Text

CFR 50.59 Summary Report
	ML053360555
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/21/2005
From:	James D; Entergy Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	2CAN110502
	Download: ML053360555 (321)
	v • d • e

AtEntergy Operations, Inc.

Entero- 1448 S.R. 333 Russeliville, AR 72802 Tel 479-858-4888 Dale E. James Manager, Licensing Nuclear Safety Assurance 2CAN110502 November 21, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

10 CFR 50.59 Summary Report Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

Dear Sir or Madam:

In accordance with 10 CFR 50.59(d)(2), enclosed is the Arkansas Nuclear One - Unit 2 (ANO-2) 10 CFR 50.59 summary report for the time period ending October 11, 2006. This report contains a brief description of changes in procedures, the facility as described in the ANO-2 Safety Analysis Report (SAR), changes in the ANO-2 Technical Requirements Manual (TRM), and changes in the ANO-2 Technical Specification (TS) Bases. The report also contains a description of tests and experiments conducted, if any, which were not described in the SAR, and other changes to the SAR for which a safety evaluation was conducted. A copy of each safety evaluation, both ANO-2 specific and those evaluations common between ANO-2 and ANO - Unit 1 (ANO-1), is included in the enclosure.

This report was previously submitted via CD-Rom on October 13, 2005 (2CAN100502).

However, the staff requested the report to be resubmitted since the CD-Rom file text was not fully searchable. Therefore, a hard copy of the report is being submitted under this letter.

If you have any questions or require additional information, please contact David Bice at 479-858-5338.

Sincerely, le EJames DEJ/dbb : ANO-2 10 CFR 50.59 Summary Report

2CAN1 10502 Page 2 of 2 cc: Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Drew G. Holland MS O-7D1 Washington, DC 20555-0001

ANO-2 10 CFR 50.59 Summary Report 50.59 # Initiating Document Summary 2003-17 ER-ANO-2000-2804-017 HPSI Pump 2P-89C Replacement 2003-29 ER-ANO-2003-0787-000 Minimum SWS Flow Required for SDC Room Cooling 2003-31 ER-ANO-2003-0793-000 Minimum Service Water Flow Required for LPSI Pump Seal Coolers 2004-14 ER-ANO-2003-0793-001 SDC Pump Seal Cooler SW Flow Evaluation 2004-15 TRM Revision 17 Relocate Presssurizer Heatup/Cooldown Limits TS/Bases to TRM 2004-16 ER-ANO-2000-3275-003 Temp-Alt to Maintain HPSI Header Pressurization 2004-20 ER-ANO-2004-0172-000 Clarification of Scale and Pointer System Associated with the ANO-2 SFP and Cask Loading Pit 2004-22 ER-ANO-2000-2768-002 Circuit Isolation for EDG Room Exhaust Fans 2004-23 ER-ANO-2004-0786-000 Clarification of SFP Transfer Tube Outside Valve Containment Isolation Function 2004-24 ER-ANO-2002-0875-004 Removal of SDC Automatic Closure Interlock 2004-26 ER-ANO-2002-0393-000 Removal of CAMS High/Low Air Flow Trip Function 2004-27 ER-ANO-2004-0933-000 Temporary Alteration to Maintain Quench Tank Penetration Isolation Valve in the Closed Position 2004-28 ER-ANO-2004-0618-000 Temporary Alteration to Install/Remove SFP Reverse Osmosis Cleaning System 2004-30 ER-ANO-2003-0012-029 Evaluation of Postulated Unit 2 Boron Dilution Event 2005-02 ER-ANO-2004-0098-002 Temp-Alt to Install Temporary ECP Water Barrier 2005-04 ER-ANO-2002-1078-009 SG Replacement Heavy Load Evaluation 2005-06 A2-NE-2004-000 Unit 2 Cycle 18 Reload Report 2005-07 A2-NE-2004-001 Unit 2 Cycle 18 Core Operating Limits Report (COLR) 2005-08 ER-ANO-2003-0245-017 Reactor Vessel Head Shroud Modification 2005-12 A2-NE-2005-003 Criteria for Failed Incore Instrument During Startup 2005-13 A2-NE-2005-003 Additional Information Regarding Failed Unit 2 ICI During Startup 2005-19 ER-ANO-2005-0316-000 Temporary Alteration to Supply Dummy CEA #20 Position Signal to CEAC #1 2005-21 ER-ANO-2002-1078-010 Replacement SG Rigging Outside Reactor Building 2005-24 OP-2409.763 Verification of Fuel Pins Located Inside Guide Tube Assemblies

ANO 50.59 Evaluation Number 2003-017

EN-S NUCLEAR QuALrry RELATED LI-101 Revision 3

-- Entew" '-"51 MANAGEMENTADMINIsTRATWE MANUAL INFORMATiON USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 1 of 15 I. OVERVIEW I SIGNATURES Facility: ANO - Unit 2 Document Reviewed: ER-ANO-2000-2804-017 including linked ERs 2000-2804-022, -023, -024 & -025 and W4'rM Plan 24D?.752-. Change/Rev.: aew-System Deslgnator(s)IDescription: HPSI jD 'rt/y/°) f Description of Proposed Chanae See Continuation Page If the proposed activity, In Its entirety, Involves any one of the criteria below, check the appropriate box, provide a justification/basis In the Description above, and forward to a Reviewer. No further 50.59 Review Is required. If none of the criteria Is applicable, continue with the 50.59 Review.

El The proposed activity is editorial/typographical as defined in Section 5.2.2.1.

[3 The proposed activity represents an "FSAR-only" change as allowed in Section 5.2.2.2 (Insert item # from Section 5.2.2.2).

If further 50.59 Review is required, check the applicable review(s): (Only the sections Indicated must be Included In the ReView.)

O SCREENING Sections I, II, III, and IV required El 50.59 EVALUATION EXEMPTION Sections I, II, III, IV, and V required 0 50.59 EVALUATION (#: A4f 03_0/ 7 Sections I, II, III, IV, and VI required Preparer: Edward R. France 4 1 t% 61/DE/ A- -0° Name (print) I Inatur / Co Litany I Department / Date Reviewer: Steohen J. Lnn! A3PS1vn..L 4 ,EOlIDE / 4 2- * -I ~L., N LV 74' Name (print) / Sign ure / Vpffiny /Depart ItDate MI=prI A l . ' A a te g - L OSRC -CChairman's

,hOlj Signature / Date pi11XAc VX4 <-4 2

[Required only for Programmatic Exclusion Screenings (see Section 5.9) and 50.59 Evaluations.]

List of Assisting/Contributing Personnel:

Name: Stan Haynes, John Hotz, Susan Mitchell, Scope of Assistance:

John Richardson Entire 50.59

EN-S NUCLEAR QUAuTY RELATED LI-101 Revision 3 to LJILLE E IIMANUAL MANAGEMENT ADMINISTATNE 6

INFORMAON USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 2 of 15 Description of Proposed Change This 50.59 supports the modification upgrades to the High Pressure Safety Injection (HPSI) 2P-89C pump bearing housing, installation of a precision pump element with back filed impeller, and a Schnoor spring kit per ER-ANO-2000-2804-17 and Work Plan OP-2409.752. The Safety Analysis calculations were revised to incorporate maximum HPSI flow of 900 gpm and pump horsepower requirements of 530 HP. The supporting calculations and this 50.59 will support operation of all three HPSI pumps with the same modification applied.

The bearing housing change is for the purpose of eliminating bearing overheating due to the cold water crush concern due to unregulated service water temperatures and the concern for bearing outer race slippage due to improperly sized bearing support areas. The new precision pump element and Schnoor spring kit will mitigate the accelerated wear and elevated vibration levels.

The bearing housings replacement, the pump element replacement and the new Schnorr spring kit for the 2P89C HPSI pump has been evaluated and justified per this ER-ANO-2000-2804-017 with linked ERs 2000-2804-022, -

023, -024, and -025. The new components are for the purpose of mitigating bearing overheating, pump vibration and accelerated wear. During 2R14 the 2P-89A and 2P-89B pumps were modified by ER002804N201. The 'A' pump had a new Schnoor kit installed and the 'B' pump had a new Schnoor kit and new precision pump element installed.

Based on the evaluations of this NCP, past evaluations, past operating experience and vendor input, these changes will enhance the performance and reliability of the HPSI pumps and HPSI system.

The Post Modification Test of Work Plan OP-2409.752 measures pump and motor performance and is allowed by existing procedure 2104.039.

ERs 2000-2804-022, -023, -024 & 025 evaluated the issues affected by the increase in HPSI pump flow and HPSI pump motor horsepower. Included were EDG loading, EQ, HPSI pump room heat load, containment pressure, ECP temperature, LTOP performance, cladding temperature, SGTR (steam generator tube rupture) issues.

As a result of the calculation revisions and pump configuration change the following SAR items require revision:

ANO-2 SAR Section 15.1.18.4.3.2 This SAR section describes the results of the Steam Generator Tube Rupture (SGTR) event which currently states that <121,000 lbs. of reactor coolant is transported to the main steam system. The SGTR event was evaluated for the increased HPSI flow per Calculation 97-E-0204-05 which resulted in an increase in the reactor coolant being transported to the main steam system. Therefore, Section 15.1.18.4.3.2 is being revised to state "<122,500 lbs. of reactor coolant is transported to the main steam system."

ANO-2 SAR Table 6.3-9 The table presents the results of DRN 03-1182 to Calculation 91-E-0007-06. The revision to this calculation maintained the total Low Pressure Safety Injection (LPSI) and HPSI flow such that the results of the Emergency Core Cooling System (ECCS) performance evaluation remain unchanged.

ANO-2 SAR Table 8.3-1 DRN-03-1242 to 89-E-0144-01 addressed the increased Emergency Diesel Generator requirements for the HPSI pump modifications.

ANO-2 SAR Table 7.5-3 DRN 03-824 for drawing M-2538 shows a new output range of 0-1000 gpm per ER-ANO-2000-2804-024 to account for the 900 gpm max flow.

ANO-2 SAR Table 6.3-1 ER-ANO-2002-0528-00S changed calculation 91-E-01 16-01, rev 5 for a maximum pump flow of 900 gpm.

EN-S NUCLEAR QUAurY RELATED LI-101 Revision 3 A tee MANAGEMENT ADMINISTRATIVE

'- nte6 MANUAL INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 3 of 15 ANO-2 Figure 6.3-4 Due to conflicting pump curve data this curve will be changed at a time when all 3 pumps have been upgraded.

ANO-2 SAR Figure 9.2-22 DRN-03-1372 which changed drawing M-2250 applies to this Figure as well.

ANO-2 SAR Section 6.3.2.7 The pump power requirements are not given in Table 6.3-1. Therefore, delete the sentence stating "pump power requirements are given in Table 6.3-1 " .

