View source for PLA-7384, Proposed Amendment No. 292, Temporary Change to Allow Replacement on Unit 1 480 V Ess Load Center Transformers in Unit 2 Technical Specifications 3.8.7 and 3.7.1

{{Adams
| number = ML16029A031
| issue date = 01/28/2016
| title = Proposed Amendment No. 292, Temporary Change to Allow Replacement on Unit 1 480 V Ess Load Center Transformers in Unit 2 Technical Specifications 3.8.7 and 3.7.1
| author name = Franke J
| author affiliation = Susquehanna Nuclear, LLC, Talen Energy
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000388
| license number = NPF-022
| contact person = 
| case reference number = PLA-7384
| document type = Letter type:PLA, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 42
}}

=Text=
{{#Wiki_filter:TALEN ~
Jon A. Franke        Susquehanna Nuclear, LLC Site Vice President                   769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504               ENERGY JAN   ~ 8 2016                                         Jon.Franke@talenenergy.com U.S. Nuclear Regulatory Commission                                                   10 CFR 50.90 Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NUMBER 292 TO UNIT 2 OPERATING LICENSE NO. NPF -22 TEMPORARY CHANGE TO ALLOW REPLACEMENT OF THE UNIT 1 480 V ESS LOAD CENTER TRANSFORMERS IN UNIT 2 TECHNICAL SPECIFICATIONS 3.8.7 and 3.7.1 PLA-7384                                                                           Docket No. 50-388 Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC, hereby requests approval of the following proposed amendment to the Susquehanna Steam Electric Station (SSES) Unit 2 Technical Specification (TS). The proposal affects Technical Specification 3.8.7 "Electrical Power Systems- Distribution Systems- Operating" and Technical Specification 3.7.1 "Plant Systems - RHRSW System and UHS."
This proposed change would increase the Completion Time for Condition C ofTS 3.8.7 and Condition A and B of TS 3. 7.1 from 72 hours to 7 days in order to accommodate 480 V ESS Load Center Transformer replacements on Unit 1. The electrical distribution system at SSES is such that only changes to Unit 2 Technical Specifications are required for these replacements. Based on historical data and schedule projections, the replacement of a Unit 1 480 V ESS Load Center Transfmmer requires approximately 120 hours, which would exceed the cunently specified Completion Times of 72 hours. The proposed change is temporary and is annotated by a note in each TS that specifies the allowance expires on June 15, 2020.
As demonstrated in the enclosed evaluation, the proposed amendment does not involve a significant hazard consideration.
To accommodate the change, allowances in Unit 2 TS 3.8.7 and Unit 2 TS 3.7.1 Completion Times referring to spurious fire-induced modifications on Unit 1 will be deleted. These allowances expired on May 31, 2012 and are no longer valid.
There are planned transformer inspections for the upcoming Unit 1 refueling outage (20 16). Expedited NRC approval of this proposal would support any maintenance that may be required as a result of these inspections, specifically unanticipated replacement of the transformer. Baning any unforeseen equipment failures, Susquehanna Nuclear, LLC

Document Control Desk PLA-7384 is requesting an approval of the proposal by February 10, 2017, effective immediately upon approval, with implementation to be complete within 30 days.
Enclosures to this letter provide the Evaluation of these proposed changes to Unit 2 Technical Specification 3.8.7 and Unit 2 Technical Specification 3.7.1. Attachment 1 is the Technical Specification mark-up. Attachment 2 is a mark-up of the associated Technical Specification Bases changes, provided for infmmation only.
There are no regulatory commitments associated with the proposed changes.
The need for this change has been discussed with the SSES NRC Project Manager.
Additionally, the change has been reviewed by the SSES Plant Operations Review Committee (PORC) and by the Susquehanna Review Committee (SRC).
In accordance with 10 CFR 50.91(b), Susquehanna Nuclear, LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.
If you have any questions or require additional information, please contact Mr. Jason Jennings at (570) 542-3155.
I declare under penalty of perjury that the foregoing is true and conect.
Executed on:    ..JAtv.JftU-t Z.B! "2.o ' '
Sincerely, J. 7'   anke

==Enclosure:==

Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems- RHRSW System and UHS"

Document Control Desk PLA-7384 Attachments:  Proposed Changes to Unit 2 Technical Specification 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems - RRRSW System and UHS" (Mark-ups)  Proposed Change to Unit 2 Technical Specifications Bases 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification Bases 3.7.1, "Plant Systems- RRRSW System and UHS" (Mark-ups provided for Information Only)
Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Ms. T. E. Hood, NRC Project Manager Mr. M. Shields, PA DEP/BRP Electronic Copy:
J. R. Jennings N. E. Fairchild (SRC)
T. G. Wales (DBD)
NRAFiles                        GENPL5 DCS                             GENPL4

Enclosure to PLA-7384 Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7 "Electrical Power Systems -
Distribution Systems - Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems-RHRSW System and UHS"
: 1. DESCRIPTION
: 2. PROPOSED CHANGE
: 3. BACKGROUND
: 4. TECHNICAL ANALYSIS
: 5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria
: 6. ENVIRONMENTAL CONSIDERATIONS
: 7. REFERENCES

Enclosure to PLA-7384 Page 1 of30 SUSQUEHANNA NUCLEAR, LLC EVALUATION

==Subject:==
Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7 "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems- RHRSW System and UHS"
: 1. DESCRIPTION The proposed change affects Susquehanna Nuclear, LLC Unit 2 Technical Specifications (TS) 3.8.7 and 3.7.1. A temporary change to the Completion Time for Condition C ofTS 3.8.7 and to Condition A and B of3.7.1 is desired to allow replacement of Unit 1 480 V ESS Load Center Transformers. As demonstrated in Section 5.0, No Significant Hazards Consideration, these changes do not involve a significant impact to the safe operation ofthe facility.
: 2. PROPOSED CHANGE A mark-up of the proposed change to Unit 2 TS 3.8.7 is included in Attachment 1 of this submittal. In this attachment, the Completion Time of Condition C is revised to allow replacement of Unit 1 480 V ESS Load Center Transformers. Specifically, the Completion Time is increased to 7 days during Unit 1 transformer replacements.
A mark-up ofthe proposed change to Unit 2 TS 3.7.1 is also included in Attachment 1 ofthis submittal. In this attachment, the Completion Time of Condition A and B are revised to allow replacement of Unit 1 480 V ESS Load Center Transformers. Specifically, the Completion Time is increased to 7 days during replacement of Unit 1 480 V ESS Load Center Transformers 1X210 and 1X220.
All three (3) changes are modified by a note at the end of each table specifying that the extended completion time allowance will expire on June 15, 2020. Completion Time changes previously made to support fire induced spurious operation modifications will be removed since the allowance expired on May 31, 2012, and the proposed changes in this Amendment will take their place.
The Unit 2 TS Bases Section B 3.8.1 and Section B 3.7.1 have been revised based on these changes and marked up copies are shown in Attachment 2.

Enclosure to PLA-7384 Page 2 of30
: 3. BACKGROUND Reason for Changes The Unit I 480 V ESS transfmmers (IX2IO, IX220, IX230, and IX240) are approaching their qualified life of 40 years. Susquehanna desires to conservatively replace these transformers before they fail, using results from Doble testing to indicate the health of the equipment. The test results coupled with a life expectancy of 40 years form a reasonable basis for replacement.
The Unit 2 AC power distribution system at Susquehanna is patiially composed of Unit I AC distribution equipment. The Unit I transfonners subject of this proposal are part of that overlap and their operability will affect the operability of the Unit 2 AC distribution system.
Some Unit 1 transformers subject of this proposal affect the operability of the Unit 2 Residual Heat Removal Service Water system. As a result, changes to Technical Specifications that govern the Unit 2 AC distribution system and Unit 2 Residual Heat Removal Service Water system are requested.
Similar 480 V ESS LC transformers have been replaced on Unit 2 in the past. Those transfmmer replacements were completed in less than I20 hours (5 days); however, those replacements did not have the same circumstances (TS impacts, Engineering Change process) and therefore did not require any Completion Time extensions.
Overview of SSES AC Distribution System The SSES AC Distribution System transmits the output of the Unit I and Unit 2 Main Generators to offsite switchyards and distributes power from the unit auxiliary and offsite power supplies to onsite AC loads. These loads are required for stmiup, normal unit operation, shutdown, and emergency plant operations. Voltage levels of 500 kV, 230 kV, 24 kV, I3.8 kV, 4.16 kV, 480 V and 208/120 V are provided for a variety of reasons.
The electric power distribution system (See Figure I for simplified AC Distribution System) includes Class IE and non-Class IE AC Power Systems. The non-Class IE pmiion of the onsite power systems provides AC power for non-nuclear safety related loads. A limited number of non-safety related loads are impmiant to the power generating equipment integrity and are fed from the Class IE Distribution System. The non-Class IE AC Power System distributes power at I3.8 kV, 4.I6 kV, 480 V and 208/120 V, grouped into two symmetrical distribution systems stemming from I3.8 kV buses.
The Class IE AC Power System distributes power at 4.16 kV, 480 V, and 208/120 V to safety-related loads. The Class IE AC System is divided into four load group channels per unit (Channels A, B, C, and D). Any three out of four load groups has the capability of supplying the minimum required safety loads. The 4.I6 kV Bus of each Class IE Load Group Channel is provided with connections to two offsite power sources designated as preferred and alternate power supplies (Preferred and alternate power supplies up to the 4.I6 kV Buses of the Class lE Power System are considered as non-Class lE). Five (5) diesel generators are available to provide the required power supply if a total loss of the preferred and alternate supplies occurs.

Enclosure to PLA-7384 Page 3 of30 Four diesel generators shared between the two Units provide emergency power for one of the four Class IE AC load groups in each Unit when notmal sources are lost. Two divisionalized load groups are established from the four Class IE AC load groups (Division I is comprised of Channels A and C; Division II is comprised of Channels B and D) for those engineered safety feature loads which require one out of two load groups to meet design basis requirements. A spare diesel generator (E Diesel) can be manually aligned as a replacement for any one of the other four diesel generators.
The ESS buses designated load group channel is as follows for Unit I and Unit 2 respectively:
4.16 kV       LOAD          CONNECTING            480 VLOAD ESS BUS        GROUP        TRANSFORMER              CENTER IA20I           A               IX2IO               1B2IO IA203           c               IX230               1B230 IA202           B               IX220                IB220 IA204           D               IX240               IB240 .
2A20I           A               2X210               2B2IO 2A203           c               2X230               2B230 2A202           B               2X220               2B220 2A204           D               2X240               2B240 Each ESS Bus powers a 4.16 kV/480 V ESS Load Center (LC) transformer used to supply an essential480 V single-ended LC. The associated 4.16 kV ESS bus is the only source of power to the respective LC through the LC transfotmer.
The ESS LC supplies power to the individual 480 V loads and to Motor Control Centers (MCCs) that power instrument AC Distribution panels, I25 and 250 VDC Battery Chargers, and essential plant lighting.
The 250 VDC Battery Chargers on each unit are supplied by that unit' s 4.I6 kV ESS Bus.
The I25 VDC Battery Chargers can be supplied from either unit's 4.I6 kV ESS Bus.
The Offsite and On-Site Power systems are described in FSAR Sections 8.2 and 8.3 respectively.
Overview of Residual Heat Removal Service Water (RHRSW) System The RHRSW System is designed to provide cooling water for the Residual Heat Removal (RHR) System heat exchangers on both Units in the following a Design Basis Accident (DBA) or Seismic event.
The RHRSW System consists of two independent and redundant subsystems. Each subsystem has one header, one pump, a suction source, valves, piping, heat exchanger, and associated instrumentation. Either one of the two subsystems is capable of providing the required cooling

Enclosure to PLA-7384 Page 4 of30 capacity to maintain safe shutdown conditions. The two subsystems are separated such that failure of one subsystem will not affect the other.
One Unit 1 RHRSW subsystem and the associated (same division) Unit 2 RHRSW subsystem constitute a single RHRSW loop. The two RHRSW pumps in a loop can each be independently aligned to either Unit's heat exchanger. The RHRSW System is designed with sufficient redundancy so that no single active component failure can prevent it from achieving its design function. One such redundant feature is the use of a redundant manual isolation valve in each loop's bypass return line, which can be closed manually using a "reach-rod" through the top of the RHRSW Valve Vault missile shield without having to access the Valve Vault itself.
Cooling water is pumped by RHRSW pumps from the ultimate heat sink (UHS) through the tube side of the RHR heat exchangers. After removing heat from the RHR heat exchanger, the water is discharged to the spray pond (UHS) by way of the UHS return loops. The UHS return loops direct the return flow to a network of sprays that dissipate the heat to the atmosphere or directly to the UHS via a bypass header. The divisionalized UHS return loops are common to both units.
The ultimate heat sink system is composed of an approximately 25,000,000 gallon spray pond and associated piping and spray risers. Each UHS return loop contains a bypass line, a large spray array and a small spray array.
The purpose of the UHS is to provide the following functions for the RHRSW and Emergency Service Water (ESW) systems:
* Provide a suction source of water
* Provide a return flow path
* Maintain a water source at less than 97&deg;F using spray cooling The RHRSW system is described in FSAR Section 9.2.6, and the UHS is described in FSAR Section 9.2.7.
: 4. TECHNICAL ANALYSIS Alignment Pertinent to this Technical Specification Change Request This section discusses the proposed changes in context with the plant configuration in which the changes will apply. Specifically, the changes are only applicable when Unit 1 is in Mode 4 or 5 and when Unit 2 is not in Mode 4 or 5. Additionally, the increased Completion Times are only applicable to Unit 1 480 V ESS LC transformer replacement activities.
Over the course of the next several years, Doble testing on Unit 1 480 V ESS LC transformers will be conducted during Unit 1 refueling outages. If test results are not satisfactory, a pre-developed contingency plan to replace the affected transformer will be implemented if this license amendment is approved.

Enclosure to PLA-7384 Page 5 of30 Impacts to Unit 2 TS 3.8.7 "Electrical Power Systems- Distribution Systems-Operating" Removing any one of these four transformers from service with Unit 1 in Mode 4 or 5 and Unit 2 not in Mode 4 or 5 requires entry into Condition C ofTS 3.8.7 on Unit 2 for one Unit 1 AC electrical power distribution subsystem inoperable. The associated Completion Time for this Condition is 72 hours. Since replacing a single transformer takes approximately 120 hours, it is not possible to replace one of these transformers within the Completion Time currently specified in 3.8.7.
Impacts to Unit 2 TS 3.7.1 "Plant Systems- RHRSW System and UHS" Two ofthese transformers, specifically 1X210 and 1X220, have specific impacts to the RHRSW system. Removing either of these transformers from service with Unit 2 not in Mode 4 or 5 requires entry into Condition A and B of TS 3. 7.1 on Unit 2 for one required RHRSW valve inoperable and one required RHRSW subsystem inoperable. As seen in the Table below, the associated Completion Time for this Condition is 72 hours. Since replacing a single transformer takes approximately 120 hours, it is not possible to replace one of these transformers within the Completion Time currently specified in 3. 7 .I. The LCO duration for impacted equipment during all other Unit 1 transformer replacements is 7 days, which is the same as the increase requested forTS 3.8.7 and TS 3.7.1 in this proposed change. As a result, no changes to those TSs are requested.
Table A- Common Unit EQuipment Impacted Associated      Unit2 TS LCO Transformer                  Equipment Impacted Unit 2 TS          Duration 1X210                RHRSW A LOOP Return Valves                     3.7.1           72 Hours 1X220                RHRSW BLOOP Return Valves                      3.7.1           72 Hours 1X230                         SGTS Division 1                      3.6.4.3            7 Days CREOASS Division 1                       3.7.3             7Days Control Room Floor Cooling Division 1             3.7.4            30 Days 1X240                         SGTS Division 2                      3.6.4.3            7 Days CREOASS Division 2                       3.7.3             7 Days Control Room Floor Cooling Division 2              3.7.4            30 Days Regardless of which Unit 1-480 V ESS LC Transfmmer is out of service, the following items remain constant throughout the replacement evolution:
* All four (4) Unit 2-4.16 kV ESS Busses are operable.
* All four (4) Common Emergency Diesel Generators are operable.
* All 125 V DC and 250 V DC Battery Chargers, Batteries and Distribution Systems for Unit 2 are operable.
No equipment other than that listed in Table A is adversely affected by Unit 1 transfmmer replacements in this plant configuration.

