Text

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
	ML16029A031
Person / Time
Site:	Susquehanna
Issue date:	01/28/2016
From:	Franke J A; Susquehanna, Talen Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PLA-7384
	Download: ML16029A031 (42)
	v • d • e

Jon A. Franke Site Vice President Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick , PA 18603 Tel. 570.542.2904 Fax 570.542.1504 Jon.Franke@talenenergy

.com JAN 8 2016 E N ERGY U.S. Nuclear Regulatory Commission Attn: Document Control Desk 10 CFR 50.90 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months , which would exceed the cunently specified Completion Times of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . 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" Attachments:

Document Control Desk PLA-7384 Attachment 1 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)

Attachment 2 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 DCS GENPL5 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 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.

3. BACKGROUND Reason for Changes Enclosure to PLA-7384 Page 2 of30 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.

E ach 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°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 Operating" Removing any one of these four transformers from service with Uni t 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Since replacing a single transformer takes approximately 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months , 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Since replacing a single transformer takes approximately 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months , 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 Transformer Equipment Impacted Associated Unit2 TS LCO 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 Emergenc y 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-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° F + 0.5° F, for instrument tolerance.

The 80° 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and the large spray array valve open on the opposite loop, the peak Spray Pond temperatures are approximately 4° F below the value required (97° 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°F. Considering these transformer replacements will occur during Unit 1 refueling outages early in the year, a spray pond temperature of 80°F is conservative.

Data collected during operator rounds demonstrates Spray Pond temperatures do not approach 80°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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months if spray pond temperatures approach 80° 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° 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 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months 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-energi z e 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 dam a ge 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 1 0) 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Yes SBGT 3.6.4.3 7 days No CREOAS 3.7.3 7 days No Control Room Floor Cooling 3.7.4 30 days No t:: 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 ESWPumps to assure the availability of fire suppression.

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 ESW Diesel Generator the open position.

Therefore, there is no impact to these valves during Unit 1 480 V ESS LC transformer Retum Valves (A-D) replacements.

RHRSW Loop A Return to Spray Pond Valves Protected Equipment Enclosure to PLA-7384 Page 10 of30 These valves in the common ESW-RHRSW return line to the 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 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 of Structures, 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 HV AC , 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 1 7-Electric Power System s 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 switch yards (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 possibilit y 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 E SF 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.

7. REFERENCES Enclosure to PLA-7384 Page 15 of30 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 TABLEt Enclosure to PLA-7384 Page 16of30 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)

TABLE 1 (Continued)

Enclosure to PLA -73 84 Page 17 of30 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 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 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 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The extension of this time is the subject of the Tech Spec amendment request.

TABLE 1 (Continued)

Enclosure to PLA-7384 Page 18 of30 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 1 Y216 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 I TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 19 of30 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 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 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 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.

TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 20 of30 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 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . 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)

TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page21 of30 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 1 Y226 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 I TABLE 1 (Continued)

Attachment 1 to PLA-73 84 Page 22 of30 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 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 HV AC 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 HV AC subsystem . (TRO 3.7.9-30 day completion time) i TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 23 of30 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 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 HV AC 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 TABLE 1 (Continued)

Attachment 1 to PLA -73 84 Page 24 of30 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 1 Y23 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 HV AC 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)

I TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 25 of30 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:

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)

I TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 26 of30 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 HV AC 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 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 I TABLE 1 (Continued)

Attachment 1 to PLA-7384 Page 27 of30 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 1 Y246 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 HV AC 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)

TABLE2 PROTECTED EQUIPMENT Enclosure to PLA-7384 Page 28 of30 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, 1 C 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 TABLE 2 (Continued)