EN-S NUCLEAR QUAuIY RELATED LI-I01 Revision 3 EnteWI~ MANAGEMENT MANUAL ADMINISTRATIVE INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 4 of 15 ii. SCREENING A. Licensing Basis Document Review

1. Does the proposed activity Impact the facility or a procedure as described In any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # andlor SECTIONS IMPACTED Operating License 0 10 TS 101 0 NRC Orders 1 120 If "YES", obtain NRC approval prior to Implementing the change by InItiatIng an LBD change In accordance with NMM U1-113 (Reference 2.2.13). (See Section 6.1.13 for exceptions.)

LBDs controlled under 50.59 YES NO CHANGE # and/or SECTIONS IMPACTED FSAR 0 0 Table 6.3-9, Table 7.5-3, Table 6.3-1, Figure 9.2-22, Table 8.3-1, Section 15.1.18.4.3.2, Section 6.3.2.7, Figure 6.3-4 TBases 0 0 Technical Requirements Manual 0 0 Core Operating Umits Report 0 0 __

NRC Safety Evaluation Reports' 0 02 If "YES", perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI AND Initiate an LBD change In accordance with NMM L1-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # (if applicable) andlor SECTIONS IMPACTED 2

Quality Assurance Program Manual 0 0 2

Emergency Plan 0 0 _

3 Fire Protection Program 0 0 (includes the Fire Hazards Analysis)

Offsite Dose Calculation Manual` 0 0 If "YES", evaluate any changes In accordance with the appropriate regulation AND Inmate an LBD change In accordance with NMM 1.-113 (Reference 2.2.13).

2. Does the proposed activity Involve a test or experiment not described In the 0 Yes FSAR? Z No If "yes," perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI.

3. Does the proposed activity potentially Impact equipment, procedures, or facilities 0 Yes utilized for storing spent fuel at an Independent Spent Fuel Storage Installation? 1 No (Check 'NIA" if dry fuel storage Is not applicable to the facility.) 0 NIA If "yes," perform a 72A8 Review In accordance with NMM Procedure L-112.

(See Sections 1.5 and 5.3.1.5 of the EOI 10CFR50.59 Review Program Guidelines.)

1If YES, see Section 5.1.4. No LBD change is required.

2 If 'YES,' notify the responsible department and ensure a 50.54 Evaluation is performed. Attach the 50.54 Evaluation.

3 If 'YES, evaluate the change in accordance with the requirements of the facility's Operating Ucense Condition.

EN-S NUCLEAR QUALTY RELATED LI-101 Revision 3 Ente y yMANUAL MANAGEMENT _ ADMINISTRATIVE INFORMATION USE ATTACHMENT 9.1 60.59 REVIEW FORM Page 5 of S. Basis Provide a clear, concise basis for the answers given Inthe applicable sections above. Explain why the proposed activity does or does not Impact the Operating License/Technical Specifications and/or the FSAR and why the proposed activity does or does not Involve a new test or experiment not previously described In the FSAR. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simply stating that the change does not affect TS or the FSAR is not an acceptable basis. See EOI 50.59 Guidelines Section 5.6.6 for guidance.)

See Continuation Sheet C. References Discuss the methodology for performing the LBD search. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.3.6.4 of Li-101. NOTE: Ensure that electronic and manual searches are performed using controlled copies of the documents. If you have any questions, contact your site Licensing department.

LBDs/Documents reviewed via keyword search: Keywords:

50.59 unit 2 LRS: All (keywords of HPSI w/10 pump, bearing w/10 housing, 'high pressure safety Injection", 2P-89A, 2P89A, 2P-89B, 2P89B, 2P89C, 2P-89C, thrust bearing", bearing wO10 cooling)

"SteamGenerator Tube Rupture", SGTR,

'121,000"l HPSI wt20 max, HPSI w120 maximum, HPSI w120 hp, HPSI wt20 horsepower, HPSI w120 EDG, HPSI w120 470, HPSI wt20 600, HPSI w/20 Emergency, HPSI w/20 flow, ECCS, Emergency Core Cooling System, Emergency Cooling Pond, ECP, Emergency Diesel Generator, EDG, LTOP, Low Temperature Overpressure Protection, recirculation, recirculation actuation signal, RAS, transfer wt25 sump, transfer w125 RWT, minimum time, containment sump LBDs/Documents reviewed manually.

Unit 2 SAR Section 15.1.18, SAR Chapter 6, SER 244, TS3/4.4.12, 3/4.5.2, 3/4.5.3, 3/4.8.1 and associated TS bases, SAR Chapter 6 Tables and Figures D. Is the validity of this Review dependent on any other change? (See Section 5.3.4 of the EOI 10CFR50.59 Program Review Guidelines)

If "Yes," list the required changes.

EN-S NUCLEAR QUALT RELATED LI-101 Revision 3 ALJEntew MANAGEMENT MANUALEEN ADMINISTRATIVE 6

INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 6Of 15 B. Basis: (continuation)

Operating License Documents: The operating license does not describe pump construction. The effect of the change will be elimination of the possibility of cold water crush on the HPSI pump bearings, restoration of the design bearing to bearing housing clearance, lower vibration levels and provide for more consistent hydraulic performance. The result will in turn be longer time spans between corrective maintenance activities and the ability of the pump to more reliably meet all design basis requirements with cooling water un-isolated to the bearings. No change to the operating license is required.

The operating license documents consider the requirements for HPSI flow and also the Emergency Diesel Generator (EDG) loading. For HPSI flow the Technical Specifications and Bases are concerned with meeting minimum flow requirements and also flow distribution requirements (TS 314.5.2, 3/4.5.3 and associated bases section). The bases section indicate that the surveillance procedures will ensure that system flow will remain within the analyzed range. The SGTR analysis with Increased HPSI flow resulted In an increase Inthe primary to secondary leakage through the ruptured tube. The Operating License, Including Technical Specifications and NRC Orders do not discuss the SGTR event or any of the results from the event. While TS Basis 3/4.4.6.2, Reactor Coolant System Leakage", and 3/4.4.8, "Specific Activity" mentions a SGTR, it only discusses the dose consequences of the tube rupture and not the level of detail that Includes the amount of leakage from the ruptured tube.

The EDG load has been evaluated against the increased horsepower requirements of HPSI pump motors.

The pertinent calculations have been revised to show that the diesel has adequate margin to handle the increased horsepower requirements of the HPSI pump. Review of the operating license documents Indicates that the EDG loading is not discussed regarding the capability of the machine. TS 3/4.8.1 provides surveillance requirements for demonstrating EDG operability. This TS defines the allowed startup times, the ability to output a given load (less than the maximum capability), and the ability to handle the loss of the largest major load. This proposed modification will not change these requirements or invalidate the ability of the EDG to handle the design basis loads.

LTOP requirements are unchanged as described in the operating license documents. The modification Is shown to be within the design basis of the system. Therefore, there is no impact to the Operating License Documents from the proposed modification to the HPSI system.

LBDs Controlled Under 60.59: The SAR documents were reviewed and information was discovered such that the proposed changes will cause a SAR statement to be untrue or Inaccurate. SAR Sections 6.3.2.7 will be revised per the attached LBDC forms to correct an existing error In the statement. Table 6.3-9 will have a new max HPSI flow value of 1760 gpm. Table 7.5-3 will be revised to change the instrumentation flow range requirement. Figure 6.3-4 will be revised to show that the curve will be updated at a later date. Table 6.3-1 will be revised to change the maximum HPSI flow. Figure 9.2-22 will be revised for heat load by DRN 03-1372 due to the Increase in motor horsepower.

The SAR discusses the requirements for the SGTR analysis, HPSI flow requirements, Containment Analyses, Dose Consequences, Emergency Core Cooling Systems (ECCS) performance analyses, LTOP analyses, and EDG loading requirements that were impacted by the proposed modification. Review and revision of the indicated documents in section I will require revision SAR Tables 6.3-9 and 8.3-1, and SAR section 15.1.18.4.3.2.

EN-S NUCLEAR QuAuTY RELATED LI-101 Revision 3 MANAGEMENT ADMINISTRATVE 5Y MANUAL MANUAL INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 7 of 15 LBDs Controlled Under Other Regulations: The amount of primary to secondary system leakage being changed in the SAR, HPSI and LPSI flow rates, and EDG loading are a result of a modification to the HPSI pump. The modification does not alter the design function of the HPSI pump or its ability to meet designed requirements and does not involve or constitute a test or experiment. Nor does the HPSI pump modification affect the Independent Spent Fuel Storage Facility since the change only affects the performance of ECCS equipment.

The Work Plan is consistent with previous HPSI full flow test plans and is not a new test performed at ANO. The test is performed under normal surveillance procedures as identified in the SAR.

EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3

-En MANAGEMENT ADMINISTRATIVE INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 8 of 15 III. ENVIRONMENTAL SCREENING If any of the following questions Is answered "yes," an Environmental Review must be performed In accordance with NMM Procedure EV-116, "Environmental Evaluations," and attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated:

Yes No

1. 0 0 Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. 0 0 Involve a land disturbance of undisturbed land areas (i.e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. 0 0 Involve dredging activities in a lake, river, pond, or stream?

4. 0 0 Increase the amount of thermal heat being discharged to the river or lake?

5. 0 0 Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

6. 0 0 Discharge any chemicals new or different from that previously discharged?

7. 0 0 Change the design or operation of the intake or discharge structures?

8. 0 0 Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. 0 0 Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10. 0 0 Modify existing stationary fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11. 0 0 Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12. Dl 0 Involve the Installation or use of equipment that will result in an air emission discharge?

13. 0 0 Involve the installation or modification of a stationary or mobile tank?

14. 0l 0 Involve the use or storage of oils or chemicals that could be directly released into the environment?

15. 0 1 Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

1See NMM Procedure EV-1 17, 'Air Emissions Management Program,' for guidance in answering this question.

@ EN-S NUCLEAR QUAuTY RELATED LI-I01 Revision 3 a tMANAGEMENT ADMINISTRATIVE

Y MANUAL.. _

INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM I Page 9 of 16 IV. SECURITY PLAN SCREENING If any of the following questions Is answered "yes," a Security Plan review must be performed by the Security Department to determine actual Impact to the Plan and the need for a change to the Plan.

A. Could the proposed activity being evaluated:

Yes No

1. a 0 Add, delete, modify, or otherwise affect Security department responsibilities (e.g., including fire brigade, fire watch, and confined space rescue operations)?

2. 0 0 Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. 0 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. 0 0 Affect security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. 0 0 Modify or otherwise affect the intrusion detection systems (e.g., E-fields, microwave, fiber optics)?

6. 0 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. 0 0 Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8. 0 0 Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. 0 0 Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

10. 0 0 Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following questions If one of the questions was answered "yes".

B. Is the Security Plan actually impacted by the 0 Yes proposed activity? 0 No C. Is a change to the Security Plan required? E Yes Change # (optional)

El No Name of Security Plan reviewer (print) I Signature I Date

_ EN-S NUCLEAR QUALITY RELATED o101 Revision 3 ADMINISTRATIVE

Enteegy y MANAGEMENT MANUAL INFORMATION USE I I I ATTACHMENT 9.1 50.59 REVIEW FORM I Page 110lofjl1 V. 50.59 EVALUATION EXEMPTION Enter this section only If a "yes" box was checked In Section li.A, above.