Enclosure to PLA-7384 Page 6 of30 The impacts of specifically removing 1X21 0 or 1X220 from service are summarized in Table B below:
Table B- Im~acts of removing 1X210/1X220 transformers from service 1X210                     II                      1X220 Enter LCO 3. 7.1, Condition A on Unit 2 for one required valve inoperable Enter LCO 3.7.1, Condition Bon Unit 2 for one RHRSW subsystem inoperable Enter LCO 3.8.7, Condition Con Unit 2 for one Unit 1 AC electrical power distribution subsystem inoperable Division I (A) Large/Small spray network          Division II (B) Large/Small spray network valves will fail in normal position (closed)      valves will fail in normal position (closed)
HV01222A will fail in normal position (open) HV01222B will fail in normal position (open)
To ensure availability of the RHRSW system on Unit 2 during Unit 1 transformer replacements, the RHRSW Spray Pond Return Bypass Valve, HV01222A orB, on the out of service loop will remain open for the length of the evolution. Operator verification will ensure a return flow path to the spray pond is established, since the valves that form the normal flow path through the spray headers will be closed due to loss of power.
Since the RHRSW Pumps on Unit 1 and Unit 2 are not impacted by the Unit 1 transformer replacements, this return flow path would ensure the RHRSW system will transfer heat from its associated loads to the spray pond. This alignment does not affect the operability of the other Unit 2 RHRSW loop.
In this valve configuration, all flow through the affected loop will go directly to the Spray Pond as opposed to the Spray Array networks. Under Design Basis LOCA/LOOP Conditions, Spray Pond temperatures exceeding the design Spray Pond temperature associated with cooling both units could occur unless the normal flow path is restored (bypass valve closed, large spray in service). Factors contributing to elevated Spray Pond temperatures in the design basis analysis include:
* The use of conservative reactor decay heat values.
* The use of conservative meteorology.
* The use of conservative initial Spray Pond temperatures, i.e., Technical Specification Maximum Temperature.
The use of conservative values for these parameters is required in the design and licensing basis for SSES. A calculation using alternate values (not Design Basis values) to simulate other possible outcomes has been performed. Initial conditions and assumptions used in this calculation include:
* Both Units operating at 100% power.
* LOCA/LOOP conditions require shutdown of both Units o   LOCA/LOOP occurs on one Unit o   LOOP occurs on other Unit

Enclosure to PLA-7384 Page 7 of30
* The bypass valve on one RHRSW loop is assumed to fail open, while the large and small spray array valves on the same loop are closed.
* The large spray array valve on the other RHRSW loop is open and spraying. The bypass and small spray array valves on this loop are closed and remain closed.
      *  "Best Estimate" meteorology is used, e.g., the 30 worst consecutive days measured at the site synthesized into a single day and repeated for the full 30-day duration is used.
      *  "Best Estimate" decay heat is used, e.g., the 2 sigma conservatism of the decay heat input is removed.
      *  "Best Estimate" initial Spray Pond temperature is used, e.g., 80&deg; F + 0.5&deg; F, for instrument tolerance. The 80&deg; F initial Spray Pond temperature is based on the highest monthly average pond temperature.
Analysis using these inputs shows that additional time is available to close HV01222A orB before peak spray pond temperature is approached. With HV01222A orB open for 12 hours and the large spray array valve open on the opposite loop, the peak Spray Pond temperatures are approximately 4&deg; F below the value required (97&deg; F; FSAR Section 9.2.7) to safely shut down both units.
In this specific calculation, the initial spray pond temperature was assumed to be 80&deg;F.
Considering these transformer replacements will occur during Unit 1 refueling outages early in the year, a spray pond temperature of 80&deg;F is conservative. Data collected during operator rounds demonstrates Spray Pond temperatures do not approach 80&deg;F until the hottest months of the year (July-August). Additionally, Unit 1 will already be in a safe shutdown condition, which reduces the heat load placed on the RHRSW system.
As demonstrated above, in the event of a design basis accident, shutting down Unit 2 and continuing to cool Unit 1 through the open HV01222A orB valve is a low risk activity which does not pose any significant safety consequences. In the event of a design basis accident, operations personnel will manually close the bypass valve (HV01222A or B) and open the large spray array valve on the affected loop within 12 hours if spray pond temperatures approach 80&deg; F. Operations personnel monitor and record spray pond temperatures each shift to satisfy surveillance requirements. Operations personnel will be notified before transformer replacements commence to ensure spray pond temperature does not approach 80&deg; F.
Despite being functional, Condition A cannot be cleared until the UHS valves are operable.
Therefore, the Unit 2 RHRSW subsystem is administratively declared inoperable until Condition A can be exited. Since transformer replacements require approximately 120 hours to complete, it is requested that the Completion Time associated with Condition A and B of TS 3. 7.1 be extended to 7 days.
Prior to removing 1X21 0 or 1X220 from service, Surveillances which demonstrate proper valve operation will be satisfied. Successful completion of the surveillances will ensure that the RHRSW loops are operable prior to beginning transformer replacements . Additionally, it will ensure the opposite loop of RHRSW is Operable.

Enclosure to PLA-7384 Page 8 of30 Operation of the Unit 2 ECCS equipment supplied by the Unit 2 AC Distribution Subsystem is not affected by the scheduled Unit 1 480 V ESS LC Transformer replacement activities.
Unit 1-480 V ESS LC Transformer Replacement Sequence This section discusses the aggregate impact to the station if Doble testing indicates a transformer should be replaced. Numbered items will be performed in sequence. Bulleted items provide generic information, or information that will apply throughout the evolution unless otherwise specified.
* Only one transformer will be tested at a time
* Work will be conducted during a period in which no Core Alterations, Fuel Movements, or Operations with the Potential to Drain the Reactor Vessel (OPDRVs) are being conducted in order to preclude not meeting LCO 3.8.8 on Unit 1
* All Unit 2 buses will remain energized and operable
* Prior to commencing Doble test, the allocated replacement transformer will be on hand and fully qualified to act as an acceptable replacement (Megger!Doble testing)
* HV01222A orB (Spray Pond Bypass Valve) will be de-energized and ensured open by operations
* Operations will monitor spray pond temperature on a shiftly basis to ensure it does not approach 80 F.
* Satisfy the following surveillances:
o SR 3. 7 .1.3 -Verify position of RHRSW flow path valves every 31 days o SR 3.7.1.4- Verify RHRSW to UHS Bypass valves (HV01222A/B) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.5 -Verify Large Spray Array valves (HV01224Al/B1) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.6- Verify Small Spray Array valves (HV01224A2/B2) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.7- Verify the manual Small Spray Array Bypass valves (012287A/B) are capable of being opened and closed every 92 days Flow path for replacement:
: 1)      De-energize the 480 V ESS LC Transformer and associated load center
: 2)      Remove enclosure panels and transformer accessories (Prepare for rigging)
: 3)      De-terminate primary, secondary, and grounding of original transformer
: 4)      Rig out original transformer
: 5)      Rig in replacement transformer
: 6)      Weld, bolt, and paint replacement transformer
: 7)      Perform pre connection megger and doble testing of replacement transformer (verifies no damage during installation)
: 8)      Terminate primary, secondary, and grounding of replacement transformer.

Enclosure to PLA-7384 Page 9 of30
: 9)      Perform pre-energization megger and doble testing of replacement transformer
: 10)     Energize replacement transformer and validate phase rotation on secondary side of transformer. (Requires restoration ofthe 4.160 kV bus.)
: 11)     Perform additional Post Maintenance Testing.
: 12)     Reinstall enclosure panels and accessories.
: 13)     Restore associated load center and perform post modification testing.
Fire Protection System Status Requirements Table C lists common systems required to function during a unit shut down as a result of a fire. The listed systems have the potential to impact Unit 2 during a Unit 1 transformer replacement. The loss of ESW and RHRSW are the only two systems affected.
TableD lists specific Post-Fire Shutdown Functions ofESW and RHRSW affected by the loss of power during a Unit 1 transformer replacement, along with mitigating actions.
Table C- Impacts to Unit 2 Post-Fire Safe Shutdown (PFSS) Svstems System Impacted               Appli               Completion         Potential PFSS LCO                  Time               Impact?
ESW                                    3.7.2               7 days               Yes RHRSW                                  3.7.1             72 hours               Yes SBGT                                  3.6.4.3              7 days               No CREOAS                                 3.7.3               7 days               No t::
Control Room Floor Cooling             3.7.4              30 days               No Table 3- ESW & RHRSW Post-Fire Shutdown Function Imoact Assessment nction Potentially         Ri k M'f f          A f tpacted by Fire                s     I Iga IOn c Ions
* Treat the Diesel Driven Fire Pump as protected equipment to assure the availability of fire suppression.
ESWPumps
* Control combustibles and hot work under normal plant procedures to limit potential of plant fires ESSW Pumphouse Cooling
* Implement temporary cooling measures outlined in (Fans & Dampers)                    existing operating procedures ESW Diesel Generator
* These valves are normally open and are required open post Supply Valves (A-D)                 transient. Removal of their power source will leave them in the open position. Therefore, there is no impact to these ESW Diesel Generator                valves during Unit 1 480 V ESS LC transformer Retum Valves (A-D)                  replacements.

Enclosure to PLA-7384 Page 10 of30 RHRSW Loop A Return to         These valves in the common ESW-RHRSW return line to the Spray Pond Valves              Spray Pond utilize a power supply path from 1X21 0.
* Treat the Diesel Driven Fire Pump as protected equipment to assure the availability of fire suppression.
* Control combustibles and hot work under normal plant procedures to limit potential of plant fires Protected Equipment Licensed operators have reviewed the list of affected equipment for these evolutions in accordance with the station's protected equipment program. Subsequently, a list of protected equipment was developed and can be viewed in Table 2 at the end of this document.
: 5. REGULATORY SAFETY ANALYSIS 5.1   No Significant Hazards Consideration This "No Significant Hazards Consideration" evaluates the following changes to the Technical Specifications:
: a. The Unit 2 TS 3.8.7, Condition C, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for a Unit 1 480 V subsystem that is de-energized and removed from service.
: b. The Unit 2 TS 3.7.1, Condition A, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for an Inoperable loop of UHS spray anay and spray array bypass valves.
: c. The Unit 2 TS 3.7.1, Condition B, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for one (1) Unit 2 RHRSW subsystem Inoperable.
All 3 changes are annotated by a note specifying the increased Completion Time only applies to Unit 1 480 V ESS LC transformer replacements and that the extension expires on June 15, 2020.

Enclosure to PLA-7384 Page 11 of30
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The temporary changes to the completion times forTS 3.8.7, Condition C and TS 3.7.1, Conditions A and B are necessary to implement plant changes, which replace the Unit 1 -
480 V ESS LC Transformers 1X210 and 1X220 in order to mitigate the loss of the transformer due to failure. The temporary change to the completion time forTS 3.8.7, Condition C is also necessary to implement plant changes, which replace the Unit 1 - 480 V ESS LC Transformers 1X230 and 1X240 in order to mitigate the loss of the transformer due to failure. These replacements decrease the probability of a transformer failure. The current assumptions in the safety analysis regarding accident initiators and mitigation of accidents are unaffected by these changes. No SSC failure modes or mechanisms are being introduced, and the likelihood of previously analyzed failures remains unchanged.
The proposed change requests the Completion Time to restore a Unit 2 RHRSW subsystem be extended to 7 days in order to replace Unit 1 transformers 1X210 and 1X220. The extended Completion Times forTS 3.7.1 Conditions A and Bare only applicable when transformers 1X21 0 or 1X220 are out of service with the intent of replacing the transformer.
During the replacements, the affected Unit 2 RHRSW subsystem will remain functional while the other subsystem of Unit 2 RHRSW will remain Operable. Operator action required to restore full capability of cooling provided by the Ultimate Heat Sink will only consist of manually operating two (2) valves; the Large Spray Array and the UHS bypass.
This action can easily be completed within several hours and would restore full cooling to the RHRSW system.
Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed changes involve the increase of TS Completion Times to allow replacement of four (4) Unit 1-480 V ESS LC Transfmmers. New transformers will be installed but will not be operated in a new or different manner. There are no setpoints at which protective or mitigative actions are initiated affected by this change. These changes do not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No alterations to procedures that ensure the plant remains within analyzed limits are being proposed, and no major changes are being made to procedures relied upon during off-normal events as described in the FSAR.

Enclosure to PLA-7384 Page 12 of30 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response: No Operational safety margin is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The proposed changes are acceptable because the Completion Time extensions allow replacement of the Unit 1-480 V ESS LC Transformers, equipment essential to safe plant operation, while ensuring safety related functions of affected equipment are maintained.
With the RHRSW Spray Pond Return Bypass Valves on the out of service loop electrically de-powered in the open position, a return flow path will be established. Since the RHRSW Pumps on Unit 2 are not impacted by the transformers outages, the affected RHRSW Loop on Unit 2 will be capable of providing cooling. This configuration will continue to provide the margin of safety assumed by the safety analysis, although the affected RHRSW loop will be administratively declared Inoperable.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Susquehanna Nuclear, LLC concludes that the proposed changes do not involve a significant hazards consideration under the standards set f01ih in 10 CFR 50.92(c),
and accordingly, a finding of no significant hazards consideration is justified.
5.2   Applicable Regulat01y Requirements/Criteria SSES FSAR Sections 3.1 and 3.13 provide detailed discussion ofSSES compliance with the applicable regulatory requirements and guidance.
The proposed TS amendment:
(a)   Does not result in any change in the qualifications of any component; and (b)   Does not result in the reclassification of any component's status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
Susquehanna conformance with the applicable General Design Criteria (GDC) related to the proposed Unit 2 TS 3.8.7 change is provided as follows:
GDC 5- Sharing ofStructures, Systems and Components Offsite Power Supplies- The two preferred offsite power supplies are shared by both units 1 and 2. The capacity of each offsite power supply is sufficient to operate the Engineered Safety Features (ESF) of one unit and safe shutdown of the other unit.
Additional details are provided in FSAR Section 8.2.

Enclosure to PLA-7384 Page 13 of30 Diesel Generators - The Diesel Generators are shared systems impottant to safety. Loss of one of the four aligned diesel generators will not impair the capability to safely shutdown both units, since this can be done with three diesel generators. Additional details are provided in FSAR Section 8.3.1.4.
Unit 1 AC Distribution System - The Unit 1 AC Distribution system is a shared system between both units 1 and 2 since the common equipment (Emergency Service Water, RHR Service Water, Standby Gas Treatment System including the Reactor Recirculation Fans, Control Structure HVAC, and Control Room Floor Cooling) is energized only from the Unit 1 AC Distribution System. The capacity of the Unit 1 AC Distribution System is sufficient to operate the engineered safety features on one unit and the safe shutdown loads of the other unit.
GDC 17 - Electric Power Systems Two offsite power transmission systems and four onsite standby diesel generators (A, B, C and D) with their associated battery systems are provided. Either of the two offsite transmission power systems or any three of the four onsite standby diesel generator systems have sufficient capability to operate safety related equipment for cooling the reactor core and maintaining primary containment integrity and other vital functions in the event of a postulated accident in one unit with a safe shutdown of the other unit.
Additionally, a fifth diesel generator 'E' with its associated battery system is provided as a replacement, and has the capability of supplying the emergency loading for any one of the other four diesel generators (A, B, Cor D). Diesel generator 'E' must be manually aligned to replace any one of the other four diesel generators in the event of a failure.
The two independent offsite power systems supply electric power to the onsite power distribution: system via the 230 kV transmission grid. Each of the offsite power sources is supplied from a transmission line which terminates in switchyards (or Substations) not common to the other transmission line. The two transmission lines are on separate rights-of-way. These two transmission circuits are physically independent and are designed to minimize the possibility of their simultaneous failure under operating and postulated accident and environment conditions.
Each offsite power source can supply all Engineered Safety Feature (ESF) buses through the associated transformers . Power is available to the ESF buses from their preferred offsite power source during normal operation and from the alternate offsite power source if the preferred power is unavailable. Each diesel generator (A, B, C, or D) supplies standby power to one of the four ESF buses in each unit. Loss of both offsite power sources to an ESF bus results in automatic stmting and connection of the associated diesel generator (A, B, C, or D) within 10 seconds. Loads are progressively and sequentially added to avoid generator instabilities.
There are four independent AC load groups provided to assure independence and redundancy of equipment function. These meet the safety requirements assuming a

Enclosure to PLA-73 84 Page 14 of30 single failure since any three of the four load groups have sufficient capacity to supply the minimum loads required to safely shut down the unit. Independent routing of the preferred and alternate offsite power source circuits to the ESF buses are provided to meet the single failure safety requirements.
Additional discussion and details are provided in FSAR Sections 8.2 and 8.3.
Based on compliance with the General Design Criteria 5 and 17 above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
: 6. ENVIRONMENTAL CONSIDERATION 10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions, which are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. Susquehanna Nuclear, LLC has evaluated the proposed change and has determined that the proposed change meets the eligibility criteria for categorical exclusion set fmih in 10 CFR 51.22(c)(9). Accordingly, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:
As demonstrated in the "No Significant Hazards Consideration" evaluation, the proposed amendment does not involve a significant hazards consideration.
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.
There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

