i.e.. requiring a shutdown) while no: allowing stable operations to continue:

b. The potential for decreased safety when requiring entry into numerous applicable Conditions and Required Actions for components without K power. while not providing sufficie~: ;m for the operators to perfo~

the necessary e'a'tions and actions for restoring power to the affe-:e. division;

c. The ootential fc .~ e'ent in conjunction with a sing'le failure dundant component.

(continued; - UNIT I 8 3 8 ~,7 Amendment A, 07/31/96 SUSQUEHANNA uc.c ~x s S.l-op -. Distribution Systems -aperating B 3.8.7 BASES ACTIONS (continued) The 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Completion Time for OC buses is consistent with Regulatory Guide 1.93 (Ref. 3). The second Completion Time for Required Action B.l establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single continuous occurrence of failing to meet hours the LCO. If Condition C is entered while. for instance. an AC bus is inoperable and subsequently restored OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This situation could lead to a total duration of 10 . since initial failure of the LCO. to restore the OC distribution system. At this time, an AC division could again become inoperable. and OC distribution could be restored OPERABLE. This could continue indefini ly. C dition is modified by a Note that states that Condition is not pplicable to the DG E DC electrical power subsystem. Condition 0 or E is applicable to an inoperable OG E DC electrical power subsystem. .This Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This allowance results in establishing the "time zero" at the time the LCO was initially not met, instead of at the time Condition C was entered. The 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Completion Time is an acceptable limitation on this potential of failing to meet the LCO indefinitely. The Completion Time exception is not applicable to Condition 0 or E because Condition D and E are only applicable to OG E OC electrical power subsystem. If the inoperable distribution subsystem cannot be restored to OPERABLE status witnin the associated Completion Time. the unit must be brought to a NODE in which the LCO does not apply. To achieve this status. the plant must be brought :o at least NODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and to NODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allot ed Comletion Times are reasonable. based on operating excel ience. to reach the required plant conditions from full p-. er conditions in an orderly manner and without challengirg plant systems. (continued) SUSQUEHANNA - UNIT 1 B 3.B-.B Amendment A. 07/31/96 alar, 4 ~ PCg pc 6~ op a~7 H. One or more Unit 1 H.l Transfer associated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OC electrical power Unit 1 and coaaen loads distribution to corresponding Unit 2 subsystem(s) DC electrical power inoperable. distribution subsystem. ~octa.A H.2 Restore Unit 1 and coaaen loads to corresponding Unit 1 DC 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after electrical power Unit 1 DC distribution subsystem. electrical power subsystem fs restored to OPERABLE status. I. Required Actions and I.l Declare associated Itnaedf ately 439.5, associated Completion Times of coaaen loads inoperable. aX~> Condition H not met. p) g,~ R AX 1- 8.1-+ Distribution Systems-Operating 3.8.7 SURVEILLANCE REQUIREHENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct breaker alignments and 7 days or indicated power availability to required AC and OC electr ical power distribution subsystems. - UNIT 3. 8-40 Amendment A, 07/31/96 SUSQUEHANNA 1 INSERT: R . I (Unit 2~0 A. ( ntinued) A.3.1 Transfer affected Inmedi ately,(Z Unit I and common C loads to corresponding Unit 2 electrical ppwer distribution subsystem. A.3.2 Declare all affected Iamediately required feature(s) which are not C+0c L.>h transferred inoperable. A.3.3.1 Restore Unit I and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (~i>> after comaon loads to Unit I corresponding Unit I electrical power electrical power distribution distribution subsystem is subsystem. restored to OPERABLE status. A.3.3.2 Declare associated 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after Unit I and coaNNn Unit I loads inoperable. electrical power distribution subsystem is restored to OPERABLE status. y INSERT: 3. &-P402 Op'. Diesel Generator E DC B.I Verify that all ESW 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> g~rg~ electrical power valves associated with ~ distribution subsystem inoperable, while not Diesel Generator E are closed. ~o~g aligned to the Class lE distrfbution system. C. Diesel Generator E DC C.l Declare Diesel 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> gy 0 p ( electrical power Generator E inoperable. distribution subsystem inoperable, while aligned to the Class lE distribution system. POCc LPQ'8.9 m3 Distribution Systems - Shutdown 3.8.8 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TINE B. Diesel Generator E DC B.l Verify that all ESW 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> electrical power valves associated distribution subsystem with Diesel Generator inoperable. while not E are closed. aligned to the Class 1E distribution system. C. Diesel Generator E DC C.l Declare Diesel 2 hours electrical power Generator E distribution subsystem inoperable. inoperable, while aligned to the Class 1E distribution system. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct breaker alignments and 7 days volta to required AC and DC electrical 4g, r i stributi on subsystems. ~sLLg(,q SUSQUEHANNA - UNIT 1 3.8-44 Amendment A. 07/31ig6 AlCC CAZ'.S.8~'f Distribution Systems-Shutdown B 3.8.8 BASES APPLICABILITY d. Instrumentation and control capability is available (continued) for monitoring and maintaining the unit in a cold shutdown condition or refueling condition. The AC, DC and DG E electrical power distribution subsystem requirements for NODES 1. 