A. Check the applicable boxes below. if any of the boxes are checked, a 50.59 Evaluation Is not required. If none of the boxes are checked, perform a 50.59 Evaluation In accordance with Section VI. Provide supporting documentation or references as appropriate.

0 The proposed activity meets all of the following criteria regarding design function per Section 5.6.1.1:

The proposed activity does not adversely affect the design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of performing or controlling a design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC described In the FSAR will be accomplished.

O An approved, valid 50.59 Review(s) covering associated aspects of the proposed activity already exists per Section 5.6.1.2. Reference 50.59 Evaluation # (if applicable) or attach documentation. Verify the previous 50.59 Review remains valid.

O The NRC has approved the proposed activity or portions thereof per Section 5.6.1.3.

Reference:

o The proposed activity Is controlled by another regulation per Section 5.6.1.4.

B. Basis Provide a clear, concise basis for determining the proposed activity may be exempted such that a third-party reviewer can reach the same conclusions. See Section 5.6.6 of the EOI 10CFR50.59 Review Program Guidelines for guidance.

EN-S NUCLEAR QuAuTY RELATED LI-101 Revision 3

-Entea MANAGEMENT ADMINISTRATIVE INFORMATION USE ATTACHMENT 9.1 50.69 REVIEW FORM Page 11 of 15 VI. 60.59 EVALUATION A. Executive Summary (Serves as Input to NRC summary report. Limit to one page or less. Send an electronic copy to the site licensing department after OSRC approval, ifavailable.)

Brief description of change, test, or experiment:

Per LI-10l, this section is not applicable to ANO and therefore, does not require completion.

Reason for proposed Change:

Per LI-101, this section is not applicable to ANO and therefore, does not require completion.

50.59 Evaluation summary and conclusions Per LI-101, this section is not applicable to ANO and therefore, does not require completion.

E EN-S NUCLEAR QUALTY RELATED LI-101 Revision 3 C-74f MANAGEMENT MANUAL.. ADMINISTRATIVE INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page of 15 B. License Amendment Determination Does the proposed Change being evaluated represent a change to a method of ' Yes evaluation ONLY? If "Yes," Questions 1 - 7 are not applicable; answer only l No Question 8. If "No," answer all questions below.

Does the proposed Change:

1 Result in more than a minimal increase in the frequency of occurrence of an 0 Yes accident previously evaluated in the FSAR? 0 No BASIS:

This nuclear change modifies specific HPSI pump components. The modifications will enhance operation In terms of lower vibration levels and greater longevity and will be transparent to the remainder of the HPSI system. No accident previously evaluated in the SAR Is initiated by a failure of a HPSI pump. The HPSI pumps are normally in a standby condition and are activated in response to accident conditions. Therefore, the frequency of occurrence of an accident previously evaluated in the SAR will not be increased.

2. Result in more than a minimal increase in the likelihood of occurrence of a E Yes malfunction of a structure, system, or component important to safety previously 3 No evaluated in the FSAR?

BASIS:

The modification increases the ability of the HPSI system to meet its design function by increasing the Head/Flow characteristics, updating the bearing system to a more reliable and robust arrangement, providing a more vibration resistance internal pump configuration and eliminating the possibility of cold water crush of the bearings. No changes are made which will present any unanalyzed challenge to any interfacing systems.

The modified pump (2P-89C) per ER 2000-2804-017 will continue to meet the operational aspects of the original design specification and the design margin as defined by the ANO-2 Technical Specifications and SAR documents. The modifications implemented by this nuclear change address the original design philosophy, now known to be Imperfect, of optimizing the various piece-parts and their working relationship for a particular operating regime, which in this instance is rarely realized. As opposed to steady state operation near the BEP (best efficiency point), frequent starts and stops with Interim operation at flow conditions far below or well above the BEP is typical. The material changes reflect a progression to materials better suited for the transient and off BEP service these pumps are subjected to, particularly in the areas of strength, hardness, and wear resistance, while maintaining the corrosion resistance required for the application. Individually and collectively, the modifications will enhance pump longevity, with a corresponding positive effect on availability and reliability. The horsepower requirements of 2P-89C will increase consistent with that of 2P-89B. The Emergency Diesel (EDG) Load will not exceed the EDG capacity and will not increase its likelihood of failure. Therefore, the likelihood of occurrence of a malfunction of equipment important to safety will not be increased.

EN-S NUCLEAR QuAuT RELATED LI-101 Revision 3 toh MANAGEMENT ADMINISTRATVE En Lii to,5 MANUAL INFORMATnON USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 1

3. Result in more than a minimal increase in the consequences of an accident 0 Yes previously evaluated in the FSAR? 3No BASIS:

The modifications implemented by this nuclear change are in response to less than satisfactory HPSI pump performance in terms of the frequency and scope of required corrective maintenance activities. The changes are directed at lowering pump vibration levels via material changes and design / assembly features and methods to Improve rotor stability (radial and axial) and wear resistance. The hydraulic performance of the pump is affected in terms of discharge head, flow, and pressure, but does not affect net positive suction head (NPSH) requirements. These changes will have the effect of improving the availability and reliability of the HPSI pumps, thus reducing the potential for pump failure or degradation to 'become a factor in accident mitigation.

The proposed HPSI modification has been evaluated as for the impact to the ECCS Performance analysis, Containment Analysis, EDG loading, LTOP, and non-LOCA transients.

No changes to the analysis results described in the SAR other than the SGTR have been identified. The impact of the proposed modification to the SGTR event results in an Increase In the primary mass that is transferred to the main steam system through the ruptured tube. SAR Section 15.1.18.4.3.2 reflects the change from 121,000 lbs to 122,500 lbs (rounded up from 122,400). However, due to the differences in the flashing fractions, the amount of reactor coolant that immediately flashes to steam and escapes through the main steam safety valves is decreased from 6865.2 lbs to 6778.6 lbs. The reactor coolant that flashes to steam carries radiolodine directly from the reactor coolant to the atmosphere through the safety valves. This steam release is one contributor to the offsite and control room dose. Other contributors to dose include the portion of the secondary side inventory that Is released through the safety valves during the cool down phase from both steam generators. The affected Steam Generator is isolated in 60 minutes and the unaffected Steam Generator is then used for cool down. The Technical Specification limit for secondary coolant specific activity is 10% of the primary coolant specific activity. Also, any release from the secondary side Inventory Is further reduced by the decontamination factor of 100. Therefore, the reactor coolant that flashes to steam and escapes directly through the MSSV Is by far the main contributor to the offsite and control room dose. Since there was a decrease in this steam release, the current analysis of record, Appendix E of Calculation 98-E-0036-04, remains bounding, and there is no increase in the resultant doses from a SGTR. Therefore, the increase in the HPSI flow does not result In an Increase in the consequences of the SGTR event.

4. Result in more than a minimal increase in the consequences of a malfunction of a a Yes structure, system, or component important to safety previously evaluated in the 0 No FSAR?

EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3

--EnteW MANAGEMENT ADMINISTRATIVE MA INFORMATION USE ATTACHMENT 9.1 j 60.59 REVIEW FORM j Page j Of I15 BASIS:

This modification does not change the interdependence of the affected component (2P89C) with any other component. The change does not make the pump more likely to leak than before nor will it make the pump less able to perform in the case of a single failure of any other component.

The modifications are restricted to the pump itself with no adverse effect on any other SSC.

There is a change in hydraulic performance and in power consumption. The failure modes of a HPSI pump modified per this nuclear change are the same as those for an unmodified pump (no flow, degraded flow, leakage).

The proposed modification to the HPSI system was evaluated against the safety analysis presented In the SAR. The Containment, ECCS performance, EDG loading requirements, and the Low Temperature Over Pressure (LTOP) analyses were all found to be bounded by the current analysis of record (AOR). For the SGTR analysis the increase In the primary coolant transferred to the main steam system through the ruptured tube is the result of a malfunction of a component (SG tube). As stated in Question 3, there was a decrease in the reactor coolant that flashes to steam and released through the safety valves, therefore, there was no increase in dose due to the ruptured steam generator tube.

5. Create a possibility for an accident of a different type than any previously evaluated 0 Yes in the FSAR? 0 No BASIS:

The HPSI pumps are not the initiator of any accident evaluated in the SAR. They are used only for accident mitigation. Auto-start set points and criteria for securing a HPSI pump also remain unchanged. Therefore, the possibility of an accident of a different type than any previously evaluated in the SAR will not be created.

6. Create a possibility for a malfunction of a structure, system, or component 0 Yes Important to safety with a different result than any previously evaluated in the 0 No FSAR?

BASIS The location, orientation, NPSH requirements I availability, and system Interface remain unchanged. The ability to start and operate during a seismic event or at reduced motor supply voltages is not degraded as a result of this change. The debris passing capability is not reduced because the only change in an internal clearance of interest Is an increase in impeller to diffuser vane gap. The material substitutions result in an improvement in the pumps ability to respond without progressive damage to the cyclic off BEP operation they typically are subjected to. Therefore, the possibility of a malfunction of equipment Important to safety with a different result than any previously evaluated Inthe SAR will not be created.

7. Result in a design basis limit for a fission product barrier as described in the FSAR 0 Yes being exceeded or altered? ED No

n I EN-S NUCLEAR MANAGEMENT QUALTY RELATED ADMINISTRATIVE LI-101 Revision 3 l £U61 MANUAL INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 15 of BASIS:

Start and run capability (including operation at reduced voltage and during seismic events),

hydraulic performance (including operation at available NPSH), debris passing capability, tolerance to thermal transients, operation at vibration levels sufficiently low to ensure required run time capability, Internals resistance to corrosion and limited leakage (with or without a temporary loss of cooling water) are all implicit criteria serving to establish the margin of safety provided by the HPSI pumps. System requirements for limiting runout flow and providing proper flow splits and pump requirements for providing adequate flow are specifically addressed in the applicable Tech Spec bases.

ECCS performance analyses remain bounding due to conservatisms in the current AOR for maximum HPSI and LPSI flows. The current containment analysis also remains bounded by the AOR based again on the conservatisms in the combined HPSI and LPSI flows. The SGTR analyzes the breach of a fission product barrier (steam generator tube). The evaluation of increased HPSI flow shows that the analysis of record remains bounding, thus fuel safety limits are not challenged and since the SGTR event results in a release of steam directly to the atmosphere, there Is no impact to the containment. LTOP evaluations show that the increased HPSI flow is within the current AOR so that the RCS will not be challenged beyond the current limts. Therefore, the design basis limit for the fuel and containment is not altered or exceeded as a result of the increased HPSI performance.

8. Result in a departure from a method of evaluation described In the FSAR used in E Yes establishing the design bases or in the safety analyses? 0 No BASIS:

The method used for evaluating the safety analyses remains unchanged. The evaluations performed include the SGTR analysis, the Containment Analysis, EDG loading evaluation, Dose Analysis, ECCS Performance analysis. Each of these evaluations was performed to assess the impact of Increased HPSI flow and increased pump horsepower requirements. In each case the methodology employed was identical to the AOR. Therefore, no methodology change was made.