Enclosure to PLA-7384 Page 15 of30
: 7. REFERENCES
: 1. Susquehanna FSAR Section 3.1, Conformance with NRC General Design Criteria
: 2. Susquehanna FSAR Section 3.13, Compliance with NRC Regulatory Guides
: 3. Susquehanna FSAR Section 8.1, Introduction
: 4. Susquehanna FSAR Section 8.2, Offsite Power System
: 5. Susquehanna FSAR Section 8.3, On Site Power Systems
: 6. Susquehanna FSAR Section 9 .2.6, Residual Heat Removal Service Water System
: 7. Susquehanna FSAR Section 9.2.7, Ultimate Heat Sink (UHS)
: 8. P&ID Drawing M-112, Unit 1 RHR Service Water System, Sheets 1 & 2
: 9. P&ID Drawing M-2112, Unit 2 RHR Service Water System, Sheet 1

Enclosure to PLA-7384 Page 16of30 TABLEt Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description     Applicable                           Comments Source                                             Unit2 LCO/TRO Motor       HV-01224A1   Residual Heat Removal     LCO 3.6.2.3   The loss of power to the spray pond return valves Control     HV-01224A2   Service Water (RHRSW)     LCO 3.6.2.4   results in the following:
Center      HV-01222A    Spray Pond Return Valves  LCO 3.5 .1 (MCC)                                              LCO 3.7.1
* One loop ofRHRSW inoperable due to loss OB517                                              LCO 3.7.2              offlow path (LCOs 3.7.1 and 3.7.2-72 hour Technical              completion time- part of Technical Requirements           Specification amendment request) for Operation
* One subsystem ofRHR suppression pool (TRO) 3.8.6            cooling inoperable due to the loss ofRHRSW to the RHR heat exchanger. (LCO 3.6.2.3- 7 day completion time)
* One subsystem ofRHR suppression pool spray inoperable due to the loss ofRHRSW to the RHR heat exchanger. (LCO 3.6.2.4- 7 day completion time)
* One RHR pump inoperable due to the loss of ESW cooling to its motor. (LCO 3.5.1 - 7 day completion time)
* One Unit 1 Emergency Switchgear Cooling subsystem inoperable due to the loss of Control Structure Chilled Water subsystem.
(TRO 3.8.6- 30 day completion time)

Enclosure to PLA-73 84 Page 17 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description     Applicable                            Comments Source                                             Unit2 LCO/TRO MCC         OV521A       Engineered Safeguard      TRO 3.7.6      Due to the loss of this MCC, 4 fans (2 ESSW fans OB517       OV521C       Service Water (ESSW)      LCO 3.7.2      and 2 RHRSW fan) are inoperable. This TRO Pumphouse Fan                            requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable. Two ESW pump are declared inoperable and LCO 3.7.2 is entered. The completion time for the restoration of2 ESW pumps is 7 days.
MCC         1V506A       RHRSW Pump Fan            TRO 3.7.6      Due to the loss of this MCC, 4 fans (2 ESSW fans OB517       2V506A                                 LCO 3.7.1      and 2 RHRSW fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable. One RHRSW pump would be declared inoperable and LCO 3.7.1 is entered. The completion time for the restoration of 1 RHRSW pump is 72 hours. The extension of this time is the subject of the Tech Spec amendment request.

Enclosure to PLA-7384 Page 18 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description       Applicable                             Comments Source                                               Unit2 LCO/TRO MCC         HV-08693A    Control Structure Chilled   LCO 3.7.3       With the loss of power to the Control Structure 1B216                    Water ESW Control Valve     LCO 3.7.4       Chilled Water ESW Control Valve, the following are TRO 3.7.9       declared inoperable:
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC         OV201A       Reactor Building            LCO 3.6.4.3     One Standby Gas Treatment subsystem is inoperable 1B217                    Recirculation Fan                           due to the loss of the Reactor Building Recirculation Fan. (LCO 3.6.4.3- 7-day completion time) 1Y216       Various      Instrumentation for         LCO 3.6.4.3     The loss of power to the 1Y216 panel results in the various systems and                         loss of instrumentation and control to one SOTS control to dampers,                         subsystem (LCO 3.6.4.3 day completion time),
including the systems                       one CREOASS subsystem.
described above

Attachment 1 to PLA-7384 Page 19 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component        Applicable     Comments Source                 Description      Unit2 LCOITRO MCC       HV-01224Bl   RHRSW Spray      LCO 3.6.2.3    The loss of power to the spray pond return valves results in the OB527     HV-01224B2   Pond Return      LCO 3.6.2.4    following:
HV-01222B    Valves           LCO 3.5.1 LCO 3.7.1
* One loop ofRHRSW inoperable due to loss of flow path LCO 3.7.2               (LCOs 3.7.1 and 3.7.2- 72 hour completion time- part of TRO 3.8.6               Technical Specification amendment request)
* One subsystem ofRHR suppression pool cooling inoperable due to the loss ofRHRSW to the RHR heat I
exchanger. (LCO 3.6.2.3 - 7 day completion time)
* One subsystem of RHR suppression pool spray inoperable due to the loss ofRHRSW to the RHR heat exchanger.
(LCO 3.6.2.4- 7 day completion time)
* One RHR pump inoperable due to the loss ofESW cooling to its motor. (LCO 3.5.1 - 7 day completion time)
* One Unit 1 Emergency Switchgear Cooling subsystem due to the loss of Control Structure Chilled Water subsystem.
(TRO 3.8.6- 30 day completion time)
MCC       OV521B       ESSW Pumphouse   TRO 3.7.6       Due to the loss of this MCC, 4 fans (2 ESSW fans and 2 RHRSW OB527     OV521D       Fan                              fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable.
Two ESW pump are declared inoperable and LCO 3.7.2 is entered.
The completion time for the restoration of 2 ESW pumps is 7 days.

Attachment 1 to PLA-7384 Page 20 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component         Applicable    Comments Source                 Description       Unit2 LCO/TRO MCC       1V506B       RHRSWPump         TRO 3.7.6     Due to the loss of this MCC, 4 fans (2 ESSW fans and 2 RHRSW OB527     2V506B       Fan               LCO 3.7.1     fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable.
One RHRSW pump would be declared inoperable and LCO 3.7.1 is entered. The completion time for the restoration of 1 RHRSW pump is 72 hours. The extension of this time is the subject of the Tech Spec amendment request.
MCC       HV-08693B    Control Structure LCO 3.7.3      With the loss of power to the Control Structure Chilled Water ESW 1B226                  Chilled Water     LCO 3.7.4      Control Valve, the following are declared inoperable:
ESW Control       TRO 3.7.9 Valve
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem. (LCO 3.7.4-30 day completion time)
* One Control Structure HVAC subsystem. (TRO 3.7.9- 30 day completion time)
MCC       OV201B       Reactor Building  LCO 3.6.4.3    One Standby Gas Treatment subsystem is inoperable due to the 1B227                  Recirculation Fan                loss of the Reactor Building Recirculation Fan. (LCO 3.6.4.3-7 day completion time)

Attachment 1 to PLA-7384 Page21 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component           Applicable     Comments Source                 Description         Unit2 LCOITRO 1Y226     Various      Instrumentation     LCO 3.6.4.3    The loss of power to the 1Y226 panel results in the loss of and damper                         instrumentation and control to one SGTS subsystem (LCO 3.6.4.3 -
control for various                7-day completion time.
systems, including the systems described above

Attachment 1 to PLA-73 84 Page 22 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO I
Implications Power       Component#   Component Description        Applicable   Comments Source                                                Unit2 LCO/TRO MCC 1B230   OE145A       Control Structure A/C Unit   LCO 3.7.3    With the loss of power to the Control Structure NC A Heater                     LCO 3.7.4    Unit A Heater, the following are declared inoperable:
TRO 3.7.9
* One CREOASS subsystem. (LCO 3.7.3-7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC OB136   SGTS                                                   The loss of power to MCC OB 136 results in one OV109A       Fan                          LCO  3.6.4.3 SGTS subsystem (LCO 3.6.4.3 - 7 day completion OC886A       Control Panel                LCO  3.6.4.3 time) and one Control Structure HVAC subsystem OV118A       Room Exchange Fan            TRO  3.7.9   (LCO 3.7.9- 30 day completion time) being declared OV144A       Equipment Room Fan           TRO  3.7.9   inoperable.
OE144A       Equipment Room Heating       TRO  3.7.9 Coil MCC OB136   cs                                                     With the loss of power to MCC OB136, the following OVIOIA       CREOASS Fan                  LCO  3.7.3   are declared inoperable:
OP171A       Chilled Water System         LCO  3.7.3 (CWS) Emergency              LCO  3.7.4
* One CREOASS subsystem. (LCO 3.7.3 -7 Condenser Water Pump         TRO  3.7.9           day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)

Attachment 1 to PLA-7384 Page 23 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description      Applicable     Comments Source                                              Unit2 LCO/TRO OP162A       Chilled Water Pump         LCO  3.7.3 LCO  3.7.4 TRO  3.7.9 OP122A       Chiller OK112A Oil Pump    LCO  3.7.3 i
OE143A       Control Room Emergency Fresh Air Heating Coil OV103A       Heating & Ventilation      LCO 3.7.3      With the loss of power to MCC OB 136, the following (H&V) System Fan           LCO 3.7.4      are declared inoperable:
TRO 3.7.9 OV117A       Control Room Ceiling Fan   LCO 3.7.3
* One CREOASS subsystem. (LCO 3.7.3- 7 LCO 3.7.4              day completion time)
TRO 3.7.9
* One Control Room Floor Cooling subsystem .
OV115A       Computer Room Ceiling      LCO 3.7.3              (LCO 3.7.4- 30 day completion time)
Fan                        LCO 3.7.4
* One Control Structure HVAC subsystem .
TRO 3.7.9              (TRO 3.7.9- 30 day completion time)
OV116A       Battery Room Exhaust Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9

Attachment 1 to PLA -73 84 Page 24 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description         Applicable   Comments Source                                                 Unit2 LCO/TRO 1Y236       Various      120 VAC instrument power      LCO  3.6.4.3 The loss of power to the 1Y23 6 panel results in the to Instrumentation for        LCO  3.3.7.1 loss of instrumentation and control to :
various systems and control   LCO  3.7.3
* One SOTS subsystem (LCO 3.6.4.3- 7 day power to dampers, including   LCO  3.7.4           completion time),
the systems described above   TRO  3.7.9
* One CREOASS subsystem (LCO 3.7.3- 7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
* Instrumentation   for CREOASS, which is already out of service. (LCO 3.3 .7.1 -declare CREOASS inoperable)

Attachment 1 to PLA-7384 Page 25 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description        Applicable    Comments Source                                                 Unit2 LCO/TRO Load Center OE145B        Control Structure A/C Unit   LCO 3.7.3     With the loss of power to the Control Structure A/C 1B240                     B Heater                     LCO 3.7.4     Unit B Heater, the following are declared inoperable:
I TRO 3.7.9
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HV AC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC OB146   SGTS OV109B        Fan                          LCO  3.6.4.3  The loss of power to MCC OB146 results in one OC886B        Control Panel                LCO  3.6.4.3  SGTS subsystem (LCO 3.6.4.3 - 7 day completion OV118B        Room Exchange Fan            TRO  3.7.9    time), one Control Structure HVAC subsystem (LCO OV144B        Equipment Room Fan           TRO  3.7.9    3.7.9- 30 day completion time) being declared OE144B        Equipment Room Heating       TRO  3.7.9    inoperable, and one vent stack radiation monitor Coil                         TRO  3.3.4    (TRO 3.11.2.6- 30-day completion time to restore the OP560         Stack Vent Vacuum Pump       TRO  3.11.2.6 monitor) inoperable.
MCC OB146   cs OV101B        CREOASS Fan                  LCO 3.7.3     With the loss of power to MCC OB146, the following OP171B        CWS Emergency                              are declared inoperable:
Condenser Water Pump         LCO 3.7.3 LCO 3.7.4
* One CREOASS subsystem. (LCO 3.7.3 -7 TRO 3.7.9             day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)

Attachment 1 to PLA-7384 Page 26 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description      Applicable    Comments Source                                               Unit2 LCO/TRO MCC OB146   OP162B        Chilled Water Pump         TRO  3.7.9
* One Control Structure HVAC subsystem .
(Continued)                                          LCO  3.7.3         (TRO 3.7.9- 30 day completion time)
LCO  3.7.4 OP122B        Chiller OK 112B Oil Pump   TRO  3.7.9 I
LCO  3.7.3 LCO  3.7.4 OE143B        Control Room Emergency     TRO  3.7.9 Fresh Air Heating Coil     LCO  3.7.3 OV103B        H&V System Fan             LCO 3.7.3 LCO 3.7.4 TRO 3.7.9 OV117B        Control Room Ceiling Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9 OV115B        Computer Room Ceiling      LCO 3.7.3 Fan                        LCO 3.7.4 TRO 3.7.9 OV116B        Battery Room Exhaust Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9

Attachment 1 to PLA-7384 Page 27 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description    Applicable      Comments Source                                             Unit2 LCO/TRO 1Y246       Various       120 VAC instrument       LCO  3.6.4.3    The loss of power to the 1Y246 panel results in the power to Instrumentation LCO  3.3.7.1    loss of instrumentation and control to:
for various systems,     LCO  3.7.3
* One SGTS subsystem (LCO 3.6.4.3 - 7 day including the systems    LCO  3.7.4              completion time),
described above          TRO  3.7.9
* One  CREOASS subsystem (LCO 3.7.3 - 7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4 - 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
I
* Instrumentation for CREOASS, which is already out of service. (LCO 3.3. 7.1 - declare CREOASS inoperable)

Enclosure to PLA-7384 Page 28 of30 TABLE2 PROTECTED EQUIPMENT Unit 1- 480 V ESS LC Transformer 1X210 Outage 1B, 1C and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1B and 1D 125 V DC Batteries 1B and 1D 250 V DC Batteries 2B and 2D 125 V DC Batteries 2B and 2D 250 V DC Batteries 2B and 2D 4 kV Buses and Load Centers U2 BLoop RHR U2 B Loop RHRSW Diesel Driven Fire Pump B Division ESW Pumphouse Unit 1 - 480 V ESS LC Transformer 1X220 Outage 1A, 1C and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1A and 1C 125 V DC Batteries 1A and lC 250 V DC Batteries 2A and 2C 125 V DC Batteries 2A and 2C 250 V DC Batteries 2A and 2C 4 kV Buses and Load Centers U2ALoopRHR U2ARHRSW Diesel Driven Fire Pump A Division ESW Pumphouse

Enclosure to PLA-7384 Page 29 of30 TABLE 2 (Continued)
Unit 1 - 480 V ESS LC Transformer 1X230 Outage 1A, 1B and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1B and 1D 125 V DC Batteries lB and lD 250 V DC Batteries 2B and 2D 125 V DC Batteries 2B and 2D 250 V DC Batteries 2B and 2D 4 kV Buses and Load Centers U2BLoopRHR U2BRHRSW Diesel Driven Fire Pump B Division ESW Pumphouse Unit 1 - 480 V ESS LC Transformer 1X240 Outage 1A, 1B and 1C 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) lA and 1C 125 V DC Batteries 1A and 1C 250 V DC Batteries 2A and 2C 125 V DC Batteries 2A and 2C 250 V DC Batteries 2A and 2C 4 kV Buses and Load Centers U2ALoopRHR U2ARHRSW Diesel Driven Fire Pump A Division ESW Pumphouse

Enclosure to PLA-7384 Page 30 of30 SUNBURY#2 STANTON #21    STANTON #1 WESCOSVILLE                                                                       MONTOUR         JENKINS SUNBURY        HARWOOD 500 kV/230 kV TIE LINE E. PALM T- 21                                                               '    230KV 500KV      <I I L.:>U IW      I                                           SWYD SWYD 230KV 24 KV 1R106 S/U  - - 230KV                                                                                                               (HSGS)
T~~~ST           13.8KV                                 2G101                                  1G101 230KV ~ S/U OX104                                                                                                  13.8 KV           TRANS T-10
                                                                                                                    ~'""("" OX103 01    ) S/U BUS                                                                                    S/U BUS   1_) _
f      20                                                                                          10    T   01 OA104 lVI                        OA10502                           V~IVV TIE BUS                         OX501
                                               -*J'.o.,_-r*r-                       ~  4.16KV~
I  -llj'"fflll-
* a T-201 ESS201 OX203 T-211                                                                                                                                   OX207 ESS211 OX213 OA510
                                                                                                     @                          OPEN OG501E                     CKT BKR OG5018 TWO UNIT OPERATIONAL C) OG501C                                                        LINEUP SHOWN Figure 1 SIMPLIFIED SSES AC DISTRIBUTION SYSTEM

Attachment 1 to PLA-7384 Susquehanna Nuclear, LLC Proposed Changes to Unit 2 Technical Specification 3.8. 7 "Electrical Power Systems -
Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems-RHRSW System and UHS" (Markups)