Enclosure to PLA-7384 Page 29 of30 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 SUNBURY#2 WESCOSVILLE S/U --230KV 13.8KV OX104 01 ) S/U BUS f 20 T-201 ESS201 OX203 T-211 ESS211 OX213 OA104 500 kV/230 kV TIE LINE T-21 STANTON #21 STANTON #1 MONTOUR JENKINS SUNBURY HARWOOD E. PALM ' 230KV Enclosure to PLA-7384 Page 30 of30 500KV U IW I SWYD SWYD 2G101 230KV 24 KV 1G101 lVI OA10502 TIE BUS -*J'.o.,_-r*r-OX501 I -llj'"fflll-

a OA510 @ OG5018 OG501E C) OG501C Figure 1 1R106 (HSGS) 230KV S/U 13.8 KV TRANS T-10 OX103 S/U BUS 1_) _ 10 T 01 OPEN CKT BKR OX207 TWO UNIT OPERATIONAL LINEUP SHOWN 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 RHRSW System and UHS" (Markups)

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 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem(s) to OPERABLE status. AND 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet LCO 3.8. 7 except for Cond i tion F or G B. ---------------

N 0 TE --------------

B.1 Restore Unit 2 DC electrical power 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Not applicable to DG E DC Bus distribution subsystem(s) to OPERABLE OD597 status. AND -------------------------------------

One or more Unit 2 DC electrical 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months distribution subsystem inoperable.

distribution subsystem to OPERABLE status. OR Q§ flfill.lFS tf1e il'lstallatiel'l ef: tf1e mMitifi)le fiFe il'l*ll.l*le*l SfilMFi*l<lS

lfileFati*li'IS F11fil*JiH*lEltifili'IS il'l Ul'lit 1 7 days during the replacement of 480 V ESS Load Center Transformers in Unit 1 (ll (continued)

(1) Uis temJileFEll)'

24 f1eMr *lSFI1filletiel'l time eHtel'lsiel'l is Elfilfilli*laele P1£Q ms*lifisatisl'!s te all Ul'lit 1 4.1SIN eMses, "'flile l'lit 1 is il'l 4 sF§, al'!*1 will eHfiliFe el'l 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

3.7 PLANT

SYSTEMS RHRSW System and UHS 3.7.1 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 A. ---------------N Separate Condition entry is allowed for each valve. One valve in Table 3.7.1-1 inoperable.

OR One valve in Table 3.7.1-2 inoperable. One valve in Table 3.7.1-3 inoperable. 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 inoperable.

REQUIRED ACTION A.1 Declare the associated RHRSW subsystems inoperable. A.2 Establish an open flow path to the UHS. A.3 Restore the inoperable valve(s) to OPERABLE status. COMPLETION TIME Immediately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 8 hours from the discovery of an inoperable RHRSW subsystem in the opposite loop from the inoperable valve(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Q@ 19elJn; ll9*l iFlstallatieFl eftl9e FFllllli13l*l fiF*l iFlSll66S Si3llFi*llJS

li3*lFfilli*lFlS FFl*lSifi6rillieFlS iFl 7 days during the replacement of 480 V ESS Load Center Transformers 1X210 and 1X220 in Unit 1(1) _(continued)

(1) sftt;te M!ilO Fl'!e*1ifi6Eitiel9s el9 t!;ts U19it 1 1/\2Q1 EII9*11/\2Q2 4.1@ leV Bllsss, t!;tis Sl*tsl9siel9 is 19e le19ssr 819*1 will el9 MEiy 2Q12. Upon completion of the replacement of 480 V ESS Load Center Transformers 1 X21 0 and 1 X220 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 ACTIONS (continued)

CONDITION B. One Unit 2 RHRSW subsystem B.1 inoperable.