No method of evaluation Is affected by the material and component upgrade Incorporated by this modification. The HPSI pumps still provide the ECCS safety functions with the same or better expected performance. The bearing housing, pump element and bearing spring kit are determined to mitigate the elevated bearing temperature, the pump vibration and accelerated wear phenomena.

ANO 50.59 Evaluation Number 2003-029

EN-S NUCLEAR QuAuTY RELATED LI-101 Revision 3 Ente-Ey MANAGEMENT ADMINISTRATWVE ATTACHMENT 9.1 E 1 50.59 REVIEW FORM Page tI

1. OVERVIEW I SIGNATURES Facility: ANO - Unit 2 Document Reviewed: ER-ANO-2003-0787-000 ChangelRev.: 0 System Designator(s)IDescriptlon: Service Water. Auxiliary Building HVAC Description of Proposed Chance ER-ANO-2003-0787-000 evaluates the minimum required Service Water flow for Operability of the equipment cooled by the Shutdown Cooler room coolers, 2VUC-1A, 1B and IC. The ER calculates the flow required to provide a room temperature at 143 degrees F. Maximum room temperature for Operability of the equipment is 143.6 degrees F. Drawing M-2250 (2FSAR 9.2-22) "Schedule of Water Demand for Aux. Cooling and Service Water System" states the minimum qualified flow Is 40 gpm. The 40 gpm value was derived In CALC-94-E-0095-20, Rev 0 based on a room temperature of 141 degree F. .

DRN-03-1872 will change the required flow from 40 gpm to 29 gpm on M-2250. A note Is also added that ER-2003-0787-000 provides an operability evaluation for Shutdown Cooler room coolers 2VUC-IA, 1B and IC. The minimum flow for operability Is 29 gpm per cooler. Any 2 of 3 coolers meet room heat loads for DBA conditions. However, design flow rates are not changed.

If the proposed activity, In its entirety, Involves any one of the criteria below, check the appropriate box, provide a Justificationlbasis In the Description above, and forward to a Reviewer. No further 50.59 Review Is required. If none of the criteria is applicable, continue with the 50.59 Review.

El The proposed activity Is editorlaltypographical as defined In Section 5.2.2.1.

O The proposed activity represents an FSAR-only" change as allowed in Section 52.2.2 (insert Item # from Section 5.2.2.2).

If further 50.59 Review Is required, check the applicable review(s): (Only the sections Indicated must be Included In the Review.)

El SCREENING Sections 1,11, III, and IV required 0 50.59 EVALUATION EXEMPTION Sections I, II, I, IV, and V required 0 50.59 EVALUATION (#: rrAJ) 1t a1S -OA 92 Sections I, II, III, IV, and VI required Pranararf

. .or-. -a@

Steve Bo i,, O Ai ?t I EOI / SYS /

Name (print) I Sign 9eI Comoifi I Department / Date Reviewer: Keith Perkins/ I O I EOI / SYS I /Q _

Name (print) I Signature / Company I epartment / Date OSRC (~ ,htper ~"/j Z, J &-. i3 a-j

-hairmran's Name (print) / Signatdre / Dat! /

[Required only for Programmatic Exclusion ScA16ings (see Section 5.9) and 50.59 Evaluatlons.]

List of Assisting/Contributing Personnel:

Name: Scope of Assistance:

Roger Wilson Wrote initial 50.59 Exemption

EN-S NUCLEAR QUALITYRELATED LI-101 Revision 3 RANAGEMENT Ent& L MANUAL ADMiNiSTRATivE ATTACHMENT 9.1 50.59 REVIEW FORM Page 2of 9 II. SCREENING A. Licensing Basis Document Review

1. Does the proposed activity Impact the facility or a procedure as described In any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # andlor SECTIONS IMPACTED Operating Ucense Cl 0 TS 00 ___

NRC Orders 0 0is if "YES", obtain NRC approval prior to Implementing the change by Initiating an LBD change In accordance with NMM U-413 (Reference 2.2.13). (See Section 5.1.13 for exceptions.)

LBDs controlled under 50.59 YES NO CHANGE # andlor SECTIONS IMPACTED FSAR 0 O Unit 2 SAR Figure 9.2-22 TS Bases 0 0__

Technical Requirements Manual 03i 0 Core Operating Limits Report 0 0I NRC Safety Evaluation Reports' 0 0 If "YES", perform an Exemption Review per Section V PR perform a 50.59 Evaluation per Section Vi AND Initiate an LBD change In accordance with NMM U-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # (if applicable) andlor SECTIONS IMPACTED Quality Assurance Program Manual2 0 [

2 0 Emergency Plan 0 Fire Protection Program 3 0 0 Onndudes the Fire Hazards Analysis)

Offslte Dose Calculation Manual 3P 0 If -YES", evaluate any changes In accordance with the appropriate regulation D Initiate an LBD change In accordance with NMM U-113 (Reference 2.2.13).

2. Does the proposed activity Involve a test or experiment not described In the El Yes FSAR? O No If "yes," perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI.

3. Does the proposed activity potentially Impact equipment, procedures, or facilities [ Yes utilized for storing spent fuel at an Independent Spent Fuel Storage Installation? 0 No (Check "'INA"If dry fuel storage Is not applicable to the facility.) NIA If "yes," perform a 72.48 Review In accordance with NMM Procedure LI-112.

(See Sections 1.5 and 5.3.1.5 of the EOI 10CFR50.59 Review Program Guidelines.)

1 If "YES,* see Section 5.1.4. No LBD change Is required.

2 If "YES," notify the responsible department and ensure a 50.54 Evaluation Is performed. Attach the 50.54 Evaluation.

3 I "YES," evaluate the change in accordance with the requirements of the facility's Operating Ucense Condition.

EN-S NUCLEAR QUAL RELATED LI-101 Revision 3 MANAGEMENT ADMINISTRATVEI Eno.g MAUA -I ATTACHMENT 9.1 50.59 REVIEW FORM I Page J 3l of _I 9 B. Basis Provide a clear, concise basis for the answers given in the applicable sections above. Explain why the proposed activity does or does not Impact the Operating License/Technical Specifications andlor the FSAR and why the proposed activity does or does not Involve a new test or experiment not previously described In the FSAR. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the'same concluslons. Simplystatingrthat the change does not affect TS or the FSAR Is not an acceptable basis. See EOI 50.59 Guidelines Section 5.6.6 for guidance.)

ER-ANO-2003-0787-000 is an operability evaluation for Shutdown Cooler room coolers 2VUC-IA, 1B and IC. The ER Issued DRN-03-1864 to Calc-94-E-0095-20. The DRN provides a minimum flow rate for the room coolers of 29 gpm per cooler to assure a maximum room temperture of 143 degrees F. Any 2 of 3 coolers provide the cooling required to meet the DBA heat loads for Shutdown Cooling room 2013/2014 (Vault A). New note 18 to this effect Is added to drawing M-2250, sheet 1, rev. 18. The drawing is 2FSAR Figure 9.2-22. The note states that design flow rates for the coolers are not changed by the operability evaluation. As stated above, ER-ANO-2003-0787-000 provides an operability evaluation for minimum flows to the Shutdown Coolers room coolers. No other FSAR impacts were Identified. Details concerning the required service water flow for room cooling are below the level of detail typically contained In other LBD's or the Operating License, Tech Specs or any other LBD. The evaluation proposes no new test or experiment. The evaluation will be used in conjunction with standard as-left service water system flow testing at the end of 2R16.

C. References Discuss the methodology for performing the LBD search. State the location of relevant licensing document Information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.3.6.4 of L-101. NOTE: Ensure that electronic and manual searches are performed using controlled copies of the documents, If you have any questions, contact your site Licensing department LBDs/Documents reviewed via keyword search: Keywords:

LRS Search U2 50.59 "2VUC-lA" or "2VUC-lB" or "2VUC-IC";.

(shutdown w120 room Unit cooler)

LBDs/Documents reviewed manually.

Figure 9.2-22, 2FSAR Section 9 Table 9.2-5, "Service Water System Single Failure Analysis",

2FSAR 9.2.1.2.2.5, [SW] Valves and Sluice Gates D. Is the validity of this Review dependent on any other E Yes change? (See Section 5.3A of the EOI IOCFR50.59 Program 3 No Review Guidelines)

If "Yes," list the required changes.

NIA

EN-S NUCLEAR QUAurTy RELATED LI-101 Revision 3 MANAGEMENT ADMINISTRATVE tew MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 4 Ill. ENVIRONMENTAL SCREENING If any of the following questions Is answered "yes," an Environmental Review must be performed in accordance with NMM Procedure EV-115, "Environmental Evaluations," and attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated:

Yes No

1. 0 0 Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. El 0 Involve a land disturbance of undisturbed land areas (i.e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. El 0 Involve dredging activities Ina lake, river, pond, or stream?

4. 0 0 Increase the amount of thermal heat being discharged to the river or lake?

5. 0 0 Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

6. 0 0 Discharge any chemicals new or different from that previously discharged?

7. 0 0 Change the design or operation of the Intake or discharge structures?

8. 0 0 Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. El 0 Modify the design or operation of the plant that will change the path of an existing water discharge or that will result In a new water discharge?

10. 0 0 Modify existing stationary fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11. 0 0 Involve the Installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12. 0 0 Involve the installation or use of equipment that will result Inan air emission discharge?

13. 0 0 Involve the installation or modification of a stationary or mobile tank?

14. 0 0 Involve the use or storage of oils or chemicals that could be directly released Into the environment?

15. 0 0 Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

1 See NMM Procedure Ev-1 17, WAr Emissions Management Program,' for guidance In answering this question.

EN-S NUCLEAR QuAuTY REtATED LI-101 Revision 3

EnteW MANAGEMENT ADMINISTRATPVE L ATTACHMENT 9.1 50.59 REVIEW FORM Page 5 of IV. SECURITY PLAN SCREENING If any of the following questions Is answered "yes," a Security Plan review must be performed by the Security Department to determine actual impact to the Plan and the need for a change to the Plan.

A. Could the proposed, activity being evaluated:

Yes No

1. El 0 Add, delete, modify, or otherwise affect Security department responsibilities (e.g., Including fire brigade, fire watch, and confined space rescue operations)?

2. 0 0 Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. El 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. 0 0 Affect security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. 0 0 Modify or otherwise affect the Intrusion detection systems (e.g., E-fields, microwave, fiber optics)?

6. 0 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. 0 0 Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8. El 0 Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. 0 E0 Modify or otherwise affect the facility's security-related signage or land vehicle barriers, Including access roadways?

10. El 0 Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following questions If one of the questions was answered "yes.