                                                                                                                                             ~Rev . 4 Distribution Systems-Operating 3.8.7 3.8                  ELECTRICAL POWER SYSTEMS 3.8 .7               Distribution Systems-Operating LCO 3.8.7            The electrical power distribution subsystems in Table 3.8.7-1 shall be OPERABLE.
APPLICABILITY:                   MODES 1, 2, and 3.
ACTIONS CONDITION                                             REQUIRED ACTION                                       COMPLETION TIME A.   --------------NOTE---------------                       ----------------Nate----------------
Not applicable to DG E DC Bus                          Enter applicable Conditions and OD597                                                   Required Actions of LCO 3.8.4,
      -------------------------------------                   "DC Sources- Operating, " for DC source(s) made inoperable One or more Unit 2 AC electrical                        by inoperable power distribution power distribution subsystems                           subsystem(s) .
inoperable.                                             ----------------------------------------
A.1     Restore Unit 2 AC electrical power                         8 hours distribution subsystem(s) to OPERABLE status.                                                    AND 16 hours from discovery of failure to meet LCO 3.8.7 except for Condition F or G
B.   ---------------N0 TE --------------             B.1     Restore Unit 2 DC electrical power                         2 hours Not applicable to DG E DC Bus                           distribution subsystem(s) to OPERABLE OD597                                                   status.                                                   AND One or more Unit 2 DC electrical                                                                                   16 hours from discovery of power distribution subsystems                                                                                     failure to meet LCO 3.8.7 inoperable.                                                                                                       except for Condition F or G
C. One Unit 1 AC electrical power                  C.1     Restore Unit 1 AC electrical power                        72 hours distribution subsystem inoperable.                     distribution subsystem to OPERABLE status.                                                    OR Q&sect; flfill.lFS lMFil'l~ tf1e il'lstallatiel'l ef: tf1e mMitifi)le fiFe il'lll.llel SfilMFil<lS lfileFatili'IS F11filJiHlEltifili'IS il'l Ul'lit 1 ~ 7 days during the replacement of 480 V ESS Load Center Transformers in Unit 1(ll (continued)
( ) Uis temJileFEll)' 24 f1eMr lSFI1filletiel'l time eHtel'lsiel'l is Elfilfillilaele 1MFil'l~ P1&#xa3;Q mslifisatisl'!s te all Ul'lit 1 4.1SIN 1
eMses, "'flile ''l'lit 1 is il'l P101J~&#xa3; 4 sF&sect;, al'!1 will eHfiliFe el'l Ma~* ~1, 2Q12. This temporary 7-day completion time is applicable during the replacement of all Unit 1 480 V ESS Load Center Transformers, while Unit 1 is in MODES 4 or 5, and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                        TS I 3.8-44                                   Amendment 4M, 4-Qa, 208, 238

                                                                                                                                              ~Rev.~
RHRSW System and UHS 3.7.1 3.7                   PLANT SYSTEMS 3.7.1                 Residual Heat Removal Service Water (RHRSW) System and the Ultimate Heat Sink (UHS)
LCO 3.7.1            Two RHRSW subsystems and the UHS shall be OPERABLE.
APPLICABILITY:                     MODES 1, 2, and 3.
ACTIONS
                 -------------------------------------------------------------NOTE----------------------------------------------------------
Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown ," for RHR shutdown cooling made inoperable by RHRSW System.
CONDITION                                               REQUIRED ACTION                                   COMPLETION TIME A.    ---------------N OlE---------------                 A.1       Declare the associated RHRSW                        Immediately Separate Condition entry is                                  subsystems inoperable.
allowed for each valve.
One valve in Table 3.7.1-1                          A.2       Establish an open flow path to the                  8 hours inoperable.                                                   UHS.
OR One valve in Table 3.7.1-2                          A.3       Restore the inoperable valve(s) to                  8 hours from the discovery inoperable.                                                   OPERABLE status.                                    of an inoperable RHRSW subsystem in the opposite loop from the inoperable valve(s)
One valve in Table 3.7.1-3 inoperable.
72 hours Any combination of valves in Table 3.7.1-1, Table 3.7.1-2, or Table 3.7.1-3 in the same return loop                                                                                   Q@ 19elJn; SllFiFl~ ll9l inoperable.                                                                                                       iFlstallatieFl eftl9e FFllllli13ll fiFl iFlSll66S Si3llFillJS li3lFfillilFlS FFllSifi6rillieFlS iFl
                                                                                                                       ~141 7 days during the replacement of 480 V ESS Load Center Transformers 1X210 and 1X220 in Unit 1(1)
_(continued) 1
( ) U~el9 6lFFl~lstiel9 sftt;te M!ilO Fl'!e1ifi6Eitiel9s el9 t!;ts U19it 1 1/\2Q1 EII911/\2Q2 4.1@ leV Bllsss, t!;tis tsFl'!~emry     Sltsl9siel9 is 19e le19ssr El~~liE>EIBie 8191 will Sl~irs el9 MEiy ~1, 2Q12. Upon completion of the replacement of 480 V ESS Load Center Transformers 1X21 0 and 1X220 in Unit 1, this temporary extension is no longer applicable and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                                TS I 3 .7-1                               Amendment .:te-1-, W, 224 , 238

                                                                                                                  ~Rev.~
RHRSW System and UHS 3.7.1 ACTIONS (continued)
CONDITION                                     REQUIRED ACTION                        COMPLETION TIME B. One Unit 2 RHRSW subsystem                B.1   Restore the Unit 2 RHRSW subsystem        72 hours from discovery inoperable.                                     to OPERABLE status.                       of the associated Unit 1 RHRSW subsystem inoperable OR 9&sect; IHlEI~s Je~~iFl&sect; t~;te iFlstallatieFl ef t~;te Fl1Witi~le fi~e iFlJwseJ s~e~~iews
                                                                                                 @~l~Olti@FlS Fl1@Jifi6Elti9FlS iFl UFlit 1 t4t 7 days during the replacement of 480 V ESS Load Center Transformers 1X21 0 and 1X220 in Unit 1(1)
AND 7 days C. Both Unit 2 RHRSW subsystems              C.1    Restore one Unit 2 RHRSW subsystem        8 hours from discovery of inoperable .                                     to OPERABLE status.                       one Unit 1 RHRSW subsystem not capable of supporting associated Unit2 RHRSW subsystem AND 72 hours D. Required Action and associated            D.1    Be in MODE 3.                             12 hours Completion Time not met.
AND OR D.2    Be in MODE 4.                            36 hours UHS inoperable.
1
( ) UJ39R S9FflJ3IetisR sf tlcle Mli)Q FflSlifisatiSRS SR tlcle 'JRit 1 1!\201 GIR1 1A2Q2 4.19 kV ewses, tiel is teFflJ3SFsFY El)(tSRsisR is Rs lsRser sJ3J3Iisaele sR1 will El)(J3ire sR May ~1, 2012. Upon completion of the replacement of 480 V ESS Load Center Transformers 1X210 and 1X220 in Unit 1, this temporary extension is no longer applicable and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                   TS I 3.7-2                             Amendment .:t-a-:t, .:t-aG, 180 238

Attachment 2 to PLA-7384 Susquehanna Nuclear, LLC Proposed Change to Unit 2 Technical Specification Bases 3.8. 7 "Electrical Power Systems -
Distribution Systems- Operating" and Unit 2 Technical Specification Bases 3.7.1, "Plant Systems - RHRSW System and UHS" (Markups provided for Information Only)

                                                                                                           ~Rev:-4 Distribution Systems-Operating B 3.8.7 BASES ACTIONS          QJ. (continued)
Time of 72 hours is consistent with the Completion Times associated with LCOs for the Unit 2 and common equipment potentially affected by loss of a Unit 1 AC electrical power subsystem .
Tt;te Ce~~letieF1 Ti~e     !;!as l:leef:l l)(teF11e1 te Q@ l;te~e~rs iF1 er1er te se~~lete tt;te
                 ~e1ifisatieF1S iF1 UF1it 1 assesiate1 wit!;! tt;te M~e~lti~le P:ire IF11~e~se1 ~~~e~rie~e~s O~erstief:ls iss~e~e. Tt;tis is a te~~ersry l)deF1sieF1 sf tFie Ce~~letieF1 Ti~e. U~ef:l 1l~~letieF1 eftFie M~O ~e1ifisatieF1s SF1 all fe~e~r UF1it 1 4.1@ I<V l:l~e~ses, tFiis te~~emry e)(teF1sieF1 is F19 IJF1~er a~~lisal:lle af:l1 will @)(~ire JF1 Ma~* ~ 1, 2012.
The Completion Time has been extended to 7 days in order to complete the replacement of the four (4) Unit 1 480 V ESS Load Center Transformers. This is a temporary extension of the Completion Time. Upon completion of the transformer replacement, this temporary extension is no longer applicable and will expire on June 15, 2020.
With two required Unit 1 AC buses, load centers, motor control centers, or distribution panels inoperable for the performance of Unit 1 SR 3.8.1.19 but not resulting in a loss of safety function, the remaining AC electrical power distribution subsystems are 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 failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours.
E.1and E.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
If Diesel Generator E is not aligned to the Class 1E distribution system, the only supported safety function is for the ESW system . Therefore, under this condition, if Diesel Generator E DC power distribution subsystem is not OPERABLE, to ensure the OPERABILITY of the ESW system, actions are taken to either restore the power distribution subsystem to OPERABLE status or shutdown Diesel Generator E and (continued)
SUSQUEHANNA- UNIT 2                TS I B 3.8-90                                                          Revision~

                                                                                                           ~Rev.@
RHRSW System and UHS B 3 .7.1 BASES ACTIONS         A.1. A.2 and A.3 (continued)
With any UHS return path valve listed in Tables 3.7.1-1, 3.7.1-2, or 3.7.1-3 inoperable, the UHS return path is no longer single failure proof.
For combinations of inoperable valves in the same loop, the UHS spray capacity needed to support the OPERABILITY of the associated Unit 1 and Unit 2 RHRSW subsystems is affected. As a result, the associated RHRSW subsystems must be declared inoperable.
The 8-hour completion time to establish the flow path provides sufficient time to open a path and de-energize the appropriate valve in the open position .
The 72-hour completion time is based on the fact that, although adequate UHS spray loop capability exists during this time period, both units are affected and an additional single failure results in a system configuration that will not meet design basis accident requirements.
Tl;!e C91ol1t:Jieti9R Tilol1e l;!es seeR e~teRlel te Qe I;!Q~FS iR erler te @9f.l1t:Jiete tl;!e f.l1llifieatieRs iR URit 1 esseeietel wit!;! tl;!e M~ltit:Jie Fire IRl~eel &:t:J~Fie~s Ot:JeFatieRs iss~e. Tt;Jis is e tlf.l1t:J9F8FJ' e~teRsieR ef tt;Je Cer.l1t:JietieR Tif.l1e aRe is Oit:Jt:Jiisaele l~riR&sect; tl;!e 1A2Q1 sRl1A2Q2 e~s f.l19elifieatieRS. IR 9Fler te 59t:Je wit!;!
            *
* tl;!e eeRSe1~eRees ef e LQQj;l, a LOCI\ iR URit 2 eRe tt;Je sl;!~tlevJR ef URit 1 l~riR&sect; tl;!e e){teRlel Cer.l1t:JietieR Tif.l1e, tt;Je fellewiR&sect; eef.l1t:JeRsateF)' aetilRS are Fe1~irel:
: 1) tt;Je affeetelleet:J's St:JFBY array eyt:Jass valves are iR t!;!e et:JeR t:JesitieR aRe 2) tt;Je affeetelleet:J's St:Jray array valves are slesel. Ut:J9R s9f.l1t:JietieR ef tl;!e M&:O f.l19lifieati9RS QR ell fe~r URit 1 4.1e IN e~ses, tl;!is tef.l1t:J9F8f'j e~teRSi9R is RQ leR&sect;er at:Jt:Jiisaele aRe will m<t:Jire eR May :11, 2Q12.
The Completion Time to restore the Unit 2 RHRSW inoperable valves has been extended to 7 days in order to complete the replacement of the Unit 1 480 V ESS Load Center Transformers 1X21 0 and 1X220. This is a temporary extension of the Completion Time and is applicable during the transformer replacement. In order to cope with the consequences of a LOOP, a LOCA in Unit 2 and the shutdown of Unit 1 during the extended Completion Time, the following compensatory actions are required : 1) the affected loop's spray array bypass valves are in the open position and 2) the affected loop's spray array valves are closed . Upon completion of the transformer replacements , this temporary extension is no longer applicable and will exp ire on June 15, 2020 .
If an additional RHRSW subsystem on either Unit is inoperable, cooling capacity less than the minimum required for response to a design basis event would exist.
Therefore, an 8-hour Completion Time is appropriate. The 8-hour Completion Time provides sufficient time to restore inoperable equipment and there is a low probability that a design basis event would occur during this period.
8.1 Required Action 8 .1 is intended to ensure that appropriate actions are taken if one Unit 2 RHRSW subsystem is inoperable. Although designated and operated as a unitized system, the associated Unit 1 subsystem is directly connected to a common header which can supply the associated RHR heat (continued)
SUSQUEHANNA- UNIT 2                       TS I B 3.7-5a                                           Revision 2.

BASES ACTIONS        fU     (continued) exchanger in either unit. The associated Unit 1 subsystem is considered capable of supporting the associated Unit 2 RHRSW subsystem when the Unit 1 subsystem is OPERABLE and can provide the assumed flow to the Unit 2 heat exchanger. A Completion time of 72 hours, when the associated Unit 1 RHRSW subsystem is not capable of supporting the associated Unit 2 RHRSW subsystem, is allowed to restore the Unit 2 RHRSW subsystem to OPERABLE status. In this configuration ,
the remaining OPERABLE Unit 2 RHRSW subsystem is adequate to perform the RHRSW heat removal function . However, the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function. The Completion Time is based on the redundant RHRSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring RHRSW during this period.
nus   Ce!'&#xa5;1~letieR Til'&#xa5;!e te festefe t~e IJRit 2 RJ.IRS'A' s~o~l:lsyste!'&#xa5;1 as !:leeR l)(teR1e1 te 9@ ~e~o~fs iR ef1ef te l@l'&#xa5;l ~lete t~e l'&#xa5;!e1ifiaatilRS iR URit 1 asslliate1 wit~ t~e M~o~lti~le Fim IR1~o~ae1 S~~o~fil~o~s O~eratilRS iss~o~e. IRis is a tel'&#xa5;!~lfafy @)GRSilR lf t~e Cli'&#xa5;1~letilR Til'&#xa5;!e aR1 is a~~liaal:lle 1~o~fiR~ t~e 1/\2Q1 aR11/\2Q2 l:l~o~s l'&#xa5;!l1ifiE>atieRs.
T~e IJRit 2 RJ.IRSW s~o~l:lsyste!'&#xa5;1 fll'&#xa5;!aiRs f~o~RE>tieRal siR6l t~e s~o~l:lsyste!'&#xa5;1 ~as aR l~lfal:lle ~loll'&#xa5;!~, l~lfal:lle fllw ~at~ aR1 aR l~lfal:lle IJJ.IS. ld~lR 6@1'&#xa5;1~1etilR lf t~e MSO l'&#xa5;!l1ifiE>atilRS lFI all fl~o~f 'JRit 1 4.1@ kV l:l~o~ses, t!;;Jis tel'&#xa5;!~erary exteRsilR is Rl leR~Bf a~~liaal:lle aR1 will @)E~im eR May :31 , 2Q12.
The Completion Time to restore the Unit 2 RHRSW subsystem has been extended to 7 days in order to complete the replacement of the Unit 1 480 V ESS Load Center Transformers 1X210 and 1X220. This is a temporary extension of the Completion Time and is applicable during the transformer replacement. The Unit 2 RHRSW subsystem remains functional since the subsystem has an operable pump, operable flow path and an operable UHS. Upon completion of the transformer replacements ,
this temporary extension is no longer applicable and will expire on June 15, 2020.
With one RHRSW subsystem inoperable and the respective Unit 1 RHRSW subsystem capable of supporting the respective Unit 2 RHRSW subsystem, the design basis cooling capacity for both units can still be maintained even considering a single active failure. However, the configuration does reduce the overall reliability of the RHRSW System. Therefore, provided the associated Unit 1 subsystem remains capable of supporting its respective Unit 2 RHRSW subsystem, the inoperable RHRSW subsystem must be restored to OPERABLE status within 7 days. The 7-day Completion Time is based on the remaining RHRSW System heat removal capability.
Required Action C.1 is intended to ensure that appropriate actions are taken if both Unit 2 RHRSW subsystems are inoperable. Although designated and operated as a unitized system , the associated Unit 1 subsystem is directly connected to a common header which can supply the associated RHR heat SUSQUEHANNA- UNIT 2                           TS I 3.7-2                                    Amendment 4-M, ~
180 238