2. and 3 are covered in LCO 3.8.7. ACTIONS The ACTIONS have been modified by a Note stating that LCO 3.0.3 is not applicable. a w! c ~all *a.mal Jle!!sa> !a +4PQ 't ~ !' aping ~A ~ ~~ <rrgglsa Scf 415era{terg The Unit 1 DC subsystems remaining OPERABi E with one or more Unit 1 OC power sources inoperable may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement. and o eratfons with a potential for draining the reactor vessel. erefore. the option is. provided to declare required features with associated DC power sources inoperable which ensures that appropriate restrictions are implemented in accordance with the affected system LCOs'CTIONS. Condition A is modified by a Note that states that Condition A is not applicable to the OG E OC electrical power subsystem. Condition B or C is applicable to an inoperable DG E OC electrical power subsystem. A A 4 n A In many instances the option above may involve undesired administrative efforts. Therefore. the allowance for sufficiently. conservative actions is made. (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies in the secondary containment. and any activities that could result in inadvertent draining of the reactor vessel). Suspension of these act vities shall not preclude completion of actions to establish a safe conservative condition. (continued) - UNIT 1 B 3.8-83 amendment A. 07/31/96 SUSQUEHANNA DISCUSSION OF DEVIATIONS FROH NUREG 1433 ITS: SECTION 3.8.8 - DISTRIBUTION SYSTEHS - SHUTDOWN N - K NT P F AN P.1 Editorial changes and additional design detail are incorporated as necessary to more precisely describe SSES current practice or design. These changes are self explanatory. This change provides additional detail and is intended to improve clarity and ensure the requi rement is fully understood and consistently applied. There are no technical changes to requirements as specified in NUREG 1433, Revision 1: therefore. this change is not a significant or generic deviation from NUREG 1433. P.Z NUREG-1433, Revision 1, LCO 3 '.8, is revised to include a reference to Table 3.8.7-1. Unit 1 or 2 Distribution Subsystems. which identifies each of the distribution subsystems required to be Operable. These changes provide additional detail and are intended to improve clarity and ensure requirements are fully understood and consistently applied. There are no technical changes to requirements as specified in NUREG-1433. Revision 1: therefore. this change does not represent a significant or generic deviation from NUREG 1433. P.3 NUREG-1433. Revision 1. LCO 3.8.8. Required Actions. is modified to include a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in Hode 4 or 5. LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in Hode 1, 2. or 3. the fuel movement is independent of reactor operations. In either case. inability to suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown. Therefore. the Note has been added consistent with other placed where the Note appears in the ITS (e.g.. ITS 3.6.4.3, Standby Gas Treatment System). The Note applies to more than one of the Required Actions. thus it has been placed at the beginning of the Actions ble This change is consistent with the current Technical Specif cations. This change is consistent with the current Qw~~ Technical Specifications and consistent with NUREG 1433. Rev. 1. H t~c Generic Change SWROG-08 (TSTF-36) which is currently being g.Q evaluated by the NRC. This change is needed to ensure that SSES Improved Technical Specifications account for the SEES design and/or that the SSES design is accurately and compiet ly described in the Bases. Tlierefore. this change is not i ~. Inificant or generic deviation from NUREG 1433. P.5 NUREG-1433. Revision 1. LCO 3 8 8 is revised to include Required Actions A.3 governing the abide "./ to temporarily transfer Unit Z loads owered by Unit 1 sources < i Unit 2. Additionally. Survei/lance Requirements far it i distribution subsystems that support Unit 2 were added to '."" <.~it 2 Technical Specifications. Thi s c h ange has been made to ~~~i.re that Improved Technical S ecifications account for the >>ES des'g i n.. Therefore. this c ange does not represent a si.;ni ficant or generic devia on rc SUSQUEHANNA UNIT 1 AND 2 Revision 0. 07/31/96 INSERT NRC RAI 3.8.8-04: This clariQcation is necessary because defaulting to LCO 3.0.3 (during irradiated fuel assembly movement in MODES 1, 2, or 3) would require the reactor to be shutdown, but would not require immediate suspension of movement of irradiated fuel assemblies when required components are inoperable. LCO 3.0.3 is only applicable in MODES 1, 2, or 3. Therefore, once the unit has been placed in MODE 4 in accordance with LCO 3.0.3, LCO 3.03 is no longer applicable: The actions of the "shutdown" Electrical Power System Technical SpeciQcations, which require suspension of irradiated fuel movement, would then be applicable. However, the requirements of LCO 3.0.3 would allow up to 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> to place the unit in MODE 4 (and, as a result, up to 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> to suspend movement of irradiated fuel). Therefore, with the unit in this Condition, the Note (LCO 3.0.3 is not applicable) ensures that the actions for requiring immediate suspension of irradiated tuel movement are not postponed due to entry into LCO 3.0.3, and that the unit is immediately placed in a condition of minimum risk with respect to fuel handling in MODES 1,2, or 3. 8 3.8-91-01 +Y'NSRNT: i) lpe Uni~~() shirces inoperable subsystems remaining OPERABLE with one or more Uni Op'power INSERT: 8 3.8-91-02 (Unit 2 Only) 5 ~ The option to transfer required comnon loads to an OPERABLE Unit 2 electrical power subsystem ensures power will be restored to required loads. To ensure any loads Mich are not transferred to the Unit 2 power distribution subsystem are compensated for, Required Action A.3.2, requires the required features to be declared inoperable. Although the corresponding Unit 2 electrical power subsystem is evaluated for this condition, this violates a design coaeitment to maintain power separation between units. To minimize the time this condition exists, Required Action A.3.3 directs that power supply be restored to the corresponding Unit 1 electrical power subsystem, which restores power to the comaon loads, or requires that the Unit 1 and coaaen loads are declared inoperable. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provides sufficient tiaa to restore power and acknowledges the fact that the condition, although not consistent with design requirements, maintains all required safety systems available. INSERT: 8 3.8-91-O3 'I T 'll 'r 0 II