B. Is the Security Plan actually Impacted by the E Yes proposed activity? E No C. Is a change to the Security Plan required? E Yes Change # (optional)

El No Name of Security Plan reviewer (print) I Signature I Date

EN -S NUCLEAR QUALrY REIATED LI-101 Revision 3

'Ent9.MANAGEMENT MANUAL ADMINISTRATVE ATTACHiMENT 9.1 50.59 REVIEW F PaeS 6 of 99 V. 50.59 EVALUATION EXEMPTION Enter this section only If a "yes" box was checked In Section II.A, above.

A. Check the applicable boxes below. if any of the boxes are checked, a 50.59 Evaluation Is not required. If none of the boxes are checked, perform a 50.59 Evaluation In accordance with Section Vi. Provide supporting documentation or references as appropriate.

0 The proposed activity meets all of the following criteria regarding design function per Section 5.6.1.1:

The proposed activity does not adversely affect the design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of performing or controlling a design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of evaluation that demonstrates Intended design function(s) of an SSC described in the FSAR will be accomplished.

O An approved, valid 50.59 Review(s) covering associated aspects of the proposed activity already exists per Section 5.6.1.2. Reference 50.59 Evaluation # - (if applicable) or attach documentation. Verify the previous 50.59 Review remains valid.

0 The NRC has approved the proposed activity or portions thereof per Section 5.6.1.3.

Reference:

0 The proposed activity is controlled by another regulation per Section 5.6.1.4.

B. Basis Provide a clear, concise basis for determining the proposed activity may be exempted such that a third-party reviewer can reach the same conclusions. See Section 5.6.6 of the E0I 10CFR50.59 Review Program Guidelines for guidance.

'Enter~g

_zE EN-S NUCLEAR MANAGEMENT MAUA QQUAUTY RELATED ADMIISTRATmE LI-101 j Revision 3 ATTACHMENT 9.1 J 50.59 REVIEW FORM Page 7I of I Vi. 50.59 EVALUATION A. Executive Summarv (Serves as input to NRC summary report. Limit to one page or less. Send an electronic copy to the site licensing department after OSRC approval, If available.)

Brief description of change, test, or experiment:

ER-ANO-2003-0787-000 is an operability evaluation for Shutdown Cooler room coolers 2VUC-IA, lB and IC. The ER issued DRN-03-1864 to Calc-94-E-0095-20. The DRN provides a minimum flow rate for the room coolers of 29 gpm per cooler. Any 2 of 3 coolers provide the cooling required to meet the DBA heat loads for Shutdown Cooling room 2013/2014 (Vault A). New note 18 to this effect is added to drawing M-2250, sheet 1, rev. 18. The drawing is 2FSAR Figure 9.2-22. The note states that design flow rates for the coolers are not changed by the operability evaluation. The revision to Calc-94-0095-20 calculates the flow required to assure a maximum room temperature of 143 degrees F. The maximum room temperature for equipment Operability is 143.6 degrees F.

The design flow listed on M-2250 Sheet 1 Rev 18 is 40 gpm, which would assure a maximum room temperature of 141 degrees F.

Reason for proposed Change:

The evaluation will be used in conjunction with standard as-left service water system flow testing at the end of 2R16.

50.59 Evaluation summary and conclusions The lower flow will not pose an Unreviewed Safety Question. The flow will be adequate to assure the Shutdown Cooler room temperature will not exceed the limits of the equipment in the room.

EN-S NUCLEAR QUALuTY RELATED LI-101 Revision 3 to ADMINISTRATIVE TC NI5MANUAL 5 E IATTACHM ENbT 9.1 50.59 iREVIEW FORM Page I 8 o B. License Amendment Determination Does the proposed Change being evaluated represent a change to a method of rl Yes evaluation ONLY? If "Yes," Questions 1 -7 are not applicable; answer only 0 No Question 8. If "No," answer all questions below.

Does the proposed Change:

I Result inmore than a minimal increase in the frequency of occurrence of an El Yes accident previously evaluated in the FSAR? O No BASIS:

To increase the frequency of occurrence of an accident any evaluated change would have to affect a Chapter 15 accident initiator. The Shutdown Cooler room coolers are not considered accident Initiators. The lower service water flow rate and the slightly increased maximum room temperature will not affect the ability of the safety related equipment in the room from performing Its function.

The AIRCOOL analysis performed In this ER shows that adequate room cooling is still available with 29 gpm of SW flow to 2VUC-1 A, 1B and 1C once service water temperature has reached its maximum temperature of 121 degrees F. The higher room temperature that can be reached due to the lower cooling water flow is the result of accident conditions and not an Initiator of an accident.

2. Result in more than a minimal increase in the likelihood of occurrence of a a Yes malfunction of a structure, system, or component important to safety previously 0 No evaluated in the FSAR?

BASIS:

Although the design flow remains 40 gpm on M-2250, the Intent of the design Is to provide sufficient flow to the room coolers such that sufficient heat will be rejected to the service water system to maintain room equipment Operability. The ER establishes that 29 gpm is adequate to maintain room temperature below the equipment Operability limit of 143.6 degrees F. The Increase in the maximum room temperature of 141 degrees F to 143 degrees F due to the lower flow will not result in the malfunction of the safety related equipment in the room. The two degree change is a minimal Increase and will still be below the equipment Operability limit.

3. Result in more than a minimal Increase in the consequences of an accident rl Yes previously evaluated In the FSAR? O No BASIS:

The change in service water flow and the resultant Increase in maximum room temperature will not exceed any Operability limit of the safety related equipment in the room. Any accident mitigators are therefore unaffected by the increased room temperature and therefore the dose (consequences) on any accident evaluated are unaffected by the reduced SW flow.

4. Result in more than a minimal increase in the consequences of a malfunction of a El Yes structure, system, or component important to safety previously evaluated in the 0 No FSAR?

BASIS:

Chapter 15 accident analysis assumes that a single failure to a safety train occurs during the response to an accident. The lower SW flow does not change how this failure might be manifested. Should a single failure occur, the results of a failure are not chan ged. No additional requirements are being imposed on the safety related equipment in the room. As a result, the consequences of this assumed single failure are not impacted by the lower SW water flow.

EN-S NUCLEAR QUAITY RELATED LI-101 Revision 3 MANAGEMENT ADMINISTRATIVE

-Entergy MANUALL I A1TACHMENT 9.1 50.59 REVIEW FORM Page 9 oIf 9

5. Create a possibility for an accident of a different type than any previously evaluated O Yes in the FSAR? No BASIS:

The lower service water flow does not result In the loss of any of the safety related equipment in the room In any evaluated accident scenario. Other accidents that are different than previously evaluated are not created since no new equipment is being added and no existing equipment Is being required to function any differently than it has in the -past.

6. Create a possibility for a malfunction of a structure, system, or component E Yes important to safety with a different result than any previously evaluated in the O No FSAR?

BASIS The ER evaluates the minimum service water flow at the highest expected service water temperature to maintain the safety related equipment In the room Operable. The design of the room coolers have not changed and they will still provide adequate heat rejection so that the safety related equipment in the room can perform their functions. The slight increase In SW discharge temperature is still bounded by the design temperature of the piping and is of no consequence. Failure of the safety related equipment in the room Is postulated In the SAR failure modes analysis; however, no different equipment malfunctions are postulated because of the evaluated change.

7. Result in a design basis limit for a fission product barrier as described in the FSAR E Yes being exceeded or altered? 3 No BASIS:

Fission product barriers are specifically Identified as fuel cladding, reactor coolant system boundary, and containment. Since the evaluation doesn't adversely impact reactor power, core design, RCS pressure boundary material or containment design pressure the design basis for a fission product barrier Is not impacted.

8. Result In a departure from a method of evaluation described In the FSAR used in 0 Yes establishing the design bases or in the safety analyses? s No BASIS:

A lower service water flow requirement does not constitute a method of evaluation as defined in the SAR. The evaluation used established methods for determining flow requirements.. All of the original evaluation methods and requirements are still met.

ANO 50.59 Evaluation Number 2003-031

?_ ___________ ________________ I I I*V _7 v.~ _

_ EN-S NUCLEAR QuAuTy RELATED LI-101 Revision 3 5E nter MANAGEMENT ADMINISTRATIVE MANUAL ATAHET9150.59 REVIEW FORM Page Io f I. OVERVIEW I SIGNATURES Facility: ANO -Unit 2 Document Reviewed: ER-ANO-2003-793-000 Change/Rev.: 0 System Designator(s)IDescrlption: LPSIUSDC Description of Proposed Chan-ze ER-ANO-2003-0793-000 evaluates the degraded condition of the Service Water System's ability to provide original design flow of 8 gpm to tie LPSI pump seal coolers, 2E-52A and 2E-52B. The 8 gpm value is located on existing SAR Figure 9.2-22. The ER evaluated the minimum flow Is actually 2.5 gpm. The ER evaluation utilized two Independent methods to arrive at the same 2.5 gpm value. The first method used the vendor's tech manual (TM 1075.0200) curves to determine necessary flow. The second method utilized Flowserve's computer program to determine necessary flow. Both methods considered heat transfer requirements and fouling effects. Based on the results of the ER the new flow requirement Is to be changed to 2.5 gpm.

The 8 gpm requirement was based on a memo from CE sent June 22, 1981. The memo did not provide calculations or justification for the required flow.

If the proposed activity, In Its entirety, Involves any one of the criteria below, check the appropriate box, provide a Justification/basis In the Description above, and forward to a Reviewer. No further 50.59 Review Is required. if none of the criteria Is applicable, continue with the 50.59 Review.

O The proposed activity is editorial/typographical as defined In Section 5.2.2.1.

o The proposed activity represents an "FSAR-only" change as allowed in Section 5.2.2.2-(Insert item # from Section 5.2.2.2).

If further 50.59 Review Is required, check the applicable review(s): (Only the sections Indicated must be Included In the Review.)

O SCREENING Sections 1, II, III, and IV required o 50.59 EVALUATION EXEMPTION Sections I, II, III, IV, and V required 1 50.59 EVALUATION (#6fi3-z23 Sections I, II, III, IV, and VI required Preparer: Keith Perkins/! /Entergy/Systems Engineering/ /0- ?-'d Name (print) / SIgnature / Compan / Department / Date Reviewer l/o1YSY Xapolrev / J 4/ge-Name (print) i Signature I Company / Department / Date - C - _-

OSRC 62 447

/e4/ee< die.rlp ( is /0k/°A 3 Chairman's Name (print) / Signature / Date (Required only for Programmatic Exclusion Screenivs (see Section 5.9) and 50.59 Evaluations.J List of Assisting/Contributing Personnel:

EN-S NUCLEAR QuAuTy RELATED LI- 101 Revision 3

" En MANAGEMENT ADMINISTRATNE nte MANUAL I I ATTACHMENT 9.1 50.59 REVIEW FORM Page 1 2 Name: Scope of Assistance:

Roger Owings LBD Search II. SCREENING A. Licensing Basis Document Review

1. Does the proposed activity Impact the facility or a procedure as described In any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # andlor SECTIONS IMPACTED Operating Ucense 0 21 TSOE NRC Orders 3 El It "YES", obtain NRC approval prior to Implementing the change by Initiating an LBD change In accordance with NMM LI-113 (Reference 2.2.13). (See Section 5.1.13 for exceptions.)