TALEN ~
Jon A. Franke        Susquehanna Nuclear, LLC Site Vice President                   769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.2904 Fax 570.542.1504               ENERGY JAN   ~ 8 2016                                         Jon.Franke@talenenergy.com U.S. Nuclear Regulatory Commission                                                   10 CFR 50.90 Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NUMBER 292 TO UNIT 2 OPERATING LICENSE NO. NPF -22 TEMPORARY CHANGE TO ALLOW REPLACEMENT OF THE UNIT 1 480 V ESS LOAD CENTER TRANSFORMERS IN UNIT 2 TECHNICAL SPECIFICATIONS 3.8.7 and 3.7.1 PLA-7384                                                                           Docket No. 50-388 Pursuant to 10 CFR 50.90, Susquehanna Nuclear, LLC, hereby requests approval of the following proposed amendment to the Susquehanna Steam Electric Station (SSES) Unit 2 Technical Specification (TS). The proposal affects Technical Specification 3.8.7 "Electrical Power Systems- Distribution Systems- Operating" and Technical Specification 3.7.1 "Plant Systems - RHRSW System and UHS."
This proposed change would increase the Completion Time for Condition C ofTS 3.8.7 and Condition A and B of TS 3. 7.1 from 72 hours to 7 days in order to accommodate 480 V ESS Load Center Transformer replacements on Unit 1. The electrical distribution system at SSES is such that only changes to Unit 2 Technical Specifications are required for these replacements. Based on historical data and schedule projections, the replacement of a Unit 1 480 V ESS Load Center Transfmmer requires approximately 120 hours, which would exceed the cunently specified Completion Times of 72 hours. The proposed change is temporary and is annotated by a note in each TS that specifies the allowance expires on June 15, 2020.
As demonstrated in the enclosed evaluation, the proposed amendment does not involve a significant hazard consideration.
To accommodate the change, allowances in Unit 2 TS 3.8.7 and Unit 2 TS 3.7.1 Completion Times referring to spurious fire-induced modifications on Unit 1 will be deleted. These allowances expired on May 31, 2012 and are no longer valid.
There are planned transformer inspections for the upcoming Unit 1 refueling outage (20 16). Expedited NRC approval of this proposal would support any maintenance that may be required as a result of these inspections, specifically unanticipated replacement of the transformer. Baning any unforeseen equipment failures, Susquehanna Nuclear, LLC

Document Control Desk PLA-7384 is requesting an approval of the proposal by February 10, 2017, effective immediately upon approval, with implementation to be complete within 30 days.
Enclosures to this letter provide the Evaluation of these proposed changes to Unit 2 Technical Specification 3.8.7 and Unit 2 Technical Specification 3.7.1. Attachment 1 is the Technical Specification mark-up. Attachment 2 is a mark-up of the associated Technical Specification Bases changes, provided for infmmation only.
There are no regulatory commitments associated with the proposed changes.
The need for this change has been discussed with the SSES NRC Project Manager.
Additionally, the change has been reviewed by the SSES Plant Operations Review Committee (PORC) and by the Susquehanna Review Committee (SRC).
In accordance with 10 CFR 50.91(b), Susquehanna Nuclear, LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.
If you have any questions or require additional information, please contact Mr. Jason Jennings at (570) 542-3155.
I declare under penalty of perjury that the foregoing is true and conect.
Executed on:    ..JAtv.JftU-t Z.B! "2.o ' '
Sincerely, J. 7'   anke

==Enclosure:==

Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems- RHRSW System and UHS"

Document Control Desk PLA-7384 Attachments:  Proposed Changes to Unit 2 Technical Specification 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems - RRRSW System and UHS" (Mark-ups)  Proposed Change to Unit 2 Technical Specifications Bases 3.8.7, "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification Bases 3.7.1, "Plant Systems- RRRSW System and UHS" (Mark-ups provided for Information Only)
Copy: NRC Region I Mr. J. E. Greives, NRC Sr. Resident Inspector Ms. T. E. Hood, NRC Project Manager Mr. M. Shields, PA DEP/BRP Electronic Copy:
J. R. Jennings N. E. Fairchild (SRC)
T. G. Wales (DBD)
NRAFiles                        GENPL5 DCS                             GENPL4

Enclosure to PLA-7384 Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7 "Electrical Power Systems -
Distribution Systems - Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems-RHRSW System and UHS"
: 1. DESCRIPTION
: 2. PROPOSED CHANGE
: 3. BACKGROUND
: 4. TECHNICAL ANALYSIS
: 5. REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria
: 6. ENVIRONMENTAL CONSIDERATIONS
: 7. REFERENCES

Enclosure to PLA-7384 Page 1 of30 SUSQUEHANNA NUCLEAR, LLC EVALUATION

==Subject:==
Susquehanna Nuclear, LLC Evaluation of Proposed Changes to Unit 2 Technical Specification 3.8.7 "Electrical Power Systems- Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems- RHRSW System and UHS"
: 1. DESCRIPTION The proposed change affects Susquehanna Nuclear, LLC Unit 2 Technical Specifications (TS) 3.8.7 and 3.7.1. A temporary change to the Completion Time for Condition C ofTS 3.8.7 and to Condition A and B of3.7.1 is desired to allow replacement of Unit 1 480 V ESS Load Center Transformers. As demonstrated in Section 5.0, No Significant Hazards Consideration, these changes do not involve a significant impact to the safe operation ofthe facility.
: 2. PROPOSED CHANGE A mark-up of the proposed change to Unit 2 TS 3.8.7 is included in Attachment 1 of this submittal. In this attachment, the Completion Time of Condition C is revised to allow replacement of Unit 1 480 V ESS Load Center Transformers. Specifically, the Completion Time is increased to 7 days during Unit 1 transformer replacements.
A mark-up ofthe proposed change to Unit 2 TS 3.7.1 is also included in Attachment 1 ofthis submittal. In this attachment, the Completion Time of Condition A and B are revised to allow replacement of Unit 1 480 V ESS Load Center Transformers. Specifically, the Completion Time is increased to 7 days during replacement of Unit 1 480 V ESS Load Center Transformers 1X210 and 1X220.
All three (3) changes are modified by a note at the end of each table specifying that the extended completion time allowance will expire on June 15, 2020. Completion Time changes previously made to support fire induced spurious operation modifications will be removed since the allowance expired on May 31, 2012, and the proposed changes in this Amendment will take their place.
The Unit 2 TS Bases Section B 3.8.1 and Section B 3.7.1 have been revised based on these changes and marked up copies are shown in Attachment 2.

Enclosure to PLA-7384 Page 2 of30
: 3. BACKGROUND Reason for Changes The Unit I 480 V ESS transfmmers (IX2IO, IX220, IX230, and IX240) are approaching their qualified life of 40 years. Susquehanna desires to conservatively replace these transformers before they fail, using results from Doble testing to indicate the health of the equipment. The test results coupled with a life expectancy of 40 years form a reasonable basis for replacement.
The Unit 2 AC power distribution system at Susquehanna is patiially composed of Unit I AC distribution equipment. The Unit I transfonners subject of this proposal are part of that overlap and their operability will affect the operability of the Unit 2 AC distribution system.
Some Unit 1 transformers subject of this proposal affect the operability of the Unit 2 Residual Heat Removal Service Water system. As a result, changes to Technical Specifications that govern the Unit 2 AC distribution system and Unit 2 Residual Heat Removal Service Water system are requested.
Similar 480 V ESS LC transformers have been replaced on Unit 2 in the past. Those transfmmer replacements were completed in less than I20 hours (5 days); however, those replacements did not have the same circumstances (TS impacts, Engineering Change process) and therefore did not require any Completion Time extensions.
Overview of SSES AC Distribution System The SSES AC Distribution System transmits the output of the Unit I and Unit 2 Main Generators to offsite switchyards and distributes power from the unit auxiliary and offsite power supplies to onsite AC loads. These loads are required for stmiup, normal unit operation, shutdown, and emergency plant operations. Voltage levels of 500 kV, 230 kV, 24 kV, I3.8 kV, 4.16 kV, 480 V and 208/120 V are provided for a variety of reasons.
The electric power distribution system (See Figure I for simplified AC Distribution System) includes Class IE and non-Class IE AC Power Systems. The non-Class IE pmiion of the onsite power systems provides AC power for non-nuclear safety related loads. A limited number of non-safety related loads are impmiant to the power generating equipment integrity and are fed from the Class IE Distribution System. The non-Class IE AC Power System distributes power at I3.8 kV, 4.I6 kV, 480 V and 208/120 V, grouped into two symmetrical distribution systems stemming from I3.8 kV buses.
The Class IE AC Power System distributes power at 4.16 kV, 480 V, and 208/120 V to safety-related loads. The Class IE AC System is divided into four load group channels per unit (Channels A, B, C, and D). Any three out of four load groups has the capability of supplying the minimum required safety loads. The 4.I6 kV Bus of each Class IE Load Group Channel is provided with connections to two offsite power sources designated as preferred and alternate power supplies (Preferred and alternate power supplies up to the 4.I6 kV Buses of the Class lE Power System are considered as non-Class lE). Five (5) diesel generators are available to provide the required power supply if a total loss of the preferred and alternate supplies occurs.

Enclosure to PLA-7384 Page 3 of30 Four diesel generators shared between the two Units provide emergency power for one of the four Class IE AC load groups in each Unit when notmal sources are lost. Two divisionalized load groups are established from the four Class IE AC load groups (Division I is comprised of Channels A and C; Division II is comprised of Channels B and D) for those engineered safety feature loads which require one out of two load groups to meet design basis requirements. A spare diesel generator (E Diesel) can be manually aligned as a replacement for any one of the other four diesel generators.
The ESS buses designated load group channel is as follows for Unit I and Unit 2 respectively:
4.16 kV       LOAD          CONNECTING            480 VLOAD ESS BUS        GROUP        TRANSFORMER              CENTER IA20I           A               IX2IO               1B2IO IA203           c               IX230               1B230 IA202           B               IX220                IB220 IA204           D               IX240               IB240 .
2A20I           A               2X210               2B2IO 2A203           c               2X230               2B230 2A202           B               2X220               2B220 2A204           D               2X240               2B240 Each ESS Bus powers a 4.16 kV/480 V ESS Load Center (LC) transformer used to supply an essential480 V single-ended LC. The associated 4.16 kV ESS bus is the only source of power to the respective LC through the LC transfotmer.
The ESS LC supplies power to the individual 480 V loads and to Motor Control Centers (MCCs) that power instrument AC Distribution panels, I25 and 250 VDC Battery Chargers, and essential plant lighting.
The 250 VDC Battery Chargers on each unit are supplied by that unit' s 4.I6 kV ESS Bus.
The I25 VDC Battery Chargers can be supplied from either unit's 4.I6 kV ESS Bus.
The Offsite and On-Site Power systems are described in FSAR Sections 8.2 and 8.3 respectively.
Overview of Residual Heat Removal Service Water (RHRSW) System The RHRSW System is designed to provide cooling water for the Residual Heat Removal (RHR) System heat exchangers on both Units in the following a Design Basis Accident (DBA) or Seismic event.
The RHRSW System consists of two independent and redundant subsystems. Each subsystem has one header, one pump, a suction source, valves, piping, heat exchanger, and associated instrumentation. Either one of the two subsystems is capable of providing the required cooling

Enclosure to PLA-7384 Page 4 of30 capacity to maintain safe shutdown conditions. The two subsystems are separated such that failure of one subsystem will not affect the other.
One Unit 1 RHRSW subsystem and the associated (same division) Unit 2 RHRSW subsystem constitute a single RHRSW loop. The two RHRSW pumps in a loop can each be independently aligned to either Unit's heat exchanger. The RHRSW System is designed with sufficient redundancy so that no single active component failure can prevent it from achieving its design function. One such redundant feature is the use of a redundant manual isolation valve in each loop's bypass return line, which can be closed manually using a "reach-rod" through the top of the RHRSW Valve Vault missile shield without having to access the Valve Vault itself.
Cooling water is pumped by RHRSW pumps from the ultimate heat sink (UHS) through the tube side of the RHR heat exchangers. After removing heat from the RHR heat exchanger, the water is discharged to the spray pond (UHS) by way of the UHS return loops. The UHS return loops direct the return flow to a network of sprays that dissipate the heat to the atmosphere or directly to the UHS via a bypass header. The divisionalized UHS return loops are common to both units.
The ultimate heat sink system is composed of an approximately 25,000,000 gallon spray pond and associated piping and spray risers. Each UHS return loop contains a bypass line, a large spray array and a small spray array.
The purpose of the UHS is to provide the following functions for the RHRSW and Emergency Service Water (ESW) systems:
* Provide a suction source of water
* Provide a return flow path
* Maintain a water source at less than 97&deg;F using spray cooling The RHRSW system is described in FSAR Section 9.2.6, and the UHS is described in FSAR Section 9.2.7.
: 4. TECHNICAL ANALYSIS Alignment Pertinent to this Technical Specification Change Request This section discusses the proposed changes in context with the plant configuration in which the changes will apply. Specifically, the changes are only applicable when Unit 1 is in Mode 4 or 5 and when Unit 2 is not in Mode 4 or 5. Additionally, the increased Completion Times are only applicable to Unit 1 480 V ESS LC transformer replacement activities.
Over the course of the next several years, Doble testing on Unit 1 480 V ESS LC transformers will be conducted during Unit 1 refueling outages. If test results are not satisfactory, a pre-developed contingency plan to replace the affected transformer will be implemented if this license amendment is approved.

Enclosure to PLA-7384 Page 5 of30 Impacts to Unit 2 TS 3.8.7 "Electrical Power Systems- Distribution Systems-Operating" Removing any one of these four transformers from service with Unit 1 in Mode 4 or 5 and Unit 2 not in Mode 4 or 5 requires entry into Condition C ofTS 3.8.7 on Unit 2 for one Unit 1 AC electrical power distribution subsystem inoperable. The associated Completion Time for this Condition is 72 hours. Since replacing a single transformer takes approximately 120 hours, it is not possible to replace one of these transformers within the Completion Time currently specified in 3.8.7.
Impacts to Unit 2 TS 3.7.1 "Plant Systems- RHRSW System and UHS" Two ofthese transformers, specifically 1X210 and 1X220, have specific impacts to the RHRSW system. Removing either of these transformers from service with Unit 2 not in Mode 4 or 5 requires entry into Condition A and B of TS 3. 7.1 on Unit 2 for one required RHRSW valve inoperable and one required RHRSW subsystem inoperable. As seen in the Table below, the associated Completion Time for this Condition is 72 hours. Since replacing a single transformer takes approximately 120 hours, it is not possible to replace one of these transformers within the Completion Time currently specified in 3. 7 .I. The LCO duration for impacted equipment during all other Unit 1 transformer replacements is 7 days, which is the same as the increase requested forTS 3.8.7 and TS 3.7.1 in this proposed change. As a result, no changes to those TSs are requested.
Table A- Common Unit EQuipment Impacted Associated      Unit2 TS LCO Transformer                  Equipment Impacted Unit 2 TS          Duration 1X210                RHRSW A LOOP Return Valves                     3.7.1           72 Hours 1X220                RHRSW BLOOP Return Valves                      3.7.1           72 Hours 1X230                         SGTS Division 1                      3.6.4.3            7 Days CREOASS Division 1                       3.7.3             7Days Control Room Floor Cooling Division 1             3.7.4            30 Days 1X240                         SGTS Division 2                      3.6.4.3            7 Days CREOASS Division 2                       3.7.3             7 Days Control Room Floor Cooling Division 2              3.7.4            30 Days Regardless of which Unit 1-480 V ESS LC Transfmmer is out of service, the following items remain constant throughout the replacement evolution:
* All four (4) Unit 2-4.16 kV ESS Busses are operable.
* All four (4) Common Emergency Diesel Generators are operable.
* All 125 V DC and 250 V DC Battery Chargers, Batteries and Distribution Systems for Unit 2 are operable.
No equipment other than that listed in Table A is adversely affected by Unit 1 transfmmer replacements in this plant configuration.

