View source for PLA-5734, Proposed License Amendment Numbers 263 for Unit 1 and 228 for Unit 2 for a One-time Change to Technical Specifications 3.6.4.1 and 3.6.4.3, Completion Time for Secondary Containment and Standby Gas Treatment Subsystems

{{Adams
| number = ML042600070
| issue date = 09/08/2004
| title = Proposed License Amendment Numbers 263 for Unit 1 and 228 for Unit 2 for a One-time Change to Technical Specifications 3.6.4.1 and 3.6.4.3, Completion Time for Secondary Containment and Standby Gas Treatment Subsystems
| author name = Mckinney B
| author affiliation = PPL Susquehanna, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000387, 05000388
| license number = NPF-014, NPF-022
| contact person = 
| case reference number = PLA-5734
| document type = Letter type:PLA, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 53
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:Britt T. McKlnney               PPL Susquehanna, LLC                      '   II Vice President-Nuclear Site Operations                 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 ppI *:i btmckinney~pplweb.com                          I00- -
SEP 0 8 2004 va.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED LICENSE AMENDMENT NUMBERS 263 FOR UNIT 1 AND 228 FOR UNIT 2 FOR A ONE-TIME CHANGE TO TECHNICAL SPECIFICATIONS 3.6.4.1 AND 3.6.4.3, COMPLETION TIME FOR SECONDARY CONTAINMENT AND STANDBY GAS TREATMENT SUBSYSTEMS                                                     Docket Nos. 50-387 PLA-5734                                                                                     and 50-388 Pursuant to 10 CFR 50.90, PPL Susquehanna, LLC (PPL) hereby requests the following amendments to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications (TS), as described in the enclosure. The proposed amendments would change the Technical Specifications for Secondary Containment and the Standby Gas Treatment System (SGTS) to extend, on a one-time basis, the allowable Completion Time for Required Actions for Secondary Containment inoperable and two SGTS subsystems inoperable, in Mode 1, 2, or 3, from 4 hours to 48 hours. This change is needed to allow sufficient time for the planned replacement of the Reactor Building Recirculating Fan Damper Motors while both units remain at power, thus avoiding a two unit shutdown. The reason for the replacement is to complete required Equipment Qualification preventive maintenance on these dampers.
As demonstrated in the enclosed evaluation, the proposed amendments do not involve a significant hazards consideration.
The justification for the change to the Secondary Containment and Standby Gas Treatment Required Action Completion Times is based upon the evaluation presented in the Enclosure.
PPL Susquehanna, LLC requests approval of the proposed one-time change to the SSES Technical Specifications by August 1, 2005 to support the planned replacement of the Reactor Building Recirculating Fan Damper Motors, to be performed in September 2005.
This one-time change would be effective from the date of issuance until December 31, 2005.                                                                                      4c         %

Document Control Desk PLA-5734 Attachments 1 and 2 are the Technical Specifications marked-up and retyped. lists the PPL Susquehanna, LLC Regulatory Commitments that would derive from NRC's approval of the proposed amendment. For your information,  is a mark-up showing the changes to the Technical Specification Bases.
The need for this change has been discussed with the SSES NRC Project Manager.
The proposed changes have been approved by the SSES Plant Operations Review Committee and reviewed by the Susquehanna Review Committee. In accordance with 10 CFR 50.91(b), PPL Susquehanna LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.
Should you have any questions or require additional information, please contact Mr. Michael H. Crowthers at (610) 774-7766.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:__________
B. T. McKinne

==Enclosure:==

PPL Susquehanna Evaluation of the Proposed Changes Attachments:  -   Proposed Technical Specification Changes (Mark-up)  -   Proposed Technical Specification Pages (Retyped)  -   List of Regulatory Commitments  -    Changes to Technical Specifications Bases Pages (Mark-up)
Copy: NRC Region 1 Mr. A. J. Blamey, Sr. Resident NRC Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. Janati DEPIBRP

Enclosure to PLA-5734 PPL Susquehanna Evaluation of Proposed One-Time Change to Technical Specifications 3.6.4.1 and 3.6.4.3, Completion Time for Secondary Containment and two Standby Gas Treatment Subsystems Inoperable
: 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 CONSIDERATION
: 7. 

==SUMMARY==
: 8. REFERENCES

Enclosure to PLA-5734 Page 1 of 24

==SUBJECT:==
Application for a one-time amendment to Technical Specifications 3.6.4.1 and 3.6.4.3, to allow extension of Completion Time of Required Actions for Secondary Containment inoperable and two Standby Gas Treatment Subsystems inoperable.

==1.0    DESCRIPTION==

The proposal would change the Technical Specification for Secondary Containment and the Standby Gas Treatment System (SGTS), to extend, on a one-time basis, the allowable Completion Time for Required Actions for Secondary Containment and two SGTS subsystems inoperable in Mode 1, 2, or 3, from 4 hours to 48 hours, while both units remain at power. The requested changes are based upon the Susquehanna Steam Electric Station (SSES) Technical Analysis presented in Section 4.0 of the evaluation. The proposed changes would allow sufficient time for the planned replacement of the two Reactor Building Recirculating Fan Damper Motors (HDMO7545A and HDMO7545B),
while both units remain at power.
Damper motor HDMO7545B is at the end of its qualification life. The lifetime was extended via reanalysis. It has been determined that replacement is required. Although damper motor HDMO7545A does not require replacement at this time, it is deemed prudent to replace it concurrently. Following replacement, both dampers will be qualified to the end of current plant life.

==2.0     PROPOSED CHANGE==

In order to effect this one-time change, Technical Specification (TS) 3.6.4.1 Secondary Containment would be revised by modifying the Completion Time for Required Action A. The modification includes a new Completion Time, which reads "48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Motors, to be completed by December 31, 2005." This new Completion Time will be connected with a logical connector "OR." The changes to TS 3.6.4.1 are marked-up on Technical Specification pages in Attachment 1.
TS 3.6.4.3 SGTS System would also be revised by modifying the Completion Time for Required Action D. The modification includes a new Completion Time, which reads "48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Motors, to be completed by December 31, 2005." This new Completion Time will be connected with a logical connector "OR." The changes to TS 3.6.4.3 are marked-up on Technical Specification pages in Attachment 1.

Enclosure to PLA-5734 Page 2 of 24 Upon approval of the proposed change, PPL Susquehanna will revise TS Bases 3.6.4.1 and 3.6.4.3 under the Technical Specifications Bases Control program, by inserting the information below (see Attachment 4).
A temporary (one-time) Completion Time is connected to the Completion Time requirements above (4 hours) with an "OR" connector. The temporary Completion Time is 48 hours and applies to the replacement of the Reactor Building Recirculating Fan Damper Motors. The temporary Completion Time of 48 hours may only be used once, and expires on December 31, 2005.
Marked-up and retyped Technical Specification pages and marked-up Technical Specification Bases pages, which incorporate the proposed changes, are provided in Attachments 1, 2, and 4, respectively. Attachment 3 is the list of Regulatory Commitments.

==3.0     BACKGROUND==

During normal operation, the Secondary Containment is required to be kept at a minimum negative pressure of 0.25 inches of water gauge with respect to outside. This is to assure that all leakage will be into the Secondary Containment. During normal operation this is accomplished by non-safety related HVAC systems.
When a Secondary Containment isolation signal is received, the safety related Reactor Building (RB) Recirculating and SGTS fans start and the normal operating, non-safety related HVAC systems are tripped. The isolated Secondary Containment zones will align to the RB Recirculation Plenum by opening of isolation dampers. The SGTS is connected to and draws air from the RB Recirculation Plenum. The removal of air from the Recirculation Plenum maintains the Secondary Containment at a negative pressure of 0.25 inches of water gauge with respect to outside.
3.1      Definition of Zone Boundaries The Secondary Containment is divided into three isolated ventilation zones. Zones I and 11 surround respective Units 1 and 2 Primary Containment below the floor at elevation 779 ft-1 in. and also include stairwells and elevator machine rooms and shafts above elevation 779 ft-1 in. Zone III includes Units 1 and 2 Secondary Containment above the floor at elevation 779 ft-1 in. including the refueling floor, but excluding the HVAC fan and equipment rooms.

Enclosure to PLA-5734 Page 3 of 24 3.2    System Descriptions 3.2.1 Secondary Containment The following are provided to control fission products within the Secondary Containment following a design basis accident:
a)    A Secondary Containment that completely surrounds each of the two Primary Containments.
b)    The Standby Gas Treatment System (SGTS).
c)   A Recirculation System.
The Secondary Containment consists of a reinforced concrete structure up to the refueling floor (El. 818 ft. 1 in.) and of a metal sided superstructure above El. 818 ft. 1 in.
The Secondary Containment consists of the three ventilation zones (I, II, and III) discussed above.
The SGTS is used to maintain the affected zone(s) of the Secondary Containment at a negative pressure.
3.2.2 Standby Gas Treatment System (SGTS)
The Standby Gas Treatment System is designed to accomplish the following safety related objectives:
a)   Exhaust sufficient filtered air from the reactor building to maintain a minimum negative pressure of 0.25 inches of water in the affected volumes following Secondary Containment isolation for the following design basis events:
(1)     Irradiated fuel handling accident in the refueling floor area (2)     Loss of Coolant Accident (LOCA) b)   Filter the exhausted air to remove radioactive particulates and both radioactive and non-radioactive forms of iodine to limit the offsite dose to the guidelines of 10 CFR 100.
Non-safety-related objectives for design of the SGTS are as follows:
a)   Filter and exhaust air from the Primary Containment for purging and ventilating.