LEDs controlled under 50.59 YES NO CHANGE # and/or SECTIONS IMPACTED FSAR 0 0 ANO-2 SAR Figure 9.2-22 TS Bases 00 _

Technical Requirements Manual 0 -

Core Operating Umits Report 0 0 NRC Safety Evaluation Reports' 0 0 if "YES", perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI A Initiate an LED change in accordance with NMM Li-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # (if applicable) and/or SECTIONS IMPACTED 2

Quality Assurance Program Manual 0 0 2

Emergency Plan 0 0 3

Fire Protection Program 0 0 (Includes the Fire Hazards Analysis)

Offalte Dose Calculation Manual 3 0 0 If "YES', evaluate any changes In accordance with the appropriate regulation A Initiate an LED change In accordance with NMM LI-113 (Reference 2.2.13). l L Z 7: w

2. Does the proposed activity Involve a test or experiment not described In the 03Yes FSAR? No If yes," perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI.

3. Does the proposed activity potentially impact equipment, procedures, or o Yes facilities utilized for storing spent fuel at an Independent Spent Fuel Storage 1 No Installation? O NIA 1 If 'YES,' see Section 5.1.4. No LBD change is required.

2 If 'YES,' notify the responsible department and ensure a 50.54 Evaluation Is performed. Attach the 50.54 Evaluation.

3 If 'YES,' evaluate the change In accordance with the requirements of the facility's Operating License Condition.

EN-S NUCLEAR QuALrrY RELATED LI-101 Revision 3

' MANAGEMENT ADMINISTRZATIVE OEnterAgylT~nc T, L~iLLII~y MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page of (Check "N/A" if dry fuel storage is not applicable to the facility.)

If "yes," perform a 72.48 Review In accordance with NMM Procedure L-112.

(See Sections 1.5 and 5.3.1.5 of the EOi 10CFR50.59 Review Program Guidelines.)

B. Basis Provide a clear, concise basis for the answers given In the applicable sections above. Explain why the proposed activity does or does not impact the Operating Ucense/Technical Specifications and/or the FSAR and why the proposed activity does or does not involve a new test or experiment not previously described in the FSAR. Adequate basis musit be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simply stating that the change does not affect TS or the FSAR is not an acceptable basis. See EOI 50.59 Guidelines Section 5.6.6 for guidance.)

This 50.59 evaluation Is for the ER documentation to change the service water flow requirements of the LPSI seal cooler from 8 gpm to 2.5 gpm.

Operating License Documents: Neither the Operating License nor Tech Specs describe the LPSI seal cooler to the detail of service water heat exchanger flowrate through the LPSI seal coolers.

LBDs Controlled Under 50.59: The SAR documents were reviewed and information was found such that the proposed change will cause a SAR statement to not be true. Figure 9.2-22 will show the required flow to be 2.5 gpm which will replace the 8 gpm value listed on the figure. The SAR does not provide the level of detail documenting the bases for the 8 gpm value.

LBDs Controlled Under Other Regulations: This change does not create a new configuration, new mode of operation or add equipment that creates a new finction. The new configuration is physically the same only the flow rate requirements are changing. The change does not alter the design function of the LPSI seal cooler system or its ability to meet designed requirements and does not involve or constitute a test or experiment Nor does the change affect the Independent Fuel Storage Facility since the change only affects the documented performance requirement of the LPSI pump seal cooler. There are no other LBDs or regulations that list details specific enough to require change.

C. References Discuss the methodology for performing the LBD search. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.3.6.4 of Li-101. NOTE: Ensure that electronic and manual searches are performed using controlled copies of the documents. If yoou have any questions, contact your site Licensing department.

LBDs/Documents reviewed via keyword search: Keywords:

LRS, 50.59 - U2 LPSI w10 seal, LPSI wO1 cooler, LPSI w10 flow, LPSI w1 0 minimum, minimum w/10 seal, minimum w10 LPSI, service w/10 minimum, service w/1 5 service, Service water flow rates LBDs/Documents reviewed manually ANO-2 SAR Chapters 9, Figure 9.2-22

_ EN-S NUCLEAR QuAL.Ty RELATED LI-101 Revision 3 Ends~Entorai IMANAGEMENT ADMWISTRATV AMNSRTV

-I---

MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 4 of 10 D. Is the validity of this Review dependent on any other a Yes change? (See Section 5.3.4 of the EOI 10CFR50.59 Program El No Review Guidelines)

If "Yes," list the required changes.

_ EN-S NUCLEAR QuALm RELATED L-101 Revision 3

- EnteW MANAGEMENT ADMINISTRATIVE MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 5 of 111. ENVIRONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed In accordance with NMM Procedure EV-115, "Environmental Evaluations," and attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated:

Yes No

1. 0 0 Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. 0 0 Involve a land disturbance of undisturbed land areas (i.e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. 0 0 Involve dredging activities Ina lake, river, pond, or stream?

4. 0 0 Increase the amount of thermal heat being discharged to the river or lake?

5. 0 0 Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

6. 0 0 Discharge any chemicals new or different from that previously discharged?

7. 0 0 Change the design or operation of the intake or discharge structures?

8. 0 0 Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. 0 0 Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10 E 0 Modify existing stationary fuel burning equipment (I.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11 0 0 Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12 El 0 Involve the Installation or use of equipment that will result in an air emission discharge?

13 0 0 Involve the installation or modification of a stationary or mobile tank?

14 0 0 Involve the use or storage of oils or chemicals that could be directly released into the environment?

1 See NMM Procedure EV-1 17, WAr Emissions Management Program,' for guidance in answering this question.

_ EN-S NUCLEAR QuALT RELATED L-101 Revision 3 MANAGEMENT M ADmINISTRAmTE Entey a MANUAL .

ATTACHMENT 9.1 50.59 REVIEW FORM Page 6 of 1 15 0 CD Involve burial or placement of any solid wastes In the site area that may affect runoff, surface water, or groundwater?

IV. SECURITY PLAN SCREENING If any of the following questions Is answered "yes," a Security Plan review must be performed by the Security Department to determine actual Impact to the Plan and the need for a change to the Plan.

A. Could the proposed activity being evaluated:

Yes No

1. 0 0 Add, delete, modify, or otherwise affect Security department responsibilities (e.g., including fire brigade, fire watch, and confined space rescue operations)?

2. 0 0 Result In a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. 0 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. 0 0 Affect security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. 0 0 Modify or otherwise affect the intrusion detection systems (e.g., E-fields, microwave, fiber optics)?

6. 0 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. 0 0 Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8. 0 0 Modify or otherwise affect primary or secondary power supplies to access control equipment, Intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. 0 0 Modify or otherwise affect the facility's security-related signage or land vehicle barriers, Including access roadways?

10. 0 0 Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following questions If one of the questions was answered "yes B. Is the Security Plan actually Impacted by the 0 Yes proposed activity? 0 No C. Is a change to the Security Plan required? 0 Yes Change # (optional) 0 No Name of Security Plan reviewer (print) / Signature I Date

__ EN-S NUCLEAR QUAuTY RELATED LI-101 Revision 3 E MANAGEM ENT ADMINISTRATIVE MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 7 V. 50.59 EVALUATION EXEMPTION Enter this section only If a "yes" box was checked In Section II.A, above.

A. Check the applicable boxes below. If any of the boxes are checked, a 50.59 Evaluation Is not required. If none of the boxes are checked, perform a 50.59 Evaluation In accordance with Section VI. Provide supporting documentation or references as appropriate.

0 The proposed activity meets all of the following criteria regarding design function per Section 5.6.1 .1:

The proposed activity does not adversely affect the design function of an SSC as described In the FSAR; AND The proposed activity does not adversely affect a method of performing or controlling a design function of an SSC as described in the FSAR; AMP The proposed activity does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC described in the FSAR will be accomplished.

O An approved, valid 50.59 Review(s) covering associated aspects of the proposed activity already exists per Section 5.6.1.2. Reference 50.59 Evaluation # - (if applicable) or attach documentation. Verify the previous 50.59 Review remains valid.

o The NRC has approved the proposed activity or portions thereof per Section 5.6.1.3.

Reference:

O The proposed activity is controlled by another regulation per Section 5.6.1 A.

B. Basis Provide a clear, concise basis for determining the proposed activity may be exempted such that a third-party reviewer can reach the same conclusions. See Section 5.6.6 of the EOI 10CFR50.59 Review Program Guidelines for guidance.

A__ EN-S NUCLEAR QUAUTY RELATED LI-101 Revision 3 MA M T ADMINISTRATIVE

~Entergy MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page of 10 VI. 50.59 EVALUATION A. Executive Summary (Serves as input to NRC summary report. Limit to one page or less. Send an electronic copy to the site licensing department after OSRC approval, If available.)

Brief description of change, test, or experiment:

ER-ANO-2003-0793-000 evaluates the degraded condition of the Service Water System's ability to provide original design flow of 8 gpm to the LPSI pump seal coolers, 2E-52A and 2E-52B. The 8 gpm value is located on existing SAR Figure 9.2-22. The ER evaluated the minimum flow for heat removal and operational cleanliness is actually 2.5 gpm. The ER evaluation utilized two independent methods to arrive at the same 2.5 gpm value. The first method used the vendor's tech manual (TM 1075.0200) curves to determine necessary flow. The second method utilized Flowserve's computer program to determine necessary flow. Both methods considered heat transfer requirements and fouling effects. Based on the results of the ER the new flow requirement is to be changed to 2.5 gpm.

The 8 gpm requirement was based on a memo from CE sent June 22, 1981. The memo did not provide calculations or justification for the required flow.

Reason for proposed Change:

ER-ANO-2003-0793-000 evaluates the degraded condition of the Service Water System's ability to provide original, design flow of 8 gpm to the LPSI pump seal coolers, 2E-52A and 2E-52B. The reason for the change is to identify the actual minimum required flow of these heat exchangers.

50.59 Evaluation summary and conclusions The evaluation concluded that 2.5 gpm service water flow rate Isacceptable for maintaining the LPSI seal coolers operable.

B. License Amendment Determination Does the proposed Change being evaluated represent a change to a method of 0 Yes evaluation ONLY? If "Yes," Questions 1 - 7 are not applicable; answer only 0 No Question 8. If "No," answer all questions below.

Does the proposed Change:

1. Result Inmore than a minimal increase in the frequency of occurrence of an C Yes accident previously evaluated Inthe FSAR? ONo BASIS:

Neither the operability limits of LPSI pump seal cooler nor the service water flow rate through the cooler nor service water total system flow rates are Inputs to accident frequency calculations evaluated In the SAR. Since these parameters are not inputs to those calculations they do not Increase the frequency of evaluated accidents. To increase the frequency of occurrence of an accident any evaluated change would have to affect a Chapter 15 accident initiator. The coolers are not considered accident Initiators. The lower service water flow rate will not affect the ability of the pump in performing its function.