Enclosure to PLA-7384 Page 6 of30 The impacts of specifically removing 1X21 0 or 1X220 from service are summarized in Table B below:
Table B- Im~acts of removing 1X210/1X220 transformers from service 1X210                     II                      1X220 Enter LCO 3. 7.1, Condition A on Unit 2 for one required valve inoperable Enter LCO 3.7.1, Condition Bon Unit 2 for one RHRSW subsystem inoperable Enter LCO 3.8.7, Condition Con Unit 2 for one Unit 1 AC electrical power distribution subsystem inoperable Division I (A) Large/Small spray network          Division II (B) Large/Small spray network valves will fail in normal position (closed)      valves will fail in normal position (closed)
HV01222A will fail in normal position (open) HV01222B will fail in normal position (open)
To ensure availability of the RHRSW system on Unit 2 during Unit 1 transformer replacements, the RHRSW Spray Pond Return Bypass Valve, HV01222A orB, on the out of service loop will remain open for the length of the evolution. Operator verification will ensure a return flow path to the spray pond is established, since the valves that form the normal flow path through the spray headers will be closed due to loss of power.
Since the RHRSW Pumps on Unit 1 and Unit 2 are not impacted by the Unit 1 transformer replacements, this return flow path would ensure the RHRSW system will transfer heat from its associated loads to the spray pond. This alignment does not affect the operability of the other Unit 2 RHRSW loop.
In this valve configuration, all flow through the affected loop will go directly to the Spray Pond as opposed to the Spray Array networks. Under Design Basis LOCA/LOOP Conditions, Spray Pond temperatures exceeding the design Spray Pond temperature associated with cooling both units could occur unless the normal flow path is restored (bypass valve closed, large spray in service). Factors contributing to elevated Spray Pond temperatures in the design basis analysis include:
* The use of conservative reactor decay heat values.
* The use of conservative meteorology.
* The use of conservative initial Spray Pond temperatures, i.e., Technical Specification Maximum Temperature.
The use of conservative values for these parameters is required in the design and licensing basis for SSES. A calculation using alternate values (not Design Basis values) to simulate other possible outcomes has been performed. Initial conditions and assumptions used in this calculation include:
* Both Units operating at 100% power.
* LOCA/LOOP conditions require shutdown of both Units o   LOCA/LOOP occurs on one Unit o   LOOP occurs on other Unit

Enclosure to PLA-7384 Page 7 of30
* The bypass valve on one RHRSW loop is assumed to fail open, while the large and small spray array valves on the same loop are closed.
* The large spray array valve on the other RHRSW loop is open and spraying. The bypass and small spray array valves on this loop are closed and remain closed.
      *  "Best Estimate" meteorology is used, e.g., the 30 worst consecutive days measured at the site synthesized into a single day and repeated for the full 30-day duration is used.
      *  "Best Estimate" decay heat is used, e.g., the 2 sigma conservatism of the decay heat input is removed.
      *  "Best Estimate" initial Spray Pond temperature is used, e.g., 80&deg; F + 0.5&deg; F, for instrument tolerance. The 80&deg; F initial Spray Pond temperature is based on the highest monthly average pond temperature.
Analysis using these inputs shows that additional time is available to close HV01222A orB before peak spray pond temperature is approached. With HV01222A orB open for 12 hours and the large spray array valve open on the opposite loop, the peak Spray Pond temperatures are approximately 4&deg; F below the value required (97&deg; F; FSAR Section 9.2.7) to safely shut down both units.
In this specific calculation, the initial spray pond temperature was assumed to be 80&deg;F.
Considering these transformer replacements will occur during Unit 1 refueling outages early in the year, a spray pond temperature of 80&deg;F is conservative. Data collected during operator rounds demonstrates Spray Pond temperatures do not approach 80&deg;F until the hottest months of the year (July-August). Additionally, Unit 1 will already be in a safe shutdown condition, which reduces the heat load placed on the RHRSW system.
As demonstrated above, in the event of a design basis accident, shutting down Unit 2 and continuing to cool Unit 1 through the open HV01222A orB valve is a low risk activity which does not pose any significant safety consequences. In the event of a design basis accident, operations personnel will manually close the bypass valve (HV01222A or B) and open the large spray array valve on the affected loop within 12 hours if spray pond temperatures approach 80&deg; F. Operations personnel monitor and record spray pond temperatures each shift to satisfy surveillance requirements. Operations personnel will be notified before transformer replacements commence to ensure spray pond temperature does not approach 80&deg; F.
Despite being functional, Condition A cannot be cleared until the UHS valves are operable.
Therefore, the Unit 2 RHRSW subsystem is administratively declared inoperable until Condition A can be exited. Since transformer replacements require approximately 120 hours to complete, it is requested that the Completion Time associated with Condition A and B of TS 3. 7.1 be extended to 7 days.
Prior to removing 1X21 0 or 1X220 from service, Surveillances which demonstrate proper valve operation will be satisfied. Successful completion of the surveillances will ensure that the RHRSW loops are operable prior to beginning transformer replacements . Additionally, it will ensure the opposite loop of RHRSW is Operable.

Enclosure to PLA-7384 Page 8 of30 Operation of the Unit 2 ECCS equipment supplied by the Unit 2 AC Distribution Subsystem is not affected by the scheduled Unit 1 480 V ESS LC Transformer replacement activities.
Unit 1-480 V ESS LC Transformer Replacement Sequence This section discusses the aggregate impact to the station if Doble testing indicates a transformer should be replaced. Numbered items will be performed in sequence. Bulleted items provide generic information, or information that will apply throughout the evolution unless otherwise specified.
* Only one transformer will be tested at a time
* Work will be conducted during a period in which no Core Alterations, Fuel Movements, or Operations with the Potential to Drain the Reactor Vessel (OPDRVs) are being conducted in order to preclude not meeting LCO 3.8.8 on Unit 1
* All Unit 2 buses will remain energized and operable
* Prior to commencing Doble test, the allocated replacement transformer will be on hand and fully qualified to act as an acceptable replacement (Megger!Doble testing)
* HV01222A orB (Spray Pond Bypass Valve) will be de-energized and ensured open by operations
* Operations will monitor spray pond temperature on a shiftly basis to ensure it does not approach 80 F.
* Satisfy the following surveillances:
o SR 3. 7 .1.3 -Verify position of RHRSW flow path valves every 31 days o SR 3.7.1.4- Verify RHRSW to UHS Bypass valves (HV01222A/B) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.5 -Verify Large Spray Array valves (HV01224Al/B1) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.6- Verify Small Spray Array valves (HV01224A2/B2) open and close upon receipt of corresponding signal every 92 days o SR 3.7.1.7- Verify the manual Small Spray Array Bypass valves (012287A/B) are capable of being opened and closed every 92 days Flow path for replacement:
: 1)      De-energize the 480 V ESS LC Transformer and associated load center
: 2)      Remove enclosure panels and transformer accessories (Prepare for rigging)
: 3)      De-terminate primary, secondary, and grounding of original transformer
: 4)      Rig out original transformer
: 5)      Rig in replacement transformer
: 6)      Weld, bolt, and paint replacement transformer
: 7)      Perform pre connection megger and doble testing of replacement transformer (verifies no damage during installation)
: 8)      Terminate primary, secondary, and grounding of replacement transformer.

Enclosure to PLA-7384 Page 9 of30
: 9)      Perform pre-energization megger and doble testing of replacement transformer
: 10)     Energize replacement transformer and validate phase rotation on secondary side of transformer. (Requires restoration ofthe 4.160 kV bus.)
: 11)     Perform additional Post Maintenance Testing.
: 12)     Reinstall enclosure panels and accessories.
: 13)     Restore associated load center and perform post modification testing.
Fire Protection System Status Requirements Table C lists common systems required to function during a unit shut down as a result of a fire. The listed systems have the potential to impact Unit 2 during a Unit 1 transformer replacement. The loss of ESW and RHRSW are the only two systems affected.
TableD lists specific Post-Fire Shutdown Functions ofESW and RHRSW affected by the loss of power during a Unit 1 transformer replacement, along with mitigating actions.
Table C- Impacts to Unit 2 Post-Fire Safe Shutdown (PFSS) Svstems System Impacted               Appli               Completion         Potential PFSS LCO                  Time               Impact?
ESW                                    3.7.2               7 days               Yes RHRSW                                  3.7.1             72 hours               Yes SBGT                                  3.6.4.3              7 days               No CREOAS                                 3.7.3               7 days               No t::
Control Room Floor Cooling             3.7.4              30 days               No Table 3- ESW & RHRSW Post-Fire Shutdown Function Imoact Assessment nction Potentially         Ri k M'f f          A f tpacted by Fire                s     I Iga IOn c Ions
* Treat the Diesel Driven Fire Pump as protected equipment to assure the availability of fire suppression.
ESWPumps
* Control combustibles and hot work under normal plant procedures to limit potential of plant fires ESSW Pumphouse Cooling
* Implement temporary cooling measures outlined in (Fans & Dampers)                    existing operating procedures ESW Diesel Generator
* These valves are normally open and are required open post Supply Valves (A-D)                 transient. Removal of their power source will leave them in the open position. Therefore, there is no impact to these ESW Diesel Generator                valves during Unit 1 480 V ESS LC transformer Retum Valves (A-D)                  replacements.

Enclosure to PLA-7384 Page 10 of30 RHRSW Loop A Return to         These valves in the common ESW-RHRSW return line to the Spray Pond Valves              Spray Pond utilize a power supply path from 1X21 0.
* Treat the Diesel Driven Fire Pump as protected equipment to assure the availability of fire suppression.
* Control combustibles and hot work under normal plant procedures to limit potential of plant fires Protected Equipment Licensed operators have reviewed the list of affected equipment for these evolutions in accordance with the station's protected equipment program. Subsequently, a list of protected equipment was developed and can be viewed in Table 2 at the end of this document.
: 5. REGULATORY SAFETY ANALYSIS 5.1   No Significant Hazards Consideration This "No Significant Hazards Consideration" evaluates the following changes to the Technical Specifications:
: a. The Unit 2 TS 3.8.7, Condition C, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for a Unit 1 480 V subsystem that is de-energized and removed from service.
: b. The Unit 2 TS 3.7.1, Condition A, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for an Inoperable loop of UHS spray anay and spray array bypass valves.
: c. The Unit 2 TS 3.7.1, Condition B, Completion Time is revised to extend the Completion Time from 72 hours to 7 days for one (1) Unit 2 RHRSW subsystem Inoperable.
All 3 changes are annotated by a note specifying the increased Completion Time only applies to Unit 1 480 V ESS LC transformer replacements and that the extension expires on June 15, 2020.

Enclosure to PLA-7384 Page 11 of30
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The temporary changes to the completion times forTS 3.8.7, Condition C and TS 3.7.1, Conditions A and B are necessary to implement plant changes, which replace the Unit 1 -
480 V ESS LC Transformers 1X210 and 1X220 in order to mitigate the loss of the transformer due to failure. The temporary change to the completion time forTS 3.8.7, Condition C is also necessary to implement plant changes, which replace the Unit 1 - 480 V ESS LC Transformers 1X230 and 1X240 in order to mitigate the loss of the transformer due to failure. These replacements decrease the probability of a transformer failure. The current assumptions in the safety analysis regarding accident initiators and mitigation of accidents are unaffected by these changes. No SSC failure modes or mechanisms are being introduced, and the likelihood of previously analyzed failures remains unchanged.
The proposed change requests the Completion Time to restore a Unit 2 RHRSW subsystem be extended to 7 days in order to replace Unit 1 transformers 1X210 and 1X220. The extended Completion Times forTS 3.7.1 Conditions A and Bare only applicable when transformers 1X21 0 or 1X220 are out of service with the intent of replacing the transformer.
During the replacements, the affected Unit 2 RHRSW subsystem will remain functional while the other subsystem of Unit 2 RHRSW will remain Operable. Operator action required to restore full capability of cooling provided by the Ultimate Heat Sink will only consist of manually operating two (2) valves; the Large Spray Array and the UHS bypass.
This action can easily be completed within several hours and would restore full cooling to the RHRSW system.
Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed changes involve the increase of TS Completion Times to allow replacement of four (4) Unit 1-480 V ESS LC Transfmmers. New transformers will be installed but will not be operated in a new or different manner. There are no setpoints at which protective or mitigative actions are initiated affected by this change. These changes do not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No alterations to procedures that ensure the plant remains within analyzed limits are being proposed, and no major changes are being made to procedures relied upon during off-normal events as described in the FSAR.

Enclosure to PLA-7384 Page 12 of30 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response: No Operational safety margin is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The proposed changes are acceptable because the Completion Time extensions allow replacement of the Unit 1-480 V ESS LC Transformers, equipment essential to safe plant operation, while ensuring safety related functions of affected equipment are maintained.
With the RHRSW Spray Pond Return Bypass Valves on the out of service loop electrically de-powered in the open position, a return flow path will be established. Since the RHRSW Pumps on Unit 2 are not impacted by the transformers outages, the affected RHRSW Loop on Unit 2 will be capable of providing cooling. This configuration will continue to provide the margin of safety assumed by the safety analysis, although the affected RHRSW loop will be administratively declared Inoperable.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Susquehanna Nuclear, LLC concludes that the proposed changes do not involve a significant hazards consideration under the standards set f01ih in 10 CFR 50.92(c),
and accordingly, a finding of no significant hazards consideration is justified.
5.2   Applicable Regulat01y Requirements/Criteria SSES FSAR Sections 3.1 and 3.13 provide detailed discussion ofSSES compliance with the applicable regulatory requirements and guidance.
The proposed TS amendment:
(a)   Does not result in any change in the qualifications of any component; and (b)   Does not result in the reclassification of any component's status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
Susquehanna conformance with the applicable General Design Criteria (GDC) related to the proposed Unit 2 TS 3.8.7 change is provided as follows:
GDC 5- Sharing ofStructures, Systems and Components Offsite Power Supplies- The two preferred offsite power supplies are shared by both units 1 and 2. The capacity of each offsite power supply is sufficient to operate the Engineered Safety Features (ESF) of one unit and safe shutdown of the other unit.
Additional details are provided in FSAR Section 8.2.

Enclosure to PLA-7384 Page 13 of30 Diesel Generators - The Diesel Generators are shared systems impottant to safety. Loss of one of the four aligned diesel generators will not impair the capability to safely shutdown both units, since this can be done with three diesel generators. Additional details are provided in FSAR Section 8.3.1.4.
Unit 1 AC Distribution System - The Unit 1 AC Distribution system is a shared system between both units 1 and 2 since the common equipment (Emergency Service Water, RHR Service Water, Standby Gas Treatment System including the Reactor Recirculation Fans, Control Structure HVAC, and Control Room Floor Cooling) is energized only from the Unit 1 AC Distribution System. The capacity of the Unit 1 AC Distribution System is sufficient to operate the engineered safety features on one unit and the safe shutdown loads of the other unit.
GDC 17 - Electric Power Systems Two offsite power transmission systems and four onsite standby diesel generators (A, B, C and D) with their associated battery systems are provided. Either of the two offsite transmission power systems or any three of the four onsite standby diesel generator systems have sufficient capability to operate safety related equipment for cooling the reactor core and maintaining primary containment integrity and other vital functions in the event of a postulated accident in one unit with a safe shutdown of the other unit.
Additionally, a fifth diesel generator 'E' with its associated battery system is provided as a replacement, and has the capability of supplying the emergency loading for any one of the other four diesel generators (A, B, Cor D). Diesel generator 'E' must be manually aligned to replace any one of the other four diesel generators in the event of a failure.
The two independent offsite power systems supply electric power to the onsite power distribution: system via the 230 kV transmission grid. Each of the offsite power sources is supplied from a transmission line which terminates in switchyards (or Substations) not common to the other transmission line. The two transmission lines are on separate rights-of-way. These two transmission circuits are physically independent and are designed to minimize the possibility of their simultaneous failure under operating and postulated accident and environment conditions.
Each offsite power source can supply all Engineered Safety Feature (ESF) buses through the associated transformers . Power is available to the ESF buses from their preferred offsite power source during normal operation and from the alternate offsite power source if the preferred power is unavailable. Each diesel generator (A, B, C, or D) supplies standby power to one of the four ESF buses in each unit. Loss of both offsite power sources to an ESF bus results in automatic stmting and connection of the associated diesel generator (A, B, C, or D) within 10 seconds. Loads are progressively and sequentially added to avoid generator instabilities.
There are four independent AC load groups provided to assure independence and redundancy of equipment function. These meet the safety requirements assuming a

Enclosure to PLA-73 84 Page 14 of30 single failure since any three of the four load groups have sufficient capacity to supply the minimum loads required to safely shut down the unit. Independent routing of the preferred and alternate offsite power source circuits to the ESF buses are provided to meet the single failure safety requirements.
Additional discussion and details are provided in FSAR Sections 8.2 and 8.3.
Based on compliance with the General Design Criteria 5 and 17 above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
: 6. ENVIRONMENTAL CONSIDERATION 10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions, which are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. Susquehanna Nuclear, LLC has evaluated the proposed change and has determined that the proposed change meets the eligibility criteria for categorical exclusion set fmih in 10 CFR 51.22(c)(9). Accordingly, pursuant to 10 CFR 51.22(b ), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:
As demonstrated in the "No Significant Hazards Consideration" evaluation, the proposed amendment does not involve a significant hazards consideration.
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.
There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

Enclosure to PLA-7384 Page 15 of30
: 7. REFERENCES
: 1. Susquehanna FSAR Section 3.1, Conformance with NRC General Design Criteria
: 2. Susquehanna FSAR Section 3.13, Compliance with NRC Regulatory Guides
: 3. Susquehanna FSAR Section 8.1, Introduction
: 4. Susquehanna FSAR Section 8.2, Offsite Power System
: 5. Susquehanna FSAR Section 8.3, On Site Power Systems
: 6. Susquehanna FSAR Section 9 .2.6, Residual Heat Removal Service Water System
: 7. Susquehanna FSAR Section 9.2.7, Ultimate Heat Sink (UHS)
: 8. P&ID Drawing M-112, Unit 1 RHR Service Water System, Sheets 1 & 2
: 9. P&ID Drawing M-2112, Unit 2 RHR Service Water System, Sheet 1

Enclosure to PLA-7384 Page 16of30 TABLEt Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description     Applicable                           Comments Source                                             Unit2 LCO/TRO Motor       HV-01224A1   Residual Heat Removal     LCO 3.6.2.3   The loss of power to the spray pond return valves Control     HV-01224A2   Service Water (RHRSW)     LCO 3.6.2.4   results in the following:
Center      HV-01222A    Spray Pond Return Valves  LCO 3.5 .1 (MCC)                                              LCO 3.7.1
* One loop ofRHRSW inoperable due to loss OB517                                              LCO 3.7.2              offlow path (LCOs 3.7.1 and 3.7.2-72 hour Technical              completion time- part of Technical Requirements           Specification amendment request) for Operation
* One subsystem ofRHR suppression pool (TRO) 3.8.6            cooling inoperable due to the loss ofRHRSW to the RHR heat exchanger. (LCO 3.6.2.3- 7 day completion time)
* One subsystem ofRHR suppression pool spray inoperable due to the loss ofRHRSW to the RHR heat exchanger. (LCO 3.6.2.4- 7 day completion time)
* One RHR pump inoperable due to the loss of ESW cooling to its motor. (LCO 3.5.1 - 7 day completion time)
* One Unit 1 Emergency Switchgear Cooling subsystem inoperable due to the loss of Control Structure Chilled Water subsystem.
(TRO 3.8.6- 30 day completion time)

Enclosure to PLA-73 84 Page 17 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description     Applicable                            Comments Source                                             Unit2 LCO/TRO MCC         OV521A       Engineered Safeguard      TRO 3.7.6      Due to the loss of this MCC, 4 fans (2 ESSW fans OB517       OV521C       Service Water (ESSW)      LCO 3.7.2      and 2 RHRSW fan) are inoperable. This TRO Pumphouse Fan                            requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable. Two ESW pump are declared inoperable and LCO 3.7.2 is entered. The completion time for the restoration of2 ESW pumps is 7 days.
MCC         1V506A       RHRSW Pump Fan            TRO 3.7.6      Due to the loss of this MCC, 4 fans (2 ESSW fans OB517       2V506A                                 LCO 3.7.1      and 2 RHRSW fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable. One RHRSW pump would be declared inoperable and LCO 3.7.1 is entered. The completion time for the restoration of 1 RHRSW pump is 72 hours. The extension of this time is the subject of the Tech Spec amendment request.