Enclosure to PLA-5734 Page 4 of 24 b)    Filter and exhaust discharge from the High Pressure Coolant Injection HPCI barometric condenser.
c)    Filter and exhaust from the Primary Containment pressure relief line.
d)    Filter and exhaust nitrogen from the Primary Containment for nitrogen purging.
The airflow diagram for the SGTS is shown on the enclosed P&ID M-175, Sheet 2 and on the FSAR Figures in Section 6.2.3.
A common Recirculation system is provided for Units 1 and 2 to perform the following safety-related functions:
a)    Mix the atmosphere in the Reactor Building to obtain a lesser and more uniform concentration of radioactivity following a Design Basis Accident (DBA) Loss Of Coolant Accident (LOCA) or a refueling accident.
b)    Prevent the spread of radioactivity by the heating-ventilating-cooling systems.
between Zone III and Zones I or II during and after an irradiated fuel handling accident.
c)   Provide mixing of the atmosphere within the Reactor Building. This may involve mixing the atmosphere of all three zones; of Zone I or Zone II and.
the refueling area (Zone III); or of Zone III alone, particularly in case of the fuel handling accident in b), above.
The Reactor Building Recirculating System is shown on the enclosed Standby Gas Treatment System flow diagram, P&ID M-175, Sheet 2.
3.3     Configuration Impacts During this work evolution, the access hatch to the reactor building recirculation plenum will be removed for the duration of the work activity. Removal of the access hatch allows the recirculation plenum air space to interact with the surrounding environment (Unit I railroad bay). For this evolution, the Unit 1 Railroad Bay will be aligned to Secondary Containment (Zone III). Therefore, opening the reactor building recirculation plenum hatch does not allow Secondary Containment to directly communicate with the environment and therefore does not represent a leakage pathway out of Secondary Containment.

Enclosure to PLA-5734 Page 5 of 24 To provide for worker safety, the power to the SGTS fans and Recirculation fans will be isolated during the work evolution, necessitating entry into the two LCO's. Therefore, should a Secondary Containment isolation signal occur, these fans will not perform their intended functions until power is restored and the recirculation plenum hatch is reinstalled.
3.4     FSAR References Related background in the SSES FSAR (Reference 1) is found in Section 1.2.
Compliance with NRC design criteria is described in detail in FSAR Sections 3.1 and 3.13. Detailed descriptions can be found in the SSES FSAR Section 6.2.3 Secondary Containment Functional Design, Section 6.5.1.1 Standby Gas Treatment System, and Section 6.5.3.2 Secondary Containment.

==4.0     TECHNICAL ANALYSIS==

The proposed changes have been evaluated. It has been determined that current regulations and applicable requirements continue to be met, that adequate defense-in-depth and sufficient safety margins are maintained, as discussed in Section 4.2.
The justification for the use of a 48-hour Secondary Containment and Standby Gas Treatment subsystems extended Completion Time is based upon:
: 1) a radiological evaluation of the impact on DBA-LOCA doses including doses offsite, control room habitability, and exposures for personnel access (Section 4.1),
: 2) the risk-mitigating requirements (i.e., equipment required to be maintained operable), which will exist during the replacement of the Reactor Building Recirculation Fan Damper Motors (Section 4.2.1 - 4.2.4), and
: 3) the Susquehanna Steam Electric Station risk management process which will assess the risk impacts of planned and emergent work during the replacement.
4.1     Radiological Evaluation Two radiological dose analyses have been performed to evaluate the one-time SGTS Technical Specification change:
4.1.1. DBA-LOCA Doses - Offsite and Control Room Habitability Analysis An evaluation of the impact on the FSAR Chapter 15 DBA-LOCA dose analysis was performed assuming restoration of Secondary Containment and the Standby Gas Treatment System (SGTS) is within the worst case time scenario. This analysis addresses both offsite and control room doses. For the discussions given below, use of the term Reactor Building is synonymous with secondary containment.

Enclosure to PLA-5734 Page 6 of 24 This analysis uses Reactor Building leakage rates consistent with DBA-LOCA conditions. Since the Reactor Building will be isolated for a DBA-LOCA, no ventilation systems will be operating during the time period it takes to restore SGTS. Therefore, the only driving force for airborne leakage from the Reactor Building to the environment during this time period would be post-accident airborne leakage from containment (1% per day) and Engineered Safety Features (ESF) Recirculation system leakage (20 gpm). Therefore, for the time period to restore SGTS, the activity release rate to the environment from the Reactor Building is assumed to be at a volumetric leakage rate equivalent to the leakages from containment and from ESF system leakage. This includes containment airborne leakage and ESF Recirculation systems leakage.
In support of this assumption, a parametric study was performed to evaluate the impact that Reactor Building leakage will have on DBA-LOCA doses for restoration of SGTS.
This parametric study demonstrates that Reactor Building leakage rates would have to be significantly higher than expected, under DBA-LOCA conditions with SGTS not operating, for 10 CFR 100 offsite dose limits or 10 CFR 50, Appendix B, Criterion 19 control room dose limits to be exceeded. All other assumptions used for this analysis will be the same as used in FSAR DBA-LOCA Section 15.6.5.
DBA-LOCA doses are evaluated for the worst case time scenario for restoration of SGTS. This worst case scenario assumes restoration of SGTS is completed within 200 minutes. Personnel actions and restoration times for these actions are discussed in Section 4.2.3.
Activity flow path models for both the FSAR DBA-LOCA Chapter 15.6.5 analysis and the DBA-LOCA dose analysis for restoration of SGTS for recirculation fan damper work are given in Figures 1 and 2. The accident sequence of events for each of these dose models is given in Tables I and 2. The model used to evaluate DBA-LOCA doses for restoration of SGTS differs from the FSAR DBA-LOCA model with respect to reactor building mixing volume modeling and reactor building leakage rates to the environment.
These differences are discussed below:
FSAR DBA-LOCA Chapter 15.6.5 Dose Analvsis The activity release rate to the environment from the reactor building for the FSAR DBA-LOCA model is based on ventilation systems operating and the design reactor building leakage rate of 200 %/day for a 50% building mixing efficiency. During a postulated DBA-LOCA, containment leakage into the reactor building will occur in reactor building ventilation Zones I for a Unit 1 event or in Zone II for a Unit 2 event. There is no containment leakage path directly into reactor building Zone III, which is the refueling floor for both units located on elevation 818'-1". Activity transport into Zone III under DBA-LOCA conditions can only occur if the reactor building recirculation system is running. The sequence of events identified in Table I for the FSAR DBA-LOCA

Enclosure to PLA-5734 Page 7 of 24 actually shows that reactor building ventilation systems will not be operating for the first ten seconds post-accident. However, in order to simplify the FSAR DBA-LOCA activity release model, reactor building mixing in all three ventilation zones was assumed for this 10-second time period. Since the reactor building leakage rate is specified as one percent per day, the assumption of two zone vs. three zone mixing has no impact on the reactor building activity release rate to the environment. Also, even though ventilation systems are not operating, the design reactor building leakage rate to the environment was also conservatively assumed for the first ten seconds. This was also done to simplify the activity release model. Since this only involved a ten second release duration, these assumptions had no significant impact on DBA-LOCA doses.
DBA-LOCA Dose Analysis For Restoration Of SGTS For Recirculation Fan Damper Work The activity release rate from the reactor building to the environment for the time it takes to restore the Standby Gas Treatment and Recirculation Systems is based on ventilation systems not operating . Since there is no containment leakage path directly into reactor building Zone III for the 200 minute time period to restore SGTS, one zone mixing (Zone I or Zone II mixing) is conservatively assumed. The activity release rate to the environment from the reactor building during this time period when ventilation systems are not operating is assumed to be at a volumetric leakage rate equivalent to the rate of containment and ESF system leakage into the reactor building. This leakage rate is equivalent to 10 SCFM. The sequence of events for restoring SGTS for recirculation fan damper work is discussed in Section 4.2.3. After SGTS is restored, the reactor building mixing model and leakage rates are the same as used for the FSAR DBA-LOCA Chapter 15.6.5 analysis. Also, all reactor building volume mixing models assume a 50% mixing efficiency.
4.1.2 DBA-LOCA Doses - Personnel Exposures Analysis The second analysis performed determined doses to plant personnel who would be taking the restoration actions described in Section 4.2.3, restoring under the highly unlikely assumption that a DBA-LOCA occurs during the Reactor Building Recirculation Fan Damper Motor work. This analysis addresses personnel doses in each of the work areas for work tasks to restore SGTS and the dose resulting from ingress/egress to these areas.
This analysis is consistent with SSES FSAR Section 18.1.20. Personnel radiation exposures for restoration of SGTS are evaluated for DBA-LOCA component/piping contained sources. Personnel requirements and restoration times are given in Section 4.2.3.
4.1.3 Radiological Results An evaluation of the impact on the DBA-LOCA dose analysis, assuming that restoration of SGTS occurs within 200 minutes due to Reactor Building Recirculation Fan damper

Enclosure to PLA-5734 Page 8 of 24 motor work, was performed. Reactor Building leakage rates consistent with DBA-LOCA conditions and ventilation systems inside the Reactor Building not operating were used. Results of this analysis show that sufficient time exists to restore SGTS without impact on current DBA-LOCA doses, as given in FSAR Chapter 15.6.5, which are well within the limits of 10 CFR 100, and without impact on control room doses, as specified in 10 CFR 50, Appendix A, GDC19.
A dose analysis was also performed to evaluate the impact of Reactor Building leakage for restoration of SGTS under DBA-LOCA conditions. The Reactor Building leakage rate during restoration of SGTS, necessary to equate to the limits of 10 CFR 100 and GDC 19, is 424 SCFM (82%/day). The expected Reactor Building leakage rate without ventilation systems operating is 10 SCFM (1.935%/day). These results show that Reactor Building leakage rates would have to be significantly higher, during the 200 minute delay in startup SGTS, than the leakage rate expected under DBA-LOCA conditions with Reactor Building Ventilation Systems not operating for 10 CFR 100 or 10 CFR 50, Appendix A, GDC19 limits to be exceeded.
Personnel DBA-LOCA radiation exposures for restoration of SGTS during damper motor replacement of the Reactor Building Recirculation Fan damper motor are as follows:
Maximum dose to an individual = 0.035 Rem Total Exposure To All Individuals = 0.19 person-Rem The personnel radiation exposure limit for vital area access under design basis accident conditions is 5 Rem whole body or its equivalent to any part of the body (10 CFR 50, Appendix A, GDC 19). DBA-LOCA doses to personnel for restoration of SGTS are well within the 5 Rem dose limit.

Enclosure to PLA-5734 Page 9 of 24 ENVIRONMENT REACTOR BUILDING tQ      2,878,000 ft3 (3 Zone Mixing)                   Efficiency =99%                SGTS DISCHARGE
_    . _   _     b CONTAINMED                                                              (0-30 sec)     0 CFM
    'D     388,190 ft3        Suppression Pool                                (30 sec - 3 min)   10,500 CFM
(> 3 min)      4000 CFM Scrubbing        CONTAINMENT LEAKAGE         -
Efficiency:
(F: {II}
I-4 (0-3 min) 0%                                 (0-30 days) 2.64 CFM
(>3 min) 0% Organic 87.4% Elenr 87.4% Part.                                                        CONTAINMENT BYPASS LEAKAGE 4                           I-(O- 30 days) 0.05591 CFM Suppression Pool Scrubbing SUPPRESSION POOL 0       132,000 ft3 REACTOR BUILDING LEAKAGE (0-3min)      200 %Iday
(> 3 min)     0%7/day Efficiency = 90%
ESF Leakage (0-30 days) 2.674 CFM FIGURE 1. DBA-LOCA TACI5 ACTIVITY FLOW PATH MODEL; FSAR LICENSING BASIS ANALYSIS

Enclosure to PLA-5734 Page 10 of 24 ENVIRONMENT Q     REACTOR BUILDING (0-200 min) 744,300 ft3 (Zone 1)                 Efficiency =99%          SGTS
(>200 min) 2,878,000 ft3 (3 Zone Mixing)                              DISCHARGE (0-200 min)        0 CFM 0     CONTAINMEr 388,190 ft3        Suppression Pool Scrubbing (200 min-203 min) 10,500 CFM
(> 203 min)        4000 CFM CONTAINMENT LEAKAGE        -
Efficiency:
(0-3 min) 0%          g:{II}               I1 (0-30 days) 2.64 CFM
(>3 min) 0% Organic 87.4% Elen 87.4% Part.                                                   CONTAINMENT BYPASS LEAKAGE (0 - 30 days) 0.05591 CFM Suppression Pool Scrubbing A}
OSUPPRESSION POOL 132,000 ft3 REACTOR BUILDING
                                                                          ~I.      LEAKAGE             _
I                                                ( 0 - 200 min)         1.935 %/day (200 min-203 min) 200%/day
(>203 min)             0 %/day
                      ?   Efficiency = 90%
(Note: 1.935%/day is reactor building leakage rate to the ESF Leakage                                                  environment equivalent to the (0-30 days) 2.674 CFM                                            volumetric rate of containment + ESF leakage into reactor building = 10 scfm.)
FIGURE 2. DBA-LOCA TACT5 ACTIVITY FLOW PATH MODEL; SGTS RESTORATION TIME = 200 MINUTES FOR RECIRCULATION FAN DAMPER WORK

Enclosure to PLA-5734 Page 11 of 24 TABLE 1. :SEQUENCE OF EVENTS - DBA-LOCA FSAR:
::-    -       .LICENSING        BASIS-ANALYSIS            -:~~;-
                    -(See Figure 1 for-Activity Flow Path Model)             -
Time From DBA-LOCA                                 --Description.,''
0                --DBA-LOCA occurs 10 sec              --Standby Gas Treatment System Exhaust Fans Start
                                 --Reactor Building Recirc Fan Fails To Start 25 sec              --Standby Gas Treatment System Exhaust Fans Reach Full Flow
                                 --Second Reactor Building Recirc Fan Starts (15 Second Timer) 30 sec              --Reactor Building Recirc Fan Reaches Full Flow 3 min               --Reactor Building drawdown to negative pressure complete
                                 --End of reactor coolant system blowdown and
._                                 suppression pool scrubbing TABLE 2. SEQUENCE OF EVENTS - DBA-LOCA-SGTS RESTORATION TIME - 200 MINUTES FOR RECIRCULATION FAN,
:-DAMPER WORK.:
                .    (See Figure 2 for Activity Flow Path Model)
Time From DBA-LOCA                      -.          Description          -
0                --DBA-LOCA occurs 3 min              --End of reactor coolant system blowdown and suppression pool scrubbing 200 min             --SGTS restored
                                --Standby Gas Treatment System Exhaust Fans Start
                                --Reactor Building Recirc Fan Starts 203 min             --Reactor Building drawdown to negative pressure complete Note: For restoration of SGTS, no credit for a delay in the SGTS fans or the reactor building recirculation fans reaching full flow is conservatively assumed.

Enclosure to PLA-5734 Page 12 of 24 4.2     Deterministic Considerations SSES is designed and operated consistent with the defense-in-depth philosophy. The defense-in-depth philosophy in reactor design and operation results in multiple means to accomplish safety functions and prevent release of radioactive material. The impact of the proposed Technical Specification changes were evaluated and determined to be consistent with the defense-in-depth philosophy.
The unavailability of Secondary Containment and two Standby Gas Treatment subsystems is already considered in the plant design and is allowed by the current Technical Specifications for four hours. Even with the Standby Gas Treatment System out of service, the Reactor Building is still an intact structure, which mitigates any potential release. The Radiological Analysis confirms the adequacy of defense-in-depth and that protection of the public health and safety are ensured. Implementation of the proposed changes will be done in a manner consistent with the defense-in-depth philosophy. Station procedures will ensure consideration of prevailing conditions, including other equipment out of service, and implementation of compensatory actions to assure adequate defense-in-depth while the Reactor Building Recirculation Fan Damper Motors are replaced.
These proposed changes do not require any new operator response or introduce any new opportunities for operator errors not previously considered. Experienced personnel will perform the Reactor Building Recirculation Fan Damper Motors replacement within the time available, while both units remain on-line. No other new operator actions are necessary.
The performance of the damper motor replacement has been added to the dual-unit shutdown list. Should that opportunity occur prior to the planned replacement, the motors will be replaced at that time and thus the proposed change will not be used.
4.2.1   Compensatory Actions / Restrictions The following mitigating measures will be taken, prior to and/or during the work, to increase the ability to identify and take appropriate actions before a problem arises:
* Engineering Inspections of Containment will be performed. These will include, prior to the work:
    >    Testing for leak tightness of the Secondary Containment Structure per Technical Specification Surveillance Requirement 3.6.4.1.4 & 3.6.4.1.5
    > Testing for Secondary Containment Bypass Leakage paths
* Movement of irradiated fuel within secondary containment will be prohibited during the extended LCO period.

Enclosure to PLA-5734 Page 13 of 24
* High-risk activities within the confines of the plant that may result in a loss of offsite power during the replacement will be prohibited.
* High-risk grid activities that may result in a loss of offsite power during the replacement will be prohibited.
* For the duration of the damper motor replacement, Transmission and Distribution Operations will not grant any work requests that would jeopardize the reliability of offsite power.
* Surveillance testing of Diesel Generator 'E' (Fifth Non-Technical Specification) will be performed before damper motor replacement to assure its availability.
* Reactor Building HVAC will be required to be available during damper motor replacement.
4.2.2 External Events Monitoring Per normal operating procedures, the Control Room will monitor weather conditions for imminent external events such as external flood or forest fire threat prior to and during the replacement.
Additionally, geomagnetic activity from solar storms will be monitored via forecasts provided to the PJM Interconnection, prior to and during the replacement.
The Control Room will instruct modification of work if conditions warrant.
4.2.3 Contingency Planning (Work Planning Actions)
The provisions, which will be made, to restore a functional train of SGTS during replacement of the actuator for the Recirculation plenum fan discharge damper are given in Table 3. Note that preparations will be made for Blade Seal Replacement, however, it is anticipated that this will not be necessary. Arrangements will be made for a dedicated secondary containment and SGTS restoration team.

Enclosure to PLA-5734 Page 14 of 24 Table 3
                      . equenceof Events and Manpower Estimates S
to Restore SGTSDuring Re'placement of the Actuator for the Recirculation-Plenum Fan Discharge Damper :                 -
Time          >7-Post-LOCA         ;'Task              npoe&#xa2;.
Ma&#xa2;t'             .        ...Work' Locto (minutes)        -                    -.           ;equirenent 0- 30       Blade Seal         3 Mechanics    Reactor Building Unit 1 Elevation 779'-1",
Replacement                       Recirculation Supply Plenum Chamber, Room 1-615 30 - 60      Wire Damper       3 Electricians  Reactor Building Unit 1 Elevation 779'-1",
Closed                            Recirculation Supply Plenum Chamber, 60_120_akeDow and3Mechanics        Room 1-615 60-120       Take Down and 3 Mechanics         Reactor Building Unit 1 Elevation 779'-1",
Secure Scaffold                   Recirculation Supply Plenum Chamber, Picks                             Room 1-615 120 - 140     Install Plenum 2 Mechanics        Reactor Building Unit 1 Elevation 779'-1",
Hatch                             Recirculation Supply Plenum Chamber, Room 1-615 140 - 170     Restore Power     2 Operators     Reactor Building Elevation Unit 1 749'-1" to OV201A                         ESS Switchgear Rooms 1-507 & I-5 10 and/or B 170 - 200     Restore Power     2 Operators     Control Structure Elevation 783'-0", H&V to OV109A                         Equipment Room C-700 and/or B Note:
These tasks were established using input from personnel familiar with the activity. The tasks and durations were validated during a planning walkdown entry into the Recirculation Plenum. Human performance tools are being factored into the final work plans. Work Plan briefings and rehearsals will be performed.

Enclosure to PLA-5734 Page 15 of 24 4.2.4 Prohibitions on Preventive Maintenance The following systems and components are required to be available during the replacement to reduce the plant risk:
Description'-
STATION PORTABLE DIESEL GENERATOR - BLUE MAX DIESEL GENERATOR A ESS 480V MOTOR CONTROL CENTER DIESEL GENERATOR B ESS 480V MOTOR CONTROL CENTER DIESEL GENERATOR 'A' DIESEL GENERATOR 'B' DIESEL GENERATOR 'C' DIESEL GENERATOR 'D' DIESEL GENERATOR 'E' U-1 125V DC BATTERY CHARGER BREAKER OB516073 U-1 125V DC BATTERY CHARGER BREAKER OB526073 U-1 125V DC BATfERY CHARGER ID613 U-1 125V DC BATTERY CHARGER 1D623 RHR LOOP A INJECTION OB ISO VLV, (Unit 1)
RHR LOOP A INJECTION FLOW CONTROL VLV, (Unit 1)
RHR LOOP B INJECTION FLOW CONTROL VLV, (Unit 1)
RHR LOOP B INJECTION OB ISO VLV, (Unit 1)
U-2 125V DC BATT7ERY CHARGER BREAKER OB516071 U-2 125V DC BATTERY CHARGER BREAKER OB526071 U-2 125V DC BATTERY CHARGER 2D613 U-2 125V DC BATTERY CHARGER 2D623 RHR LOOP A INJECTION FLOW CONTROL VLV, (Unit 2)
RHR LOOP A INJECTION OB ISO VLV, (Unit 2)
RHR LOOP B INJECTION OB ISO VLV, (Unit 2)
RHR LOOP B INJECTION FLOW CONTROL VLV, (Unit 2)
RHR/RHRSW CROSS TIE VALVES (Unit 1)
RHR/RHRSW CROSS TIE VALVES (Unit 2)
HPCI (UNIT 1)
HPCI (UNIT 2)
RCIC (UNIT 1)
RCIC (UNIT 2)
REACTOR BUILDING HVAC

Enclosure to PLA-5734 Page 16 of 24 To ensure these systems and components are available, elective maintenance will not be performed and these systems will be maintained operable. Any failed system/component will be returned to operable status as soon as possible. (The failed system/component shall be worked around the clock.)
Should any of the above equipment or systems become unavailable or inoperable, SSES will immediately begin and promptly complete an evaluation of the impact, to determine if the basis for the change to LCO 3.6.4.3 remains valid, and within 1 hour of identification, contact the NRC Resident Inspector.
4.3     Risk Consideration This section provides the results of the risk considerations, and details the risk insights pertaining to the proposed Completion Time for the work.
The Reactor Building Recirculation Fan damper motor replacement requires entry into the Secondary Containment TS 3.6.4.1A and the SGTS TS LCO 3.6.4.3.D, since a manway into the Recirculation Plenum will be open, and since both Recirculation fans and both SGTS fans will be tagged out for personnel protection. The Recirculation Plenum is common to the two SGTS subsystems, hence both SGTS subsystems will be inoperable until the Recirculation Plenum hatch is restored. A 48-hour work window is requested for this activity. During this work evolution, the integrity function of Secondary Containment will not be affected. Opening the Recirculation Plenum does not allow Secondary Containment to communicate with the outside environment.
(See Section 3.3.)
SGTS does not provide any core damage mitigation and would not be credited in a full level 2 analyses to mitigate LERF (PPL has a CDF and LERF model but does not have a full level 2 model). Hence, if a risk model were used for the risk evaluation, there would be no change in risk because SGTS does not change any initiating event frequency, it does not mitigate core damage, and does not mitigate a large early release.
PPL's risk model (without SGTS) was peer reviewed in October 2003 and there were no comments concerning the exclusion of SGTS from either the CDF or LERF portions of the model.
4.3.1 Core Damage Mitigation SGTS does not provide any core damage mitigation because it does not provide any makeup capability to the reactor vessel nor does it support depressurizing the reactor vessel.

Enclosure to PLA-5734 Page 17 of 24 SGTS is designed to accomplish the safety related objectives listed in Section 3.2. One of the design bases employed for sizing the filters, fans, and associated ductwork is as follows:
Each train is sized and specified for treating incoming air mixture at a maximum of 1251F, and containing fission products and incoming particulates equivalent to 1.0 volume percent per day of the fission products available in the Primary Containment as determined in accordance with Regulatory Guide 1.3 and TID14844 (References 1 and 2).
The situations in which SGTS can be effective in mitigating a release are those, after an initiating event, which result in core damage, the containment pressurizes, a leak path exists to the Reactor Building and the Secondary Containment release boundary is intact.
All four elements, core damage, containment pressure (the driving force for a release), a leak path, and an intact Secondary Containment release boundary are necessary for SGTS to be effective in mitigating a release. It should be also noted that SGTS has limitations as to the quantity of leakage it can process.
4.3.2 Large Early Release The following discussion illustrates why SGTS is not effective for a large release.
To be a large release, which could potentially be mitigated by SGTS, a release would need to be from the Reactor Building, and the Secondary Containment release boundary would need to be intact. The release would need to be caused by fuel damage, containment pressurization, and either containment failure or containment isolation failure. SSES has modeled two mechanisms for containment failure, Containment Over Pressure Failure (COPF) and Containment Over Temperature Failure (COTF). A COTF failure is caused by the heating of the containment atmosphere directly by the fuel or by a concrete-core interaction. This can occur two ways, a low-pressure vessel failure with no drywell sprays or by a high-pressure vessel failure with the exiting fuel directly heating the containment atmosphere (DCH). In the low-pressure vessel failure case with drywell spray failure, the fuel interacts with the drywell floor, heating the containment atmosphere from the concrete-core interaction. In the high-pressure vessel failure case, the fuel is expelled from the failed vessel in the form of small fragments, which causes a rapid expansion of the containment atmosphere. In both of these cases, the containment fails due to overpressure or on loss of the pressure boundary, i.e., melting of the liner plate or the head seal. In the case of COTF, pressurization is caused by rapid heating of the containment atmosphere. The COPF is also containment failure by pressure but, in this case, the pressure increase is caused by a failure of decay heat removal (suppression pool cooling) which allows the vapor pressure of the suppression pool to increase. The COPF failures are not rapid.

Enclosure to PLA-5734 Page 18 of 24 Both COPF and COTF entail a failed containment. Given that containment fails, it is predicted that Secondary Containment will also fail due to the sudden release of gas from Primary Containment into Secondary Containment. With Secondary Containment breached, SGTS will be ineffective at mitigating a release to the environment.
SGTS is not designed for and in fact is ineffective at mitigating a large release, i.e., the SGTS capacity is insufficient to prevent Secondary Containment failure given a primary containment failure.
PPL has calculated a containment leakage rate of 392 SCFM to be equivalent to a "large release." This is the flow rate that would pass through a one inch opening and corresponds to 35 x La, where La is the Technical Specification allowed leakage. 35 La is the flow rate, which would be indicative of a breach of containment. This flow is within the design of SGTS (10,000 SCFM). However, to achieve this leakage rate equipment or operator failures would have to have occurred. Primary Containment would continue to pressurize with this leak present and ultimately fail. PPL calculates a primary containment "leak" rate of 55,000 CFM per unit (at 14.7 psia and 2800 F) is required to prevent primary containment over-pressure failures. Adjusting this leak rate to SCFM yields 39,000 SCFM, which is well beyond the SGTS capacity. Hence, if primary containment was leaking at 55,000 CFM, the primary containment would not rupture; however, Secondary Containment would pressurize and breach. With the Secondary Containment breached, SGTS is ineffective in mitigating a large release. Note that if the containment failure mode is COTF, leakage rates higher than 55,000 CFM are expected because of non-condensable gas generation from the metal-water and core-concrete interactions.
The containment leakage rate requirements are shown graphically below.
0     392 SCFM         10,000 SCFM       39,000 SCUM Containment Leakage                                                                  0 Large Release                                                _          _
SGTS capacity                Sec. Cont. Intact           Secondary Containment Fails Primary Containment          Inadequate Leakage - Primary Containme     Adequate t      Legkage Integrity                                                Failure        No Primary Containment Failure 4.3.3 Defense in Depth Extending the AOT for SGTS results in no increase in CDF and LERF. However, for the purpose of defense in depth, PPL will have a recovery plan in place to restore SGTS and

Enclosure to PLA-5734 Page 19 of 24 at least one Reactor Building Recirculation Fan. The work in the Recirculation Plenum is staged so that at least one Recirculation fan can be restored and the duct closed within a maximum of 200 minutes. All COPF failures, except the ones associated with an ATWS, occur 12 or more hours from an initiating event. Given an initiating event has occurred, the probability of an ATWS per unit is small (2E-6), therefore it will not significantly detract from the validity of the defense in depth approach. Note, although the COTF can occur in less than 4 hours, the pressure rise in containment is rapid and release rates are well beyond the capacity of SGTS.
4.3.4 External Events Consideration of external events such as flooding and fire will not affect the extension of the SGTS AOT since it has been shown that SGTS is ineffective in mitigating a large release. The CDF and LERF will be the same with or without SGTS available.
A seismic event has the potential to fail the closed-cooling system water piping. Failure of the closed cooling water piping containment isolation valves was found not to be an issue since the piping is not open to the containment atmosphere. However, if a seismic event occurs, the piping integrity can be lost and containment isolation would need to be maintained by the penetration's containment isolation valves.
The PRA for one unit uses a probability of 1E-4 for containment isolation failure.
Combined with a seismic frequency of 8.5E-5 per year this would yield a frequency of 8.5E-9 containment isolation failures per year due to a seismic event.
A seismic event could also cause a loss of off site power (LOOP). To assess the incremental LERF contribution due to a seismic event, the CDF is divided by the LOOP frequency since the seismic event is assumed to cause a LOOP, and multiplied by the frequency of a seismic event causing a containment isolation failure. This yields:
[(3.4E-6 CDF)/(2.98E-2 LOOP initiation frequency)]*(8.5E-9 frequency of a seismic event failing containment isolation), which results in a 9.7E-13 incremental increase in LERF. This conservatively assumes that all of the CDF is due to a LOOP. Considering that the base SSES LERF is 6.7E-7, an increase of 9.7E-13 is insignificant.
Given that the AOT is only 48 hours, the incremental probability of a large early release is 9.7E-13*2/365 which is 5.3E-15.
4.3.5 Conclusion SGTS provides no mitigation for CDF and LERF. When internal events or external events are considered, there is no mitigation from SGTS. Therefore there is no risk increase resulting from an extension of the Secondary Containment and SGTS AOT to 48 hours.

Enclosure to PLA-5734 Page 20 of 24 5.0     REGULATORY SAFETY ANALYSIS 5.1     No Signifilcant Hazards Consideration The proposed amendments would change the Technical Specifications for Secondary Containment and the Standby Gas Treatment System (SGTS) to extend, on a one-time basis, the allowable Completion Time for Required Actions for Secondary Containment inoperable and two SGTS subsystems inoperable, in Mode 1, 2, or 3, from 4 hours to 48 hours. This change is needed to allow sufficient time for the planned replacement of the Reactor Building Recirculating Fan Damper Motors, while both units remain at power. The reason for the replacement is to complete Equipment Qualification required preventive maintenance on these dampers.
PPL Susquehanna, LLC has evaluated whether or not a significant hazards consideration is involved with the proposed change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change does not involve a significant increase in the probability of an accident previously evaluated because neither Secondary Containment nor the Standby Gas Treatment System is an initiator of an accident. Both mitigate accident consequences.
The consequences of a Design Basis Analysis-Loss of Coolant Accident (DBA-LOCA) have been evaluated in the FSAR. Increasing the completion time for Secondary Containment and two SGTS subsystems inoperable from 4 hours to 48 does not result in a significant increase in the consequences of a DBA-LOCA event nor change the evaluation of DBA-LOCA events as stated in the FSAR evaluation. The radiological evaluation of DBA-LOCA doses, including doses offsite, Control Room habitability, and exposures for personnel access demonstrates that there would be no significant impact.
Movement of irradiated fuel within Secondary Containment will be prohibited during the extended LCO period, to preclude a fuel handling accident, which might lead to a radiological consequence.
Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Enclosure to PLA-5734 Page 21 of 24
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed changes do not involve a physical alteration of the plant. No new or different type of equipment will be installed (damper motors will be replaced) nor will there be changes in methods governing normal plant operation.
The accident analyses affected by this extension are the radiological events that are discussed in the FSAR. The potential for the loss of other plant systems or equipment to mitigate the effects of an accident is not altered.
The proposed changes do not require any new operator response or introduce any new opportunities for operator error not previously considered.
Thus, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed change does not involve a significant reduction in margin of safety.
The increase in completion time for Standby Gas Treatment does not result in any effect on the margin of safety. There is no increase in Core Damage Frequency (CDF) or Large Early Release Frequency (LERF). A recovery plan will be in place to restore the SGTS and Secondary Containment to functional, if a DBA-LOCA accident should occur.
Implementation of the compensatory measures minimizes the probability that an accident will be initiated, maximizes the probability that accident mitigation equipment will be available and ensures that SGTS and Secondary Containment will be able to be restored in a timely manner. Thus the potential impact of extending the Completion Time is small. Therefore, this one-time extension will not involve a significant reduction in safety margin.
Based on the above, the PPL Susquehanna concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

Enclosure to PLA-5734 Page 22 of 24 5.2    Applicable Regulatory Requirements / Criteria 5.2.1 Analysis SSES FSAR Sections 3.1 and 3.13 provide detailed discussion of SSES compliance with the applicable regulatory requirements and guidance. The proposed TS amendment:
(a)    Does not alter the design or function of any reactivity control system; (b)    Does not result in any change in the qualifications of any component; and (c)    Does not result in the reclassification of any component's status in the areas of shared, safety related, independent, redundant, and physically or electrically separated.
General Design Criteria:
The following applicable General Design Criteria (GDC) for the Standby Gas Treatment System require that containment atmosphere cleanup systems reduce the amount of radioactive material released to the environment following a postulated design basis accident.
GDC 41 - Containment Atmosphere Cleanup GDC 42 - Inspection of Containment Atmosphere Systems GDC 43 - Testing of Containment Atmosphere Systems Regulatory Guide 1.52:
Regulatory Guide 1.52 is titled "Design, Testing, and Maintenance Criteria for Engineered-Safety Feature Atmosphere Cleanup Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants." Regulatory Guide 1.52 addresses the atmosphere cleanup system, including the various components and ductwork, in a postulated design basis radiological accident environment.
The current Completion Times associated with Secondary Containment and Standby Gas Treatment are intended to minimize the time an operating plant is exposed to a reduction in radiological accident mitigation capability.
Conformance with GDC 41, 42, and 43, as well as conformance with Regulatory Guide 1.52 are not affected by these proposed changes, because a recovery plan will be in place to restore the system to be functional, if an accident should occur.
Thus, the proposed extended Completion Times do not change the conformance with the above General Design Criteria and regulatory guidance.

Enclosure to PLA-5734 Page 23 of 24 5.2.2 Conclusion Based on the analyses provided in Section 4.0 Technical Analysis, the proposed changes are consistent with all applicable regulatory requirements and criteria. In conclusion, there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, such activities will be conducted in compliance with the Commission's regulations, and the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

==6.0     ENVIRONMENTAL CONSIDERATION==

10 CFR 51.22(c)(9) identifies certain licensing and regulatory actions that are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. PPL Susquehanna has evaluated the proposed change and has determined that the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c)(9). Accordingly, pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:
: 1. As demonstrated in the No Significant Consideration Evaluation, the proposed amendment does not involve a significant hazards consideration.
: 2. 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 modification or alteration of plant equipment (no new or different type of equipment will be installed) or change in methods governing normal plant operation.
: 3. There is no significant increase in individual or cumulative occupational radiation exposure. The proposed change does not involve any physical modification or alteration of plant equipment (no new or different type of equipment will be installed) or change in methods governing normal plant operation.

Enclosure to PLA-5734 Page 24 of 24 7.0     

==SUMMARY==

The radiological evaluations of the proposed one-time Technical Specification change show the following:
: 1. The proposed change meets the current regulation as discussed in Section 5.0, Regulatory Safety Analysis, under Applicable Regulatory Requirements/Criteria.
: 2. The proposed change is consistent with the defense-in-depth philosophy as discussed in Section 4.2, Deterministic Considerations.
: 3. Safety Margins are adequately maintained as discussed in Section 5.0, Regulatory Safety Analysis, under the No Significant Hazards Consideration.
Therefore, PPL Susquehanna has concluded that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operating in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

==8.0      REFERENCES==
: 1. Susquehanna Steam Electric Station Final Safety Analysis Report, Docket Numbers 50-387 and 50-388.
: 2. USNRC Regulatory Guide 1.3, "Assumptions Used for Evaluating the Potential Radiological Consequences of a Loss of Coolant Accident for Boiling Water Reactors," Revision 2, June 1974.
: 3. TID 14844, "Calculation of Distance Factors for Power and Test Reactor Sites,"
J. J. DiNunno et al., U. S. Atomic Energy Commission (now USNRC), 1962.

THIS PAGE IS AN OVERSIZED DRAWING OR-FIGURE, THAT- CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. M-1 75 Rev. No. 7, Sheet No. 2 "SUSQUEHANNA S.E.S.
UNIT 1, P & ID REACTOR BLDG. AIR FLOW DIAGRAM WITHIN THIS PACKAGE..
OR BY SEARCHING USING DWG. NO. M-175 D-O1

ATTACHMENT 1 to PLA-5734 Proposed Technical Specification Change (Mark-Up)

PPL Rev. 0 Secondary Containment 3.6.4.1 3.6              CONTAINMENT SYSTEMS 3.6.4.1         Secondary Containment LCO 3.6.4.1             The secondary containment shall be OPERABLE.
APPLICABILITY:          MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                                                   REQUIRED ACTION                            COMPLETION TIME A. Secondary containment                                A.1          Restore secondary                            4 hours inoperable in MODE 1, 2,                                         containment to OPERABLE                      o&
or 3.                                                            status.                      if                   Ausfo        A oN&#xa3; -TIME 0 A-1IE. i B. Required Action and                                  B.1          Be in MODE 3.                                12 hours associated Completion Time of Condition A not met.
AND                                                                                    RN DAMP0?L q E P, "a jAOi\ou.I WM B.2          Be in MODE 4.                                36 hours 1f IYOM&I~m C. Secondary containment                                C.1                   -      NOTE inoperable during movement                                         LCO 3.0.3 is not applicable.
of irradiated fuel assemblies in the secondary containment, during CORE                                        Suspend movement of                           Immediately ALTERATIONS, or during                                          irradiated fuel assemblies in OPDRVs.                                                         the secondary containment.
AND
__ _ _ __ __ _ __ _ _ _ _ __ _ __ _ __ __ _ _   _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _(             co nti n ued )
SUSQUEHANNA - UNIT 1                                                   3.6-35                                          Amendment 178

PPL Rev. 0 SGT System 3.6.4.3 ACTIONS CONDITION                                      REQUIRED ACTION                         COMPLETION TIME C. (continued)                               C.2.1 Suspend movement of                          Immediately irradiated fuel assemblies in secondary containment.
AND C.2.2 Suspend CORE                                 Immediately ALTERATIONS.
AND C.2.3 Initiate action to suspend                   Immediately OPDRVs.
D. Two SGT subsystems                        D.1       Restore one SGT subsystem                4 hours inoperable in MODE 1, 2,                            to OPERABLE status.                     ____
or 3.                                                                                       qg? 4 R5.VP I PA o ti'e of at6 E. Required Action and                      E.1        Be in MODE 3.                            12 hours                  eAcrA "
associated Completion Time                                                                                                 IL  N(
of Condition D not met in                                                                                              cWw c MODE 1, 2, or 3.                         AND                                                                          hAe   ?,P p E.2        Be in MODE 4.                            36 hours                  P &deg;V2
                                                                                                                           '31 F. Two SGT subsystems                       F.1       -INOTE inoperable during movement                        LCO 3.0.3 is not applicable.
of irradiated fuel assemblies in the secondary containment, during CORE                 Suspend movement of irradiated fuel'                Immediately ALTERATIONS, or during                   assemblies in secondary OPDRVs.                                  containment.
AND
___     ____   ___ ___  ____  ___  ___(continued)
SUSQUEHANNA - UNIT 1                                     3.6-43                                      Amendment 178

PPL Rev. 0 Secondary Containment 3.6.4.1 3.6              CONTAINMENT SYSTEMS 3.6.4.1          Secondary Containment LCO 3.6.4.1             The secondary containment shall be OPERABLE.
APPLICABILITY:          MODES 1,2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONSR CONDITION                           REQUIRED ACTION                      COMPLETION TIME A. Secondary containment               A.1   Restore secondary                      4 hours inoperable in MODE 1,2,                  containment to OPERABLE                 __
jE- ropi or 3.                                    status.                                 4t'   PreU(v S Fog A e
_ _ __ __ __ _ _ _ _ _ _ _ _ _ _ _  b o rsc    h6 (:ot  Rf t:u 4CEM Es  P c>; a14 B. Required Action and                 B.1   Be in MODE 3.                          12 hours                       Reekiwa PtAtg>.
associated Completion Time                                                                                    I UI   >o%
of Condition A not met.
AND                                                                        DAMPZR-B2    Be in MODE 4.                          36 hours rs./ oCe46Fq.
31 ;ivoz C. Secondary containment              C.1                       NOT inoperable during movement                 LCO 3.0.3 is not applicable.
of irradiated fuel assemblies in the secondary containment, during CORE                Suspend movement of                     Immediately ALTERATIONS, or during                  irradiated fuel assemblies in OPDRVs.                                 the secondary containment.
AND SUSQUEHANNA - UNIT 2                           3.6-35                                      Amnendment 151

PPL Rev. 0 SGT System 3.6.4.3 ACTIONS                          .
CONDITION                         REQUIRED ACTION              COMPLETION TIME C. (continued)                     C.2.1 Suspend movement of             Immediately irradiated fuel assemblies in
                                         .-secondary containment.
AND C.2.2 Suspend CORE                    Immediately ALTERATIONS.
AND C.2.3 Initiate action to suspend      Immediately OPDRVs.
D. Two SGT subsystems              D.1     Restore one SGT subsystem     4 hours inoperable in MODE 1, 2,                to OPERABLE status.           O_
or 3.                                                                 qqiiours Fone t:
Ae AWEd OF tha.
E. Required Action and             E.1     Be in MODE 3.                 12 hours.       a; Id,4.A associated Completion Time                                                          /Zec sw of Condition D not met in                                                            Hi,< Do MODE 1, 2, or3.                 AND                                                  Mtars toe by E.2     Be in MODE 4.                 36 hours      Dc lD Cr5v aws:
F. Two SGT subsystems              F.1   -N            NOTE inoperable during movement            LCO 3.0.3 is not applicable.
of irradiated fuel assemblies in the secondary containment, during CORE        Suspend movement of irradiated fuel   Immediately ALTERATIONS, or during          assemblies in secondary OPDRVs.                         containment.
AND (continued)
SUSQUEHANNA - UNIT 2                         3.643                            Amendment 151

ATTACHMENT 2 to PLA-5734 Proposed Technical Specification Pages (Retyped)

PPL Rev. 1 Secondary Containment 3.6.4.1 3.6            CONTAINMENT SYSTEMS 3.6.4.1        Secondary Containment LCO 3.6.4.1          The secondary containment shall be OPERABLE.
APPLICABILITY:       MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE ALTERATIONS, During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                         REQUIRED ACTION                    COMPLETION TIME A. Secondary containment            A.1    Restore secondary                   4 hours inoperable in MODE 1, 2,              containment to OPERABLE or 3.                                 status.                             OR 48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Motors, to be completed by December 31, 2005.
B. Required Action and              B.1   Be in MODE 3.                        12 hours associated Completion Time of Condition A not met.
AND B.2   Be in MODE 4.                       36 hours (continued)
SUSQUEHANNA - UNIT 1                     TS / 3.6-35                                Amendment 17/8

PPL Rev. 1 Secondary Containment 3.6.4.1 ACTIONS (continued)
CONDITION                          REQUIRED ACTION                  COMPLETION TIME C. Secondary containment            C.1  --------       NOTE--------
inoperable during movement               LCO 3.0.3 is not applicable.
of irradiated fuel assemblies                          -        ---
in the secondary                      Suspend movement of                 Immediately containment, during CORE              irradiated fuel assemblies in ALTERATIONS, or during                the secondary containment.
OPDRVs.
AND C.2  Suspend CORE                        Immediately ALTERATIONS.
AND C.3  Initiate action to suspend          Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                        FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is                  24 hours
                > 0.25 inch of vacuum water gauge.
SR 3.6.4.1.2 Verify all required secondary containment               31 days removable walls and equipment hatches required to be closed are closed and sealed.
(continued)
SUSQUEHANNA - UNIT 1                    TS /3.6-36                               Amendment 17t8

PPL Rev. 1 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS               (continued)
SURVEILLANCE                                           FREQUENCY SR 3.6.4.1.3 Verify each secondary containment access door is        31 days closed except when the access opening is being used for entry and exit, then at least one door shall
             -be closed.
SR 3.6.4.1.4                           NOTE ---------------
                                   -----------                     -     --   ---- NOTE The maximum time allowed for secondary                 Once every 60 months containment draw down is dependent on the              testing will be performed in secondary containment configuration.                   three zone configuration.
Verify each standby gas treatment (SGT)                24 months on a subsystem will draw down the secondary                 STAGGERED TEST BASIS containment to 2 0.25 inch of vacuum water gauge in less than or equal to the maximum time allowed for the secondary containment configuration that is OPERABLE.
SR 3.6.4.1.5  --    a ---            --NOTE--------  -----------            -----NOTE --------
The maximum flow allowed for maintaining               Once every 60 months secondary containment vacuum is dependent on           testing will be performed in the secondary containment configuration.               three zone configuration.
Verify each SGT subsystem can maintain                 24 months on a
              > 0.25 inch of vacuum water gauge in the                STAGGERED TEST BASIS secondary containment for at least 1 hour at a flow rate less than or equal to the maximum flow rate permitted for the secondary containment configuration that is OPERABLE.
SUSQUEHANNA - UNIT 1                         TS / 3.6-37                           Amendment 17/8

PPL Rev. 1 SGT System 3.6.4.3 ACTIONS CONDITION                    REQUIRED ACTION              COMPLETION TIME C. (continued)                 C.2.1 Suspend movement of           Immediately irradiated fuel assemblies in secondary containment.
AND C.2.2 Suspend CORE                  Immediately ALTERATIONS.
AND C.2.3 Initiate action to suspend    Immediately OPDRVs.
D. Two SGT subsystems          D.1   Restore one SGT subsystem     4 hours inoperable in MODE 1, 2,         to OPERABLE status.
or 3.                                                          OR 48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Motors, to be completed by December 31, 2005.
E. Required Action and        E.1   Be in MODE 3.                 12 hours associated Completion Time of Condition D not met in MODE 1, 2, or3.           AND E.2   Be in MODE 4.                 36 hours (continued)
SUSQUEHANNA - UNIT 1               TS / 3.6-43                          Amendment 1763

PPL Rev. 1 SGT System 3.6.4.3 ACTIONS (continued)           _       _
CONDITION                             REQUIRED ACTION                 COMPLETION TIME F. Two SGT subsystems                  F.1       -------   NOTE---
inoperable during movement                LCO 3.0.3 is not applicable.
of irradiated fuel assemblies                               -----
in the secondary containment, during CORE           Suspend movement of irradiated fuel      Immediately ALTERATIONS, or during             assemblies in secondary OPDRVs.                            containment.
AND F.2   Suspend CORE                      Immediately ALTERATIONS.
AND F.3   Initiate action to suspend        Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                          FREQUENCY SR 3.6.4.3.1 Operate each SGT filter train for > 10 continuous          31 days hours with heaters operating.
SR 3.6.4.3.2 Perform required SGT filter testing in accordance          In accordance with the VFTP with the Ventilation Filter Testing Program (VFTP).
SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual            24 months or simulated initiation signal.
SR 3.6.4.3.4 Verify each SGT filter cooling bypass and outside          24 months air damper opens and the fan starts on high charcoal temperature.
SUSQUEHANNA - UNIT 1                        TS /3.6-44                             Amendment      17A

PPL Rev. 1 Secondary Containment 3.6.4.1 3.6            CONTAINMENT SYSTEMS 3.6.4.1        Secondary Containment LCO 3.6.4.1          The secondary containment shall be OPERABLE.
APPLICABILITY:       MODES 1, 2, and 3, During movement of irradiated fuel assemblies in the secondary containment, During CORE-ALTERATIONS,-
During operations with a potential for draining the reactor vessel (OPDRVs).
ACTIONS CONDITION                         REQUIRED ACTION                    COMPLETION TIME A. Secondary containment            A.1   Restore secondary                    4 hours inoperable in MODE 1, 2,              containment to OPERABLE or 3.                                 status.                              OR 48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Fan Damper Motors, to be completed by December 31, 2005.
B. Required Action and              B.1   Be in MODE 3.                        12 hours associated Completion Time of Condition A not met.
AND B.2   Be in MODE 4.                       36 hours (continued)
SUSQUEHANNA - UNIT 2                     TS / 3.6-35                                Amendment 41g

PPL Rev. 1 Secondary Containment 3.6.4.1 ACTIONS     (continued)
CONDITION                          REQUIRED ACTION                     COMPLETION TIME C. Secondary containment             C.1  --------------NOTE----------------
inoperable during movement                LCO 3.0.3 is not applicable.
of irradiated fuel assemblies                          -----       ---
in the secondary                       Suspend movement of                    Immediately containment, during CORE               irradiated fuel assemblies in ALTERATIONS, or during                 the secondary containment.
OPDRVs.
AND C.2  Suspend CORE ALTERATIONS.                           Immediately AND C.3   Initiate action to suspend            Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                            FREQUENCY SR 3.6.4.1.1 Verify secondary containment vacuum is                       24 hours
                > 0.25 inch of vacuum water gauge.
SR 3.6.4.1.2 Verify all required secondary containment                    31 days removable walls and equipment hatches required to be closed are closed and sealed.
(continued)
SUSQUEHANNA - UNIT 2                      TS /3.6-36                                 Amendment ii/1

PPL Rev. 1 Secondary Containment 3.6.4.1 SURVEILLANCE REQUIREMENTS             (continued)
SURVEILLANCE                                       FREQUENCY SR 3.6.4.1.3 Verify each secondary containment access door is      31 days closed except when the access opening is being used for entry and exit, then at least one door shall beclosed.
SR 3.6.4.1.4               -        -NOTE--------------------------------- NOTE--------
The maximum time allowed for secondary                Once every 60 months containment draw down is dependent on the             testing will be performed in secondary containment configuration.                  three zone configuration.
Verify each standby gas treatment (SGT)               24 months on a subsystem will draw down the secondary                STAGGERED TEST BASIS containment to 2 0.25 inch of vacuum water gauge in less than or equal to the maximum time allowed for the secondary containment configuration that is OPERABLE.
SR 3.6.4.1.5 ----------------- NOTE-NOTE--------------
The maximum flow allowed for maintaining              Once every 60 months secondary containment vacuum is dependent on          testing will be performed in the secondary containment configuration.              three zone configuration.
Verify each SGT subsystem can maintain                24 months on a 2 0.25 inch of vacuum water gauge in the               STAGGERED TEST BASIS secondary containment for at least 1 hour at a flow rate less than or equal to the maximum flow rate permitted for the secondary containment configuration that is OPERABLE.
SUSQUEHANNA - UNIT 2                    TS / 3.6-37                              Amendment 1il

PPL Rev. 1 SGT System 3.6.4.3 ACTIONS CONDITION                     REQUIRED ACTION              COMPLETION TIME C. (continued)                  C.2.1 Suspend movement of           Immediately irradiated fuel assemblies in secondary containment.
AND C.2.2 Suspend CORE                  Immediately ALTERATIONS.
AND C.2.3 Initiate action to suspend    Immediately OPDRVs.
D. Two SGT subsystems           D.1   Restore one SGT subsystem     4 hours inoperable in MODE 1,2,           to OPERABLE status.
or 3.                                                           OR 48 hours for a one-time outage for replacement of the Reactor Building Recirculating Fan Damper Motors, to be completed by December 31, 2005.
E. Required Action and         E.1   Be in MODE 3.                 12 hours associated Completion Time of Condition D not met in MODE 1,2, or 3.            AND E.2   Be in MODE 4.                 36 hours (continued)
SUSQUEHANNA - UNIT 2                TS /3.6-43                           Amendment 101

PPL Rev. 1 SGT System 3.6.4.3 ACTIONS (continued)
CONDITION                            REQUIRED ACTION                 COMPLETION TIME F. Two SGT subsystems                  F.1   -------- NOTE------
inoperable during movement                LCO 3.0.3 is not applicable.
of irradiated fuel assemblies in the secondary containment, during CORE            Suspend movement of irradiated fuel     Immediately ALTERATIONS, or during             assemblies in secondary OPDRVs.                            containment.
AND F.2   Suspend CORE                      Immediately ALTERATIONS.
AND F.3   Initiate action to suspend        Immediately OPDRVs.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                          FREQUENCY SR 3.6.4.3.1 Operate each SGT filter train for 2 10 continuous          31 days hours with heaters operating.
SR 3.6.4.3.2 Perform required SGT filter testing in accordance          In accordance with the VFTP with the Ventilation Filter Testing Program (VFTP).
SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual            24 months or simulated initiation signal.
SR 3.6.4.3.4 Verify each SGT filter cooling bypass and outside         24 months air damper opens and the fan starts on high charcoal temperature.
SUSQUEHANNA - UNIT 2                        TS /3.6-44                             Amendment 101

ATTACHMENT 3 to PLA-5734 List of Regulatory Commitments

Attachment 3 to PLA-5734 Page 1 of 3 I                       LIST OF REGULATORY COMMITMENTS                                           I The following table identifies those actions committed to by PPL Susquehanna in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Mr. Michael H. Crowthers.
REGULATORY COMMITMENTS -                        j;l;;-       Due Date/Event -
All commitments will be applicable prior to and/or during the damper motor replacement, as indicated below:
: 1. The performance of the damper motor replacement has          Before damper motor been added to the dual-unit shutdown list. Should that      replacement opportunity occur prior to the planned replacement, the motors will be replaced at that time and thus the proposed change will not be used.
: 2. Provision will be made to restore Secondary                  Before and during damper motor Containment and the Standby Gas Treatment System to replacement be functional, within 200 minutes of an accident initiation.
: 3. To minimize the damper motor replacement time,               Before and during damper motor experienced personnel will perform the damper motor         replacement replacement.
: 4. Mitigating Measures:
The following mitigating measures will be taken to increase the ability to identify and take appropriate actions before a problem arises:
Before and during damper motor Engineering Inspections of Containment will be replacement performed. These will include:
     > Testing for leak tightness of the Secondary Containment Structure per Technical Specification Surveillance Requirement 3.6.4.1.4
          & 3.6.4.1.5
     > Testing for Secondary Containment Bypass Leakage paths

Attachment 3 to PLA-5734 Page 2 of 3
  ~~:          -REGULATORYCOMMITMENTS: -.                             - .Due Date/Event-
* Movement of irradiated fuel, within Secondary                During damper motor Containment will be prohibited during the extended          replacement LCO period.
* High-risk activities within the confines of the plant that   During damper motor may result in a loss of offsite power during the damper     replacement motor replacement will be prohibited.
* High-risk grid activities that may result in a loss of       During damper motor offsite power during the damper motor replacement           replacement will be prohibited.
* For the duration of the damper motor replacement,            During damper motor Transmission and Distribution Operations will not           replacement grant any work requests that would jeopardize the reliability of offsite power.
* Surveillance testing of the Emergency Diesel 'E'             Before damper motor (Fifth Non-Technical Specification)                         replacement
* Reactor Building HVAC will be required to be                 During damper motor available.                                                  replacement
* Dedicated Secondary Containment SGTS Restoration             During damper motor Team                                                        replacement
: 5. External Events monitoring                                  Before and during damper motor replacement
* Geomagnetic activity from solar storms will be monitored via forecasts provided to the PJM.
: 6. The Susquehanna Steam Electric Station Risk                 Prior to and during damper motor Management Process will assess the impacts of planned       replacement and emergent work prior to and during the damper motor replacement.
: 7. The following systems and components will be                During damper motor required to be available during the damper motor            replacement replacement to reduce the plant risk. Elective maintenance will not be performed on these systems and components. Any failed system or component will be returned to operable status as soon as possible. (The

Attachment 3 to PLA-5734 Page 3 of 3 REGULATORY COMMTMENTS.                         e i.:. Due Date/Event - ; -.
failed system/component shall be worked around the clock.) If one of these systems or components become unavailable or inoperable, SSES will immediately begin and promptly complete an evaluation to determine if the basis for the proposed one-time change to LCOs 3.6.4.2.1 and 3.6.4.3 remain valid, and within one hour of identification, contact the NRC Resident Inspector.
* Station Portable Diesel Generator - Blue Max
* Diesel Generator A ESS 480V Motor Control
* Diesel Generator B ESS 480V Motor Control
* Diesel Generator 'A'
* Diesel Generator 'B'
* Diesel Generator 'C'
* Diesel Generator 'D'
* Diesel Generator 'E'
* U-1 125V DC Battery Charger Breaker OB516073
* U-1 125V DC Battery Charger Breaker OB526073
* U-1 125V DC Battery Charger ID613
* U-1 125V DC Battery Charger 1D623
* RHR LOOP A Injection OB ISO VLV, (Unit 1)
* RHR LOOP A Injection Flow Control VLV, (Unit 1)
* RHR LOOP B Injection Flow Control VLV, (Unit 1)
* RHR LOOP B Injection OB ISO VLV, (Unit 1)
* U-2 125V DC Battery Charger Breaker OB516071
* U-2 125V DC Battery Charger Breaker OB526071
* U-2 125V DC Battery Charger 2D613
* U-2 125V DC Battery Charger 2D623
* RHR LOOP A Injection Flow Control VLV, (Unit 2)
* RHR LOOP A Injection OB ISO VLV, (Unit 2)
* RHR LOOP B Injection OB ISO VLV, (Unit 2)
* RHR LOOP B Injection Flow Control VLV, (Unit 2)
* RHR/RHRSW Cross Tie Valves, (Unit 1)
* RHR/RHRSW Cross Tie Valves, (Unit 2)
* HPCI (UNIT 1)
* HPCI (UNIT 2)
* RCIC (UNIT 1)
* RCIC (UNIT 2)
* REACTOR BUILDING HVAC

ATTACHMENT 4 to PLA- 5734 Changes to Technical Specification Bases

PPL Rev. 0 Secondary Containment B 3.6.4.1 BASES LCO              The required boundary encompasses the zones which can be postulated to (continued)    contain fission products from accidents required to be considered for the condition of each unit.
APPLICABILITY    In MODES 1,2, and 3, a LOCA could lead to a fission product release to primary containment that leaks to secondary containment. Therefore, secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.
In MODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations In these MODES.
Therefore, maintaining secondary containment OPERABLE Is not required in MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs),
during CORE ALTERATIONS, or during movement of irradiated fuel assemblies in the secondary containment.
ACTIONS        A.1 If secondary containment is inoperable, it must be restored to OPERABLE status within 4 hours. The 4 hour Completion Time provides a period of time to correct the problem that Is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.
                'TQ        Peo       AJQY CO ME TE)             ILA%^      C{wC'    am               >a}{'
O.CA C*01        A-1O 0      *T                  A E.            " VD      uk N Pt fee      C(tcotnLuAned) FAP.
(continued)
SUSQUEHANNA - UNIT 1                 TS / B 3.6-86                                   Revision I

PPL Rev. 0 SGT System B 3.6.4.3 BASES ACTIONS            C.1. C.2.1. C.2.2, and C.2.3 (continued) should immediately be placed in operation. This action ensures that the remaining filter train Is OPERABLE, that no failures that could prevent automatic actuation have-occurred, and that any other failure would be readily detected.
An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk. If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies must immediately be suspended. Suspension of these activities must not preclude completion of movement of a component to a safe position. Also, if applicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.
The Required Actions of Condition C have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while In MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
D.1 CoA.& Pc..SAJ rtv ' ""~         If both SGT subsystems are inoperable in MODE 1, 2, or 3, the SGT system To tc COM ,nL?1         c      may not be capable of supporting the required radioactivity release control AeCoo t*RFFmr ArioA"4-K&deg;v4)function. The 4 hour Completion Time provides a period of time to correct Or i, Uthe                      problem that is commensurate with the importance of maintaining the
      &#xa2;              C.        SGT System contribution to secondary containment during MODES 1, 2, 44 e I    and 3. This time period also ensures that the probability of an accident 6ora el: (requiring SGT OPERABILITY) occurring during periods where SGT is TH we      - LAC            inoperable Is minimal.
CohM      wJ A   E- or OS   Ce   D
            ,   he'OO o0         3A        .    .                                                          (continued)
SUSQUEHANNA - UNIT 1                         B 3.6-104                                   Revision 0

                                                                                  - PPL Rev. 0 Secondary Containment B 3.6.4.1 BASES LCO             The required boundary encompasses the zones which can be postulated to (continued)    contain fission products from accidents required to be considered for the condition of each unit.
APPLICABILITY    In MODES 1, 2, and 3, a LOCA could lead to a fission product release to primary containment-thaUeaksjo secondary containment. Therefore,
               -.secondary containment OPERABILITY is required during the same operating conditions that require primary containment OPERABILITY.
InMODES 4 and 5, the probability and consequences of the LOCA are reduced due to the pressure and temperature limitations In these MODES.
Therefore, maintaining secondary containment OPERABLE Is not required In MODE 4 or 5 to ensure a control volume, except for other situations for which significant releases of radioactive material can be postulated, such as during operations with a potential for draining the reactor vessel (OPDRVs),
during CORE ALTERATIONS, or during movement of irradiated fuel assemblies Inthe secondary containment.
ACTIONS         A.1 If secondary containment is inoperable, Itmust be restored to OPERABLE 2*
status within 4 hours. The 4 hour Completion Time provides a period of time to correct the problem that Is commensurate with the importance of maintaining secondary containment during MODES 1, 2, and 3. This time period also ensures that the probability of an accident (requiring secondary containment OPERABILITY) occurring during periods where secondary containment is inoperable is minimal.
OAJ              ICem    RCi       -'(     LCI n A0To              _
OK%orR                          TS$                     ,    -
H.Mi     MM          (4   SlL M 8    oxs     aIR      ^e>r5            A;~\        .0AfX                  it A .l^
mxYM                      t he-                        1kfo~t
                                                                                            -Ore     (
OWL-     AN eo
* P"(r--3 'ceK o                      t      o (continued)
SUSQUEHANNA - UNIT 2                  TS / B 3.6-85                                    Revision 1

PPL Rev. 0 SGT System B 3.6.4.3 BASES ACTIONS                    C.1. C.2.1, C.2.2. and C.2.3 (continued) ensures that the remaining filter train is OPERABLE, that no failures that could prevent automatic actuation have occurred, and that any other failure would be readily detected.
An alternative to Required Action C.1 is to immediately suspend activities that represent a potential for releasing radioactive material to the secondary containment, thus placing the plant in a condition that minimizes risk. If applicable, CORE ALTERATIONS and movement of irradiated fuel assemblies must immediately be suspended. Suspension of these activities must not preclude completion of movement of a component to a safe position. Also, Ifapplicable, actions must immediately be initiated to suspend OPDRVs in order to minimize the probability of a vessel draindown and subsequent potential for fission product release. Actions must continue until OPDRVs are suspended.
The Required Actions of Condition C have been modified by a Note stating that LCO 3.0.3 is not applicable. If moving Irradiated fuel assemblies while in MODE 4 or 5, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, or 3, the fuel movement is independent of reactor operations. Therefore, in either case, inability to suspend movement of irradiated fuel assemblies would not be a sufficient reason to require a reactor shutdown.
ez  w~esty(9[-~z)            D.1 CDtPanTI4<                '5    "A'Ilfboth SGT subsystems are inoperable in MODE 1, 2, or3, the SGT system
 -~ -r'~- (lo~       1       thf.      may not be capable of supporting the required radioactivity release control R         v h(I,,,         g-6j.vj,,)function. The 4 hour Completion Time provides a period of time to correct
_                  _~-. the problem that is commensurate with the importance of maintaining the w~t      A4'00('~6-b7V                 SGT System contribution to secondary containment during MODES 1, 2, p,,pg_       CP urnP~eL11te.      and 3. This time period also ensures that the probability of an accident S q{ 8 (00-S 640 APPLUE              (requiring SGT OPERABILITY) occurring during periods where SGT is T ax s         e                    inoperable is minimal.
TH re.
ttVonroeL.     (uo    TeflO$Aff
(&deg;s0's ONLE I3<      sonJSEne EU.      rJD YPREoN Dot        B      ,   oiN3w S.                                                                  (continued)
SUSQUEHANNA - UNIT 2                            B 3.6-1 03                                       Revision 0}}