2. Result In more than a minimal increase In the likelihood of occurrence of a 0 Yes malfunction of a structure, system, or component Important to safety previously 0 No evaluated in the FSAR?

EN-S NUCLEAR QuALrry RELATED L-l101 Revision 3 A IMANAGEM.ADmINISTRATIVE

~Entergy MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM IPage 19o 10 BASIS:

The Engineering evaluation demonstrated that the LPSI pump seal cooler flow rate of 2.5 gpm is sufficient to maintain the cooler operable and therefore the pump operable. Since operability of these components is maintained the likelihood of equipment malfunction is not increased.

There was no basis documented for the original 8 gpm flow listed on SAR figure 9.2-22.

3. Result Inmore than a minimal increase In the consequences of an accident Yes previously evaluated in the FSAR? 0i No BASIS:

The LPSI seal cooler and pump remain operable for all operational modes of the LPSI system with reduced cooler flow. The change in flow does not create a new configuration for the release of radioactive material. The radiological and accident consequences of a failure of these components have been evaluated and are not changed by adjusting cooler flow rate in this fashion. Since no new release configuration or failure mechanism iscreated that exceeded the release rates assumed Inthe SAR the consequences of an accident are not changed

4. Result in more than a minimal Increase In the consequences of a malfunction of a E Yes structure, system, or component important to safety previously evaluated in the ED No FSAR?

BASIS:

The change in flow does not create a new configuration for the release of radioactive material and does not impact opposite train components. The trains of LPSI and SDC remain Independent. The frequency of malfunction on any component is not changed because the flow rate isevaluated as acceptable. The consequences for the failure of a component or single train are not changed. Since the frequency and consequences of each train are not changed the consequences have not changed and are still bounded by the analyses.

Chapter 15 accident analysis assumes that a single failure to a safety train occurs during the response to an accident. The lower SW flow does not change how this failure might be manifested. Should a single failure occur, the results of afailure are not changed. No additional requirements are being imposed on the safety related pump. As a result, the consequences of this assumed single failure are not impacted by the lower SW water flow.

5. Create a possibility for an accident of a different type than any previously evaluated Q Yes Inthe FSAR? 3 No BASIS:

The change in flow rate through the cooler can not create a new type of accident because the cooler will still perform its intended function. Since its intended function is maintained the cooler flow rate does not create a condition that challenges the LPSI pump or service water in any new way. Since no new challenges or configurations are created there are no new accident possibilities. The lower service water flow does not result Inthe loss of any of the safety related pump in any evaluated accident scenario. Other accidents that are different than previously evaluated are not created since no new equipment is being added and no existing equipment is being required to function any differently than it has in the past.

6. Create a possibility for a malfunction of a structure, system, or component a Yes important to safety with a different result than any previously evaluated in the ED No FSAR?

_ EN-S NUCLEAR QUALTY REILATED LI-101 Revision 3.

MANAGEMENT ADMINISTRATIVE Entergy MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 10 of 10 BASIS The change In flow rate through the cooler can not create a new type of accident because the cooler will still perform its intended function. Since its intended function is maintained the cooler flow rate does not create a condition that challenges the LPSI pump or service water In any new way. Since no new challenges or configurations are created there are no new accident possibilities. The ER evaluates the minimum service water flow at the highest expected service water temperature to maintain the safety related pump Operable. The design coolers have not changed and they will still provide adequate heat rejection so that the safety related pump can perform its function. Failure of the pump Is postulated in the SAR failure modes analysis; however, no different equipment malfunctions are postulated because of the evaluated change.

7. Result in a design basis limit for a fission product barrier as described In the FSAR E Yes being exceeded or altered? ED No BASIS:

Fission product barriers are specifically Identified as fuel cladding, reactor coolant system boundary, and containment. Since the evaluation doesn't adversely Impact reactor power, core design, RCS pressure boundary material or containment design pressure the design basis for a fission product barrier Is not impacted. The seal cooler will be operable with the lower flows and therefore the LPSI pump seal will remain operable. Since the seal remains operable no new leakage path is created and no limit is exceeded.

8. Result in a departure from a method of evaluation described in the FSAR used in 0 Yes establishing the design bases or In the safety analyses? E No BASIS:

A lower service water flow requirement does not constitute a method of evaluation as defined in the SAR. The evaluation used established methods for determining flow requirements. There is no documented analysis for the original value of 8 gpm. The new value of 2.5 gpm is based on two different and acceptable methods.

ANO 50.59 Evaluation Number 2004-014

EN-S NUCLEAR QuAuTY RELATED LI-101 Revision 3 4 MANAGEMENT ADMINISTRATIVE AAENT915EW MANUAL ATTACHMENT 9.1 1 50.59 REVIEW FORM IPage II I. OVERVIEW I SIGNATURES Facility: ANO -Unit 2 Document Reviewed: ER-ANO-2003-0793-001 ChangelRev.: 0 System Designator(s)IDescription: SOC/Shutdown Cooling Description of Proposed Channe ER-ANO-2003-0793-000 and -001 evaluates the degraded condition of the U2 Service Water system's ability to provide the original design flow to the SDC pump seal coolers, 2E-52 A&B. The existing design value shown Inthe U2 SAR and on M-2250 Sheet 1 is 8 GPM. The minimum acceptable-flow for operability and functionality of the coolers is 2.5 GPM of SW. The ER evaluation used both the Flowserve calculation summary sheet and the method described in the 2E-52 A&B Technical Manual for concluding that 2.5 GPM is the minimal acceptable flow for ANO2's application. The design flow will remain at 8 GPM and the minimum flow for functionality Is 2.5 GPM.

This 10CFR50.59 review supercedes the 10CFR50.59 Evaluation Exemption in ER-ANO-2003-0792-000 and the 10CFR50.59 Review recorded InOSRC minutes as FFN 03-031.

If the proposed activity, in Its entirety, Involves any one of the criteria below, check the appropriate box, provide a Justification/basis In the Description above, and forward to a Reviewer. No further 50.59 Review Is required. If none of the criteria Is applicable, continue with the 50.59 Review.

El The proposed activity is editorial/typographical as defined in Section 5.2.2.1.

El The proposed activity represents an uFSAR-only" change as allowed InSection 5.2.2.2 (insert Item # from Section 5.2.2.2).

If further 50.59 Review Is required, check the applicable review(s): (Only the sections Indicated must be Included Inthe Review.)

El SCREENING Sections I, I, IlIl, and IV required 0 50.59 EVALUATION EXEMPTION Sections I, II, Ill, IV,and V required 0 50.59 EVALUATION (#:w?, 1I4 dSI(S1o Sections I, II, III, IV,and VI required

_ .I I - . - - ,

Preparer: Tim Woodson/ -I K* t Jwwl /EOI/DE/

Name (print) / Signday/e / Company / Department / Date Reviewer: Bill Kistler/ Yp'yz', 5P/ Iza Name (print) / Signature / Company / Department / Date

/EOI/DE/ - X Y OSRC Chuirman's Name (print) Sicnaeure E Date (

[Retquired only for Programmatic Exclusion Screenings (see Section 5.9) and 50.59 Evaluations.]

List of Assisting/Contributing Personnel:

Name: Scope of Assistance:

_ EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3

- -n-ew L.J MANAGEMENT MANUAL ADMINISTRATIVE 6

ATTACHMENT 9.1 50.59 REVIEW FORM Page 2 of 9 II. SCREENING A. Licensing Basis Document Review

1. Does the proposed activity Impact the facility or a procedure as described in any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # and/or SECTIONS IMPACTED Operating License 0 _

TS 1_

NRC Orders o 0__

If "YES", obtain NRC approval prior to Implementing the change by Initiating an LBD change In accordance with NMI! L-113 (Reference 2.2.13). (See Section 6.1.13 for exceptions.)

LBDs controlled under 50.59 YES NO CHANGE # andlor SECTIONS IMPACTED FSAR 0 0 DRN 04-167 (M-2250 Sheet 1)to U2 SAR Figure 9.2-22 TS Bases 0 0 Technical Requirements Manual 0 0 Core Operating Limits Report 0 0 NRC Safety Evaluation Reports' 0 0 If "YES, perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI AND Initiate an LBD change In accordance with NMM LI-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # (if applicable) and/or SECTIONS IMPACTED Quality Assurance Program Manual 0 0 2

Emergency Plan 0 0 ___ _

Fire Protection Program 30 0 (includes the Fire Hazards Analysis)

Offsite Dose Calculation Manual3 131 If "YESn, evaluate any changes In accordance with the appropriate regulation AND InItiate an LBD change In accordance with NMM LU-113 (Reference 2.2.13).

2. Does the proposed activity Involve a test or experiment not described In the El Yes FSAR? O No if "yes," perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI.

3. Does the proposed activity potentially Impact equipment, procedures, or facilities - Yes utilized for storing spent fuel at an Independent Spent Fuel Storage Installation? 0 No (Check "NIA" If dry fuel storage Is not applicable to the facility.) Cl NIA If "yes," perform a 72.48 Review In accordance with NMM Procedure LI-112.

(See Sections 1.5 and 5.3.1.5 of the EOI I OCFR50.59 Review Program Guidelines.)

1 If 'YES," see Section 5.1.4. No LBD change is required.

2 If YES," notify the responsible department and ensure a 50.54 Evaluation Is performed. Attach the 50.54 Evaluation.

3 If 'YES," evaluate the change in accordance with the requirements of the ftcility's Operating License Condition.

EN-S NUCLEAR QUALuy RELATED L-101 RevIsion 3

- Enferm~ W j MANAGEMENT MANUAL AoMINtSTRATvE -

ATTACHMENT 9.1 50.59 REVIEW FORM Page f9 B. Basis Provide a clear, concise basis for the answers given in the applicable sections above. Explain why the proposed activity does or does not Impact the Operating License/Technical Specifications and/or the FSAR and why the proposed activity does or does not involve a new test or experiment not previously described In the FSAR. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simply stating that the change does not affect TS or the FSAR is not an acceptable basis. See EOI 50.59 Guidelines Section 5.6.6 for guidance.)

The design value of 8 GPM for the 2E-52 A&B coolers is not being changed. The ER evaluation concludes that the minimum acceptable service water flow through the 2E52 A&B coolers is 2.5 GPM. With 2.5 GPM flow, there is no loss of any 2E-52 A&B heat transfer functions and no degradation or loss of function to the mechanical seals in the 2P-60 A&B LPSI pumps or the LPSI/SDC systems. A note is being added to SAR Figure 9.2-22 to specify the minimum acceptable flow is 2.5 GPM. The 2E-52 A&B heat exchangers are not required to reject heat to satisfy any LPSI support functions, they are required to reject heat during some periods of Shutdown Cooling to optimize the LPSI pump mechanical seal life.