Enclosure to PLA-7384 Page 18 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X210- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description       Applicable                             Comments Source                                               Unit2 LCO/TRO MCC         HV-08693A    Control Structure Chilled   LCO 3.7.3       With the loss of power to the Control Structure 1B216                    Water ESW Control Valve     LCO 3.7.4       Chilled Water ESW Control Valve, the following are TRO 3.7.9       declared inoperable:
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC         OV201A       Reactor Building            LCO 3.6.4.3     One Standby Gas Treatment subsystem is inoperable 1B217                    Recirculation Fan                           due to the loss of the Reactor Building Recirculation Fan. (LCO 3.6.4.3- 7-day completion time) 1Y216       Various      Instrumentation for         LCO 3.6.4.3     The loss of power to the 1Y216 panel results in the various systems and                         loss of instrumentation and control to one SOTS control to dampers,                         subsystem (LCO 3.6.4.3 day completion time),
including the systems                       one CREOASS subsystem.
described above

Attachment 1 to PLA-7384 Page 19 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component        Applicable     Comments Source                 Description      Unit2 LCOITRO MCC       HV-01224Bl   RHRSW Spray      LCO 3.6.2.3    The loss of power to the spray pond return valves results in the OB527     HV-01224B2   Pond Return      LCO 3.6.2.4    following:
HV-01222B    Valves           LCO 3.5.1 LCO 3.7.1
* One loop ofRHRSW inoperable due to loss of flow path LCO 3.7.2               (LCOs 3.7.1 and 3.7.2- 72 hour completion time- part of TRO 3.8.6               Technical Specification amendment request)
* One subsystem ofRHR suppression pool cooling inoperable due to the loss ofRHRSW to the RHR heat I
exchanger. (LCO 3.6.2.3 - 7 day completion time)
* One subsystem of RHR suppression pool spray inoperable due to the loss ofRHRSW to the RHR heat exchanger.
(LCO 3.6.2.4- 7 day completion time)
* One RHR pump inoperable due to the loss ofESW cooling to its motor. (LCO 3.5.1 - 7 day completion time)
* One Unit 1 Emergency Switchgear Cooling subsystem due to the loss of Control Structure Chilled Water subsystem.
(TRO 3.8.6- 30 day completion time)
MCC       OV521B       ESSW Pumphouse   TRO 3.7.6       Due to the loss of this MCC, 4 fans (2 ESSW fans and 2 RHRSW OB527     OV521D       Fan                              fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable.
Two ESW pump are declared inoperable and LCO 3.7.2 is entered.
The completion time for the restoration of 2 ESW pumps is 7 days.

Attachment 1 to PLA-7384 Page 20 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component         Applicable    Comments Source                 Description       Unit2 LCO/TRO MCC       1V506B       RHRSWPump         TRO 3.7.6     Due to the loss of this MCC, 4 fans (2 ESSW fans and 2 RHRSW OB527     2V506B       Fan               LCO 3.7.1     fan) are inoperable. This TRO requires that at least 2 of in the ESSW Pumphouse Ventilation subsystem be restored to operable status within 36 hours or declare the associated pumps inoperable.
One RHRSW pump would be declared inoperable and LCO 3.7.1 is entered. The completion time for the restoration of 1 RHRSW pump is 72 hours. The extension of this time is the subject of the Tech Spec amendment request.
MCC       HV-08693B    Control Structure LCO 3.7.3      With the loss of power to the Control Structure Chilled Water ESW 1B226                  Chilled Water     LCO 3.7.4      Control Valve, the following are declared inoperable:
ESW Control       TRO 3.7.9 Valve
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem. (LCO 3.7.4-30 day completion time)
* One Control Structure HVAC subsystem. (TRO 3.7.9- 30 day completion time)
MCC       OV201B       Reactor Building  LCO 3.6.4.3    One Standby Gas Treatment subsystem is inoperable due to the 1B227                  Recirculation Fan                loss of the Reactor Building Recirculation Fan. (LCO 3.6.4.3-7 day completion time)

Attachment 1 to PLA-7384 Page21 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X220- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power     Component#   Component           Applicable     Comments Source                 Description         Unit2 LCOITRO 1Y226     Various      Instrumentation     LCO 3.6.4.3    The loss of power to the 1Y226 panel results in the loss of and damper                         instrumentation and control to one SGTS subsystem (LCO 3.6.4.3 -
control for various                7-day completion time.
systems, including the systems described above

Attachment 1 to PLA-73 84 Page 22 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO I
Implications Power       Component#   Component Description        Applicable   Comments Source                                                Unit2 LCO/TRO MCC 1B230   OE145A       Control Structure A/C Unit   LCO 3.7.3    With the loss of power to the Control Structure NC A Heater                     LCO 3.7.4    Unit A Heater, the following are declared inoperable:
TRO 3.7.9
* One CREOASS subsystem. (LCO 3.7.3-7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC OB136   SGTS                                                   The loss of power to MCC OB 136 results in one OV109A       Fan                          LCO  3.6.4.3 SGTS subsystem (LCO 3.6.4.3 - 7 day completion OC886A       Control Panel                LCO  3.6.4.3 time) and one Control Structure HVAC subsystem OV118A       Room Exchange Fan            TRO  3.7.9   (LCO 3.7.9- 30 day completion time) being declared OV144A       Equipment Room Fan           TRO  3.7.9   inoperable.
OE144A       Equipment Room Heating       TRO  3.7.9 Coil MCC OB136   cs                                                     With the loss of power to MCC OB136, the following OVIOIA       CREOASS Fan                  LCO  3.7.3   are declared inoperable:
OP171A       Chilled Water System         LCO  3.7.3 (CWS) Emergency              LCO  3.7.4
* One CREOASS subsystem. (LCO 3.7.3 -7 Condenser Water Pump         TRO  3.7.9           day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)

Attachment 1 to PLA-7384 Page 23 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description      Applicable     Comments Source                                              Unit2 LCO/TRO OP162A       Chilled Water Pump         LCO  3.7.3 LCO  3.7.4 TRO  3.7.9 OP122A       Chiller OK112A Oil Pump    LCO  3.7.3 i
OE143A       Control Room Emergency Fresh Air Heating Coil OV103A       Heating & Ventilation      LCO 3.7.3      With the loss of power to MCC OB 136, the following (H&V) System Fan           LCO 3.7.4      are declared inoperable:
TRO 3.7.9 OV117A       Control Room Ceiling Fan   LCO 3.7.3
* One CREOASS subsystem. (LCO 3.7.3- 7 LCO 3.7.4              day completion time)
TRO 3.7.9
* One Control Room Floor Cooling subsystem .
OV115A       Computer Room Ceiling      LCO 3.7.3              (LCO 3.7.4- 30 day completion time)
Fan                        LCO 3.7.4
* One Control Structure HVAC subsystem .
TRO 3.7.9              (TRO 3.7.9- 30 day completion time)
OV116A       Battery Room Exhaust Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9

Attachment 1 to PLA -73 84 Page 24 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X230- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#   Component Description         Applicable   Comments Source                                                 Unit2 LCO/TRO 1Y236       Various      120 VAC instrument power      LCO  3.6.4.3 The loss of power to the 1Y23 6 panel results in the to Instrumentation for        LCO  3.3.7.1 loss of instrumentation and control to :
various systems and control   LCO  3.7.3
* One SOTS subsystem (LCO 3.6.4.3- 7 day power to dampers, including   LCO  3.7.4           completion time),
the systems described above   TRO  3.7.9
* One CREOASS subsystem (LCO 3.7.3- 7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
* Instrumentation   for CREOASS, which is already out of service. (LCO 3.3 .7.1 -declare CREOASS inoperable)

Attachment 1 to PLA-7384 Page 25 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description        Applicable    Comments Source                                                 Unit2 LCO/TRO Load Center OE145B        Control Structure A/C Unit   LCO 3.7.3     With the loss of power to the Control Structure A/C 1B240                     B Heater                     LCO 3.7.4     Unit B Heater, the following are declared inoperable:
I TRO 3.7.9
* One CREOASS subsystem. (LCO 3.7.3 -7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)
* One Control Structure HV AC subsystem .
(TRO 3.7.9- 30 day completion time)
MCC OB146   SGTS OV109B        Fan                          LCO  3.6.4.3  The loss of power to MCC OB146 results in one OC886B        Control Panel                LCO  3.6.4.3  SGTS subsystem (LCO 3.6.4.3 - 7 day completion OV118B        Room Exchange Fan            TRO  3.7.9    time), one Control Structure HVAC subsystem (LCO OV144B        Equipment Room Fan           TRO  3.7.9    3.7.9- 30 day completion time) being declared OE144B        Equipment Room Heating       TRO  3.7.9    inoperable, and one vent stack radiation monitor Coil                         TRO  3.3.4    (TRO 3.11.2.6- 30-day completion time to restore the OP560         Stack Vent Vacuum Pump       TRO  3.11.2.6 monitor) inoperable.
MCC OB146   cs OV101B        CREOASS Fan                  LCO 3.7.3     With the loss of power to MCC OB146, the following OP171B        CWS Emergency                              are declared inoperable:
Condenser Water Pump         LCO 3.7.3 LCO 3.7.4
* One CREOASS subsystem. (LCO 3.7.3 -7 TRO 3.7.9             day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4- 30 day completion time)

Attachment 1 to PLA-7384 Page 26 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description      Applicable    Comments Source                                               Unit2 LCO/TRO MCC OB146   OP162B        Chilled Water Pump         TRO  3.7.9
* One Control Structure HVAC subsystem .
(Continued)                                          LCO  3.7.3         (TRO 3.7.9- 30 day completion time)
LCO  3.7.4 OP122B        Chiller OK 112B Oil Pump   TRO  3.7.9 I
LCO  3.7.3 LCO  3.7.4 OE143B        Control Room Emergency     TRO  3.7.9 Fresh Air Heating Coil     LCO  3.7.3 OV103B        H&V System Fan             LCO 3.7.3 LCO 3.7.4 TRO 3.7.9 OV117B        Control Room Ceiling Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9 OV115B        Computer Room Ceiling      LCO 3.7.3 Fan                        LCO 3.7.4 TRO 3.7.9 OV116B        Battery Room Exhaust Fan   LCO 3.7.3 LCO 3.7.4 TRO 3.7.9

Attachment 1 to PLA-7384 Page 27 of30 TABLE 1 (Continued)
Unit 1-480 V ESS LC Transformer 1X240- Unit 2 & Common Loads Affected by De-Energization with LCO or TRO Implications Power       Component#    Component Description    Applicable      Comments Source                                             Unit2 LCO/TRO 1Y246       Various       120 VAC instrument       LCO  3.6.4.3    The loss of power to the 1Y246 panel results in the power to Instrumentation LCO  3.3.7.1    loss of instrumentation and control to:
for various systems,     LCO  3.7.3
* One SGTS subsystem (LCO 3.6.4.3 - 7 day including the systems    LCO  3.7.4              completion time),
described above          TRO  3.7.9
* One  CREOASS subsystem (LCO 3.7.3 - 7 day completion time)
* One Control Room Floor Cooling subsystem .
(LCO 3.7.4 - 30 day completion time)
* One Control Structure HVAC subsystem .
(TRO 3.7.9- 30 day completion time)
I
* Instrumentation for CREOASS, which is already out of service. (LCO 3.3. 7.1 - declare CREOASS inoperable)

Enclosure to PLA-7384 Page 28 of30 TABLE2 PROTECTED EQUIPMENT Unit 1- 480 V ESS LC Transformer 1X210 Outage 1B, 1C and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1B and 1D 125 V DC Batteries 1B and 1D 250 V DC Batteries 2B and 2D 125 V DC Batteries 2B and 2D 250 V DC Batteries 2B and 2D 4 kV Buses and Load Centers U2 BLoop RHR U2 B Loop RHRSW Diesel Driven Fire Pump B Division ESW Pumphouse Unit 1 - 480 V ESS LC Transformer 1X220 Outage 1A, 1C and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1A and 1C 125 V DC Batteries 1A and lC 250 V DC Batteries 2A and 2C 125 V DC Batteries 2A and 2C 250 V DC Batteries 2A and 2C 4 kV Buses and Load Centers U2ALoopRHR U2ARHRSW Diesel Driven Fire Pump A Division ESW Pumphouse

Enclosure to PLA-7384 Page 29 of30 TABLE 2 (Continued)
Unit 1 - 480 V ESS LC Transformer 1X230 Outage 1A, 1B and 1D 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) 1B and 1D 125 V DC Batteries lB and lD 250 V DC Batteries 2B and 2D 125 V DC Batteries 2B and 2D 250 V DC Batteries 2B and 2D 4 kV Buses and Load Centers U2BLoopRHR U2BRHRSW Diesel Driven Fire Pump B Division ESW Pumphouse Unit 1 - 480 V ESS LC Transformer 1X240 Outage 1A, 1B and 1C 4 kV Buses and Load Centers If in service, Shutdown Cooling (SDC) lA and 1C 125 V DC Batteries 1A and 1C 250 V DC Batteries 2A and 2C 125 V DC Batteries 2A and 2C 250 V DC Batteries 2A and 2C 4 kV Buses and Load Centers U2ALoopRHR U2ARHRSW Diesel Driven Fire Pump A Division ESW Pumphouse

Enclosure to PLA-7384 Page 30 of30 SUNBURY#2 STANTON #21    STANTON #1 WESCOSVILLE                                                                       MONTOUR         JENKINS SUNBURY        HARWOOD 500 kV/230 kV TIE LINE E. PALM T- 21                                                               '    230KV 500KV      <I I L.:>U IW      I                                           SWYD SWYD 230KV 24 KV 1R106 S/U  - - 230KV                                                                                                               (HSGS)
T~~~ST           13.8KV                                 2G101                                  1G101 230KV ~ S/U OX104                                                                                                  13.8 KV           TRANS T-10
                                                                                                                    ~'""("" OX103 01    ) S/U BUS                                                                                    S/U BUS   1_) _
f      20                                                                                          10    T   01 OA104 lVI                        OA10502                           V~IVV TIE BUS                         OX501
                                               -*J'.o.,_-r*r-                       ~  4.16KV~
I  -llj'"fflll-
* a T-201 ESS201 OX203 T-211                                                                                                                                   OX207 ESS211 OX213 OA510
                                                                                                     @                          OPEN OG501E                     CKT BKR OG5018 TWO UNIT OPERATIONAL C) OG501C                                                        LINEUP SHOWN Figure 1 SIMPLIFIED SSES AC DISTRIBUTION SYSTEM

Attachment 1 to PLA-7384 Susquehanna Nuclear, LLC Proposed Changes to Unit 2 Technical Specification 3.8. 7 "Electrical Power Systems -
Distribution Systems- Operating" and Unit 2 Technical Specification 3.7.1, "Plant Systems-RHRSW System and UHS" (Markups)