C. Both Unit 2 RHRSW subsystems C.1 inoperable. D. Required Action and associated D.1 Completion Time not met. AND OR D.2 UHS inoperable. REQUIRED ACTION RHRSW System and UHS 3.7.1 COMPLETION TIME Restore the Unit 2 RHRSW subsystem 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from discovery to OPERABLE status. of the associated Unit 1 RHRSW subsystem inoperable OR 9§ iFlstallatieFl ef iFl*Jwse*J Fl1@*Jifi6Elti9FlS iFl UFlit 1 t4t 7 days during the replacement o f 480 V ESS Load C enter Transformers 1X21 0 and 1X220 in Un i t 1(1) AND 7 days Restore one Unit 2 RHRSW subsystem 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months from discovery of to OPERABLE status. one Unit 1 RHRSW subsystem not capable of supporting associated Unit2 RHRSW subsystem AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Be in MODE 3. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Be in MODE 4. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (1) UJ39R S9FflJ3IetisR sf tlcle Mli)Q FflS*lifisatiSRS SR tlcle 'JRit 1 1!\201 GIR*1 1A2Q2 4.19 kV ewses, tiel is teFflJ3SFsFY El)(tSRsisR is Rs lsRser sJ3J3Iisaele sR*1 will El)(J3ire sR May 2012. Upon completi o n 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)

BASES ACTIONS QJ. (continued)

Distribution Systems-Operating B 3.8.7 Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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

!;!as l:leef:l *l)(teF1*1e*1 te Q@

iF1 er*1er te tt;te iF1 UF1it 1 assesiate*1 wit!;! tt;te P:ire Tt;tis is a

l)deF1sieF1 sf tFie eftFie SF1 all UF1it 1 4.1@ I<V tFiis e)(teF1sieF1 is F19 af:l*1 will

JF1 1, 2012. The Completion T i me 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 rep l acement , this temporary extension is no longer applicable and wi l l 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 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and to MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The 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 1 E 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 BASES ACTIONS A.1. A.2 and A.3 (continued)

RHRSW System and UHS B 3.7.1 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 te Qe iR er*ler te @9f.l1t:Jiete tl;!e f.l1*l*lifieatieRs iR URit 1 esseeiete*l wit!;! tl;!e Fire Ot:JeFatieRs Tt;Jis is e t*lf.l1t:J9F8FJ' ef tt;Je Cer.l1t:JietieR Tif.l1e aRe is Oit:Jt:Jiisaele tl;!e 1A2Q1 sR*l1A2Q2 f.l19elifieatieRS.

IR 9F*ler te 59t:Je wit!;! *

tl;!e ef e LQQj;l , a LOCI\ iR URit 2 eRe tt;Je ef URit 1 tl;!e e){teR*le*l Cer.l1t:JietieR Tif.l1e, tt;Je fellewiR§ eef.l1t:JeRsateF)'

aeti*lRS are

1) tt;Je affeete*lleet:J's St:JFBY array eyt:Jass valves are iR t!;!e et:JeR t:JesitieR aRe 2) tt;Je affeete*lleet:J

's St:Jray array valves are slese*l. Ut:J9R s9f.l1t:JietieR ef tl;!e M&:O f.l19*lifieati9RS QR ell URit 1 4.1e IN tl;!is tef.l1t:J9F8f'j is RQ leR§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 i re 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 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , 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 Til'¥!e te festefe IJRit 2 RJ.IRS'A' as !:leeR *l)(teR*1e*1 te 9@

iR ef*1e f te l'¥!e*1ifiaati*lRS iR URit 1 ass*l*liate*1 Fim IRis is a

@)G*RSi*lR

lf Til'¥!e aR*1 is 1/\2Q1 aR*11/\2Q2 l'¥!*l*1ifiE>atieRs. IJRit 2 RJ.IRSW f*ll'¥!aiRs siR6*l aR fl*lw aR*1 aR IJJ.IS.

lf MSO l'¥!*l*1ifiE>ati*lRS

lFI all

'JRit 1 4.1@ kV t!;;Jis exteRsi*lR is R*l aR*1 will 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 T i me and is applicable dur i ng the transformer replacement.

The Unit 2 RHRSW subsystem rema i ns 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 Jon A. Franke Site Vice President Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick , PA 18603 Tel. 570.542.2904 Fax 570.542.1504 Jon.Franke@talenenergy