The Operating License does not specify flow rates through heat exchangers and adding a note to SAR Figure 9.2-22 for minimum flow through the 2E-52 A&B heat exchangers Is below the level of detail in the Operating License. The ANO2 LBDs specify a design flow of 8 GPM in SAR Figure 9.2-

22. The design flow value is not being changed. The minimum flow for 2E-52 A&B operability Is 2.5 GPM and that is being noted on the SAR figure. No design values or functions are being altered by this ER. Noting the minimal acceptable service water flow value for operability through the 2E-52 A&B heat exchangers does not constitute a test or experiment. The U2 Service Water system'is tested during refueling outages to ensure that design values are met or if not corrective actions are taken to restore flows to Service Water components. This ER does not affect any ISFI equipment or processes.

C. References Discuss the methodology for performing the LBD search. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.3.6.4 of LI-101. NOTE: Ensure that electronic and manual searches are performed using controlled copies of the documents. If you have any questions, contact your site Licensing department LBDs/Documents reviewed via keyword search: Keywords:

All, 50.59-Unit 2 LPSI w/10 seal, LPSI w/10 cooler, LPSI w/10 flow, LPSI w/10 minimum, minimum w/10 seal, service w/10 minimum.

LBDs/Documents reviewed manually:

ANO2 SAR Chapter 9, Figure 9.2-22 D. Is the validity of this Review dependent on any other n Yes change? (See Section 5.3.4 of the EOI 10CFR50.59 Program 1 No Review Guidelines)

If "Yes," list the required changes.

_ EN-S NUCLEAR QuAuTY RELATED L1-401 Revision 3

'-- ~ MANAGEMENT ADMINISTRATIVE LJLL 1 MANUAL ATTACHMENT 9.1 50.59 REVIEW FORM Page 4 of Ill. ENVIRONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review must be performed In accordance with NMM Procedure EV-115, "Environmental Evaluations," and-attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated:

Yes No

1. 0 0 Involve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,

grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

2. 0 0 Involve a land disturbance of undisturbed land areas (i.e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

3. 0l Involve dredging activities in a lake, river, pond, or stream?

4. 0 0 Increase the amount of thermal heat being discharged to the river or lake?

5. 0 0 Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

6. 0l 0 Discharge any chemicals new or different from that previously discharged?

7. El Change the design or operation of the intake or discharge structures?

8. 0 0 Modify the design or operation of the cooling tower that will change water or air flow characteristics?

9. El 0 Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10. El 0 Modify existing stationary fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

11. E 0 Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

12. E 0 Involve the installation or use of equipment that will result in an air emission discharge?

13. El 0 Involve the installation or modification of a stationary or mobile tank?

14. 0 0 Involve the use or storage of oils or chemicals that could be directly released into the environment?

15. 0 0 Involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

1 See NMM Procedure EV-1 17, 'Air Emissions Management Program,' for guidance Inanswering this question.

EN-S NUCLEAR QuALrry RELATED LI-101 Revision 3 MEter A2TACHMN 1 MANAGEMENT ADMINISTRTIVE 5MANUAL IATTACHMENT 9.1 1 50.59 REVIEW FORM IPage I6o IV. SECURITY PLAN SCREENING If any of the following questions Is answered "yes," a Security Plan review must be performed by the Security Department to determine actual Impact to the Plan and the need for a change to the Plan.

A. Could the proposed activity being evaluated:

Yes No

1. 0 0 Add, delete, modify, or otherwise affect Security department responsibilities (e.g., Including fire brigade, fire watch, and confined space rescue operations)?

2. 0 0 Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. 0 0 Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4. 0 0 Affect security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

5. E 0 Modify or otherwise affect the intrusion detection systems (e.g., E-fields, microwave, fiber optics)?

6. 0 0 Modify or otherwise affect the operation or field of view of the security cameras?

7. 0 0 Modify or otherwise affect (block, move, or alter) installed access control equipment, intrusion detection equipment, or other security equipment?

8. 0 0 Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9. 0 0 Modify or otherwise affect the facility's security-related signage or land vehicle barriers, including access roadways?

10. El 0 Modify or otherwise affect the facility's telephone or security radio systems?

The Security Department answers the following questions if one of the questions was answered "yes".

B. Is the Security Plan actually Impacted by the E Yes proposed activity? O No C. Is a change to the Security Plan required? E Yes Change # (optional)

El No Name of Security Plan reviewer (print) I Signature I Date

EN-S NUCLEAR QUALffy RELATED L1l401 Revision 3 ZiP:-ENT ADMINISTRATIVE L.JL ' MANUAL AE 55. R P ATTACHMENT 9.1 5 0.69 REVIEW FORM IPage 16 of9 V. 50.59 EVALUATION EXEMPTION Enter this section only If a "yes" box was checked In Section II.A, above.

A. Check the applicable boxes below. If any of the boxes are checked, a 50.59 Evaluation Is not required. If none of the boxes are checked, perform a 50.59 Evaluation In accordance with Section VI. Provide supporting documentation or references as appropriate.

E The proposed activity meets all of the following criteria regarding design function per Section 5.6.1.1:

The proposed activity does not adversely affect the design function of an SSC as described in the FSAR; AND The proposed activity does not adversely affect a method of performing or controlling a design function of an SSC as described In the FSAR; AND The proposed activity does not adversely affect a method of evaluation that demonstrates intended design function(s) of an SSC described in the FSAR will be accomplished.

El An approved, valid 50.59 Review(s) covering associated aspects of the proposed activity already exists per Section 5.6.1.2. Reference 50.59 Evaluation # - (if applicable) or attach documentation. Verify the previous 50.59 Review remains valid.

E The NRC has approved the proposed activity or portions thereof per Section 5.6.1.3.

Reference:

E The proposed activity is controlled by another regulation per Section 5.6.1.4.

B. Basis Provide a clear, concise basis for determining the proposed activity may be exempted such that a third-party reviewer can reach the same conclusions. See Section 5.6.6 of the EQI I OCFR50.59 Review Program Guidelines for guidance.

An evaluation is included.

EN-S NUCLEAR QuALffy RELATED LI-101 Revision 3 n MANAGEMENT MANUAL ADMINISTRATIVE ATTACHMENT 9.1 50.69 REVIEW FORM Page 7 VI. 50.69 EVALUATION A. Executive Summary (Serves as input to NRC summary report. Umit to one page or less. Send an electronic copy to the site licensing department after OSRC approval, if available.)

Brief description of change, test, or experiment:

Reason for proposed Change:

50.59 Evaluation summary and conclusions Per the note below step 5.7.1 in L1- 01 Revision 3, ANO is not required to fill out section VI.A in accordance with step 5.7.1.1.

EN-S NUCLEAR QUAuTY RELATED L-101 Revision 3

- En y MANAGEMENTVE MANUAL ATTACHMENT 9.1 1 50.59 REVIEW FORM IPage I8 B. License Amendment Determination Does the proposed Change being evaluated represent a change to a method of E Yes evaluation ONLY? If "Yes," Questions 1 - 7 are not applicable; answer only El No Question 8. If "No," answer all questions below.

Does the proposed Change:

I Result in more than a minimal increase in the frequency of occurrence of an El Yes accident previously evaluated in the FSAR? 0 No BASIS:

Chapter 15 of the U2 SAR evaluates "Loss of Service Water System" and states that no single failure of an active or passive component in the Service Water system can lead to a LOCA.

The 2E-52 A&B coolers are passive components and this ER does not evaluate the loss of any heat transfer functions at reduced service water flow through the heat exchangers. The 2E-52 A&B heat exchangers are not accident initiators and there is no change in the frequency of occurrence described in any Chapter 15 design bases accident.

2. Result in more than a minimal increase in the likelihood of occurrence of a El Yes malfunction of a structure, system, or component important to safety previously 0 No evaluated in the FSAR?

BASIS:

The 2E-52 A&B heat exchangers are not required to provide heat transfer to support LPSI functions. The heat exchangers are required to reject heat to the service water to support Shutdown Cooling Functions with RCS temperatures between16 0 0F and 300 0F to optimize the mechanical seal life of the 2P-60 LPSI pumps. Since the 2E-52 A&B heat exchangers can satisfy all their design functions with 2.5 GPM of Service Water flow the increase in any malfunction is considered minimal.

3. Result in more than a minimal increase in the consequences of an accident E Yes previously evaluated in the FSAR? ONo BASIS:

The 2P-60 A&B LPSI pump mechanical seals are required to provide minimal leakage during an accident to minimize an offsite dose release. The LPSI system is Identified as a system that is connected to containment after an accident and is relied upon to prevent the migration of radioactive materials from the containment building to the auxiliary building. The 2P-60 LPSI pumps are secured when the ECCS systems switch to the containment sump as a suction source. Since the 2P-60 LPSI seals are not required to be cooled after a RAS signal is initiated and the 2E-52 A&B heat exchangers are capable of removing any heat loads with 2.5 GPM of water, there is no increase in the likelihood that the LPSI seals will leak more than the values permitted in the U2 SAR (Total ECCS leakage is 2060 cc/hr).

4. Result in more than a minimal increase In the consequences of a malfunction of a E Yes structure, system, or component important to safety previously evaluated in the 0 No FSAR?

_ EN-S NUCLEAR QUAuTy RELATED LI-101 Revision 3

-f MANAGEEN ADMINISTRATIVE MANUAL ATTACHMENT 9.1 1 50.59 REVIEW FORM IPage I BASIS:

The 2E-52 A&B heat exchangers are capable of performing all their design functions with 2.5 GPM of Service Water. The components will be operated within their capabilities without undue loading or operated in a different manner than before. Chapter 15 of the SAR and Table 9.2-5 both state that a single failure of a component will not result in a LOCA and there is no increase in accident consequences per question 3. The loss of Service Water Accident described in section 15.1.20 is still bounding. Since the heat exchangers and the mechanical seals in the 2P-60 LPSI pumps will not experience any loss of functionality, there is no more than a minimal increase in the consequences of a malfunction previously evaluated in the SAR.

5. Create a possibility for an accident of a different type than any previously evaluated 0 Yes in the FSAR? - No BASIS:

The ER concludes that the 2E-52 A&B will satisfy all of its design functions with 2.5 GPM of service water flowing through each heat exchanger. Chapter 15 of the U2 SAR already evaluates the loss of the Service Water System and discusses various failure scenarios In Table 9.2-5. Since the heat exchangers will satisfy all their design functions, no new accidents are created and the Chapter 15 accidents are still bounding.

6. Create a possibility for a malfunction of a structure, system, or component 0 Yes important to safety with a different result than any previously evaluated Inthe 0 No FSAR?

BASIS The 2E-52 A&B heat exchangers are not considered by the SAR to be accident initiators. This ER concludes that the heat exchangers will satisfy their design functions with a minimum of 2.5 GPM even though that is below the 8 GPM design value. Chapter 15 evaluates the loss of the Service Water System and this change does not affect that analysis. The heat exchangers are no more likely to fail and cause a different accident than loss of Service Water by allowing measured, actual flows to drop below design flows.

7. Result in a design basis limit for a fission product barrier as described in the FSAR 0 Yes being exceeded or altered? 3 No BASIS:

This ER concludes that the 2E-52 A&B heat exchangers will satisfy all their design functions with 2.5 GPM of Service Water flow. As such, they will adequately support LPSI and SDC system functions and