                                                                                                                                             ~Rev . 4 Distribution Systems-Operating 3.8.7 3.8                  ELECTRICAL POWER SYSTEMS 3.8 .7               Distribution Systems-Operating LCO 3.8.7            The electrical power distribution subsystems in Table 3.8.7-1 shall be OPERABLE.
APPLICABILITY:                   MODES 1, 2, and 3.
ACTIONS CONDITION                                             REQUIRED ACTION                                       COMPLETION TIME A.   --------------NOTE---------------                       ----------------Nate----------------
Not applicable to DG E DC Bus                          Enter applicable Conditions and OD597                                                   Required Actions of LCO 3.8.4,
      -------------------------------------                   "DC Sources- Operating, " for DC source(s) made inoperable One or more Unit 2 AC electrical                        by inoperable power distribution power distribution subsystems                           subsystem(s) .
inoperable.                                             ----------------------------------------
A.1     Restore Unit 2 AC electrical power                         8 hours distribution subsystem(s) to OPERABLE status.                                                    AND 16 hours from discovery of failure to meet LCO 3.8.7 except for Condition F or G
B.   ---------------N0 TE --------------             B.1     Restore Unit 2 DC electrical power                         2 hours Not applicable to DG E DC Bus                           distribution subsystem(s) to OPERABLE OD597                                                   status.                                                   AND One or more Unit 2 DC electrical                                                                                   16 hours from discovery of power distribution subsystems                                                                                     failure to meet LCO 3.8.7 inoperable.                                                                                                       except for Condition F or G
C. One Unit 1 AC electrical power                  C.1     Restore Unit 1 AC electrical power                        72 hours distribution subsystem inoperable.                     distribution subsystem to OPERABLE status.                                                    OR Q&sect; flfill.lFS lMFil'l~ tf1e il'lstallatiel'l ef: tf1e mMitifi)le fiFe il'lll.llel SfilMFil<lS lfileFatili'IS F11filJiHlEltifili'IS il'l Ul'lit 1 ~ 7 days during the replacement of 480 V ESS Load Center Transformers in Unit 1(ll (continued)
( ) Uis temJileFEll)' 24 f1eMr lSFI1filletiel'l time eHtel'lsiel'l is Elfilfillilaele 1MFil'l~ P1&#xa3;Q mslifisatisl'!s te all Ul'lit 1 4.1SIN 1
eMses, "'flile ''l'lit 1 is il'l P101J~&#xa3; 4 sF&sect;, al'!1 will eHfiliFe el'l Ma~* ~1, 2Q12. This temporary 7-day completion time is applicable during the replacement of all Unit 1 480 V ESS Load Center Transformers, while Unit 1 is in MODES 4 or 5, and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                        TS I 3.8-44                                   Amendment 4M, 4-Qa, 208, 238

                                                                                                                                              ~Rev.~
RHRSW System and UHS 3.7.1 3.7                   PLANT SYSTEMS 3.7.1                 Residual Heat Removal Service Water (RHRSW) System and the Ultimate Heat Sink (UHS)
LCO 3.7.1            Two RHRSW subsystems and the UHS shall be OPERABLE.
APPLICABILITY:                     MODES 1, 2, and 3.
ACTIONS
                 -------------------------------------------------------------NOTE----------------------------------------------------------
Enter applicable Conditions and Required Actions of LCO 3.4.8, "Residual Heat Removal (RHR) Shutdown Cooling System-Hot Shutdown ," for RHR shutdown cooling made inoperable by RHRSW System.
CONDITION                                               REQUIRED ACTION                                   COMPLETION TIME A.    ---------------N OlE---------------                 A.1       Declare the associated RHRSW                        Immediately Separate Condition entry is                                  subsystems inoperable.
allowed for each valve.
One valve in Table 3.7.1-1                          A.2       Establish an open flow path to the                  8 hours inoperable.                                                   UHS.
OR One valve in Table 3.7.1-2                          A.3       Restore the inoperable valve(s) to                  8 hours from the discovery inoperable.                                                   OPERABLE status.                                    of an inoperable RHRSW subsystem in the opposite loop from the inoperable valve(s)
One valve in Table 3.7.1-3 inoperable.
72 hours Any combination of valves in Table 3.7.1-1, Table 3.7.1-2, or Table 3.7.1-3 in the same return loop                                                                                   Q@ 19elJn; SllFiFl~ ll9l inoperable.                                                                                                       iFlstallatieFl eftl9e FFllllli13ll fiFl iFlSll66S Si3llFillJS li3lFfillilFlS FFllSifi6rillieFlS iFl
                                                                                                                       ~141 7 days during the replacement of 480 V ESS Load Center Transformers 1X210 and 1X220 in Unit 1(1)
_(continued) 1
( ) U~el9 6lFFl~lstiel9 sftt;te M!ilO Fl'!e1ifi6Eitiel9s el9 t!;ts U19it 1 1/\2Q1 EII911/\2Q2 4.1@ leV Bllsss, t!;tis tsFl'!~emry     Sltsl9siel9 is 19e le19ssr El~~liE>EIBie 8191 will Sl~irs el9 MEiy ~1, 2Q12. Upon completion of the replacement of 480 V ESS Load Center Transformers 1X21 0 and 1X220 in Unit 1, this temporary extension is no longer applicable and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                                TS I 3 .7-1                               Amendment .:te-1-, W, 224 , 238

                                                                                                                  ~Rev.~
RHRSW System and UHS 3.7.1 ACTIONS (continued)
CONDITION                                     REQUIRED ACTION                        COMPLETION TIME B. One Unit 2 RHRSW subsystem                B.1   Restore the Unit 2 RHRSW subsystem        72 hours from discovery inoperable.                                     to OPERABLE status.                       of the associated Unit 1 RHRSW subsystem inoperable OR 9&sect; IHlEI~s Je~~iFl&sect; t~;te iFlstallatieFl ef t~;te Fl1Witi~le fi~e iFlJwseJ s~e~~iews
                                                                                                 @~l~Olti@FlS Fl1@Jifi6Elti9FlS iFl UFlit 1 t4t 7 days during the replacement of 480 V ESS Load Center Transformers 1X21 0 and 1X220 in Unit 1(1)
AND 7 days C. Both Unit 2 RHRSW subsystems              C.1    Restore one Unit 2 RHRSW subsystem        8 hours from discovery of inoperable .                                     to OPERABLE status.                       one Unit 1 RHRSW subsystem not capable of supporting associated Unit2 RHRSW subsystem AND 72 hours D. Required Action and associated            D.1    Be in MODE 3.                             12 hours Completion Time not met.
AND OR D.2    Be in MODE 4.                            36 hours UHS inoperable.
1
( ) UJ39R S9FflJ3IetisR sf tlcle Mli)Q FflSlifisatiSRS SR tlcle 'JRit 1 1!\201 GIR1 1A2Q2 4.19 kV ewses, tiel is teFflJ3SFsFY El)(tSRsisR is Rs lsRser sJ3J3Iisaele sR1 will El)(J3ire sR May ~1, 2012. Upon completion of the replacement of 480 V ESS Load Center Transformers 1X210 and 1X220 in Unit 1, this temporary extension is no longer applicable and will expire on June 15, 2020.
SUSQUEHANNA- UNIT 2                                   TS I 3.7-2                             Amendment .:t-a-:t, .:t-aG, 180 238

Attachment 2 to PLA-7384 Susquehanna Nuclear, LLC Proposed Change to Unit 2 Technical Specification Bases 3.8. 7 "Electrical Power Systems -
Distribution Systems- Operating" and Unit 2 Technical Specification Bases 3.7.1, "Plant Systems - RHRSW System and UHS" (Markups provided for Information Only)

                                                                                                           ~Rev:-4 Distribution Systems-Operating B 3.8.7 BASES ACTIONS          QJ. (continued)
Time of 72 hours is consistent with the Completion Times associated with LCOs for the Unit 2 and common equipment potentially affected by loss of a Unit 1 AC electrical power subsystem .
Tt;te Ce~~letieF1 Ti~e     !;!as l:leef:l l)(teF11e1 te Q@ l;te~e~rs iF1 er1er te se~~lete tt;te
                 ~e1ifisatieF1S iF1 UF1it 1 assesiate1 wit!;! tt;te M~e~lti~le P:ire IF11~e~se1 ~~~e~rie~e~s O~erstief:ls iss~e~e. Tt;tis is a te~~ersry l)deF1sieF1 sf tFie Ce~~letieF1 Ti~e. U~ef:l 1l~~letieF1 eftFie M~O ~e1ifisatieF1s SF1 all fe~e~r UF1it 1 4.1@ I<V l:l~e~ses, tFiis te~~emry e)(teF1sieF1 is F19 IJF1~er a~~lisal:lle af:l1 will @)(~ire JF1 Ma~* ~ 1, 2012.
The Completion Time has been extended to 7 days in order to complete the replacement of the four (4) Unit 1 480 V ESS Load Center Transformers. This is a temporary extension of the Completion Time. Upon completion of the transformer replacement, this temporary extension is no longer applicable and will expire on June 15, 2020.
With two required Unit 1 AC buses, load centers, motor control centers, or distribution panels inoperable for the performance of Unit 1 SR 3.8.1.19 but not resulting in a loss of safety function, the remaining AC electrical power distribution subsystems are 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 failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours.
E.1and E.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the associated Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
If Diesel Generator E is not aligned to the Class 1E distribution system, the only supported safety function is for the ESW system . Therefore, under this condition, if Diesel Generator E DC power distribution subsystem is not OPERABLE, to ensure the OPERABILITY of the ESW system, actions are taken to either restore the power distribution subsystem to OPERABLE status or shutdown Diesel Generator E and (continued)
SUSQUEHANNA- UNIT 2                TS I B 3.8-90                                                          Revision~

                                                                                                           ~Rev.@
RHRSW System and UHS B 3 .7.1 BASES ACTIONS         A.1. A.2 and A.3 (continued)
With any UHS return path valve listed in Tables 3.7.1-1, 3.7.1-2, or 3.7.1-3 inoperable, the UHS return path is no longer single failure proof.
For combinations of inoperable valves in the same loop, the UHS spray capacity needed to support the OPERABILITY of the associated Unit 1 and Unit 2 RHRSW subsystems is affected. As a result, the associated RHRSW subsystems must be declared inoperable.
The 8-hour completion time to establish the flow path provides sufficient time to open a path and de-energize the appropriate valve in the open position .
The 72-hour completion time is based on the fact that, although adequate UHS spray loop capability exists during this time period, both units are affected and an additional single failure results in a system configuration that will not meet design basis accident requirements.
Tl;!e C91ol1t:Jieti9R Tilol1e l;!es seeR e~teRlel te Qe I;!Q~FS iR erler te @9f.l1t:Jiete tl;!e f.l1llifieatieRs iR URit 1 esseeietel wit!;! tl;!e M~ltit:Jie Fire IRl~eel &:t:J~Fie~s Ot:JeFatieRs iss~e. Tt;Jis is e tlf.l1t:J9F8FJ' e~teRsieR ef tt;Je Cer.l1t:JietieR Tif.l1e aRe is Oit:Jt:Jiisaele l~riR&sect; tl;!e 1A2Q1 sRl1A2Q2 e~s f.l19elifieatieRS. IR 9Fler te 59t:Je wit!;!
            *
* tl;!e eeRSe1~eRees ef e LQQj;l, a LOCI\ iR URit 2 eRe tt;Je sl;!~tlevJR ef URit 1 l~riR&sect; tl;!e e){teRlel Cer.l1t:JietieR Tif.l1e, tt;Je fellewiR&sect; eef.l1t:JeRsateF)' aetilRS are Fe1~irel:
: 1) tt;Je affeetelleet:J's St:JFBY array eyt:Jass valves are iR t!;!e et:JeR t:JesitieR aRe 2) tt;Je affeetelleet:J's St:Jray array valves are slesel. Ut:J9R s9f.l1t:JietieR ef tl;!e M&:O f.l19lifieati9RS QR ell fe~r URit 1 4.1e IN e~ses, tl;!is tef.l1t:J9F8f'j e~teRSi9R is RQ leR&sect;er at:Jt:Jiisaele aRe will m<t:Jire eR May :11, 2Q12.
The Completion Time to restore the Unit 2 RHRSW inoperable valves has been extended to 7 days in order to complete the replacement of the Unit 1 480 V ESS Load Center Transformers 1X21 0 and 1X220. This is a temporary extension of the Completion Time and is applicable during the transformer replacement. In order to cope with the consequences of a LOOP, a LOCA in Unit 2 and the shutdown of Unit 1 during the extended Completion Time, the following compensatory actions are required : 1) the affected loop's spray array bypass valves are in the open position and 2) the affected loop's spray array valves are closed . Upon completion of the transformer replacements , this temporary extension is no longer applicable and will exp ire on June 15, 2020 .
If an additional RHRSW subsystem on either Unit is inoperable, cooling capacity less than the minimum required for response to a design basis event would exist.
Therefore, an 8-hour Completion Time is appropriate. The 8-hour Completion Time provides sufficient time to restore inoperable equipment and there is a low probability that a design basis event would occur during this period.
8.1 Required Action 8 .1 is intended to ensure that appropriate actions are taken if one Unit 2 RHRSW subsystem is inoperable. Although designated and operated as a unitized system, the associated Unit 1 subsystem is directly connected to a common header which can supply the associated RHR heat (continued)
SUSQUEHANNA- UNIT 2                       TS I B 3.7-5a                                           Revision 2.

BASES ACTIONS        fU     (continued) exchanger in either unit. The associated Unit 1 subsystem is considered capable of supporting the associated Unit 2 RHRSW subsystem when the Unit 1 subsystem is OPERABLE and can provide the assumed flow to the Unit 2 heat exchanger. A Completion time of 72 hours, when the associated Unit 1 RHRSW subsystem is not capable of supporting the associated Unit 2 RHRSW subsystem, is allowed to restore the Unit 2 RHRSW subsystem to OPERABLE status. In this configuration ,
the remaining OPERABLE Unit 2 RHRSW subsystem is adequate to perform the RHRSW heat removal function . However, the overall reliability is reduced because a single failure in the OPERABLE RHRSW subsystem could result in loss of RHRSW function. The Completion Time is based on the redundant RHRSW capabilities afforded by the OPERABLE subsystem and the low probability of an event occurring requiring RHRSW during this period.
nus   Ce!'&#xa5;1~letieR Til'&#xa5;!e te festefe t~e IJRit 2 RJ.IRS'A' s~o~l:lsyste!'&#xa5;1 as !:leeR l)(teR1e1 te 9@ ~e~o~fs iR ef1ef te l@l'&#xa5;l ~lete t~e l'&#xa5;!e1ifiaatilRS iR URit 1 asslliate1 wit~ t~e M~o~lti~le Fim IR1~o~ae1 S~~o~fil~o~s O~eratilRS iss~o~e. IRis is a tel'&#xa5;!~lfafy @)GRSilR lf t~e Cli'&#xa5;1~letilR Til'&#xa5;!e aR1 is a~~liaal:lle 1~o~fiR~ t~e 1/\2Q1 aR11/\2Q2 l:l~o~s l'&#xa5;!l1ifiE>atieRs.
T~e IJRit 2 RJ.IRSW s~o~l:lsyste!'&#xa5;1 fll'&#xa5;!aiRs f~o~RE>tieRal siR6l t~e s~o~l:lsyste!'&#xa5;1 ~as aR l~lfal:lle ~loll'&#xa5;!~, l~lfal:lle fllw ~at~ aR1 aR l~lfal:lle IJJ.IS. ld~lR 6@1'&#xa5;1~1etilR lf t~e MSO l'&#xa5;!l1ifiE>atilRS lFI all fl~o~f 'JRit 1 4.1@ kV l:l~o~ses, t!;;Jis tel'&#xa5;!~erary exteRsilR is Rl leR~Bf a~~liaal:lle aR1 will @)E~im eR May :31 , 2Q12.
The Completion Time to restore the Unit 2 RHRSW subsystem has been extended to 7 days in order to complete the replacement of the Unit 1 480 V ESS Load Center Transformers 1X210 and 1X220. This is a temporary extension of the Completion Time and is applicable during the transformer replacement. The Unit 2 RHRSW subsystem remains functional since the subsystem has an operable pump, operable flow path and an operable UHS. Upon completion of the transformer replacements ,
this temporary extension is no longer applicable and will expire on June 15, 2020.
With one RHRSW subsystem inoperable and the respective Unit 1 RHRSW subsystem capable of supporting the respective Unit 2 RHRSW subsystem, the design basis cooling capacity for both units can still be maintained even considering a single active failure. However, the configuration does reduce the overall reliability of the RHRSW System. Therefore, provided the associated Unit 1 subsystem remains capable of supporting its respective Unit 2 RHRSW subsystem, the inoperable RHRSW subsystem must be restored to OPERABLE status within 7 days. The 7-day Completion Time is based on the remaining RHRSW System heat removal capability.
Required Action C.1 is intended to ensure that appropriate actions are taken if both Unit 2 RHRSW subsystems are inoperable. Although designated and operated as a unitized system , the associated Unit 1 subsystem is directly connected to a common header which can supply the associated RHR heat SUSQUEHANNA- UNIT 2                           TS I 3.7-2                                    Amendment 4-M, ~
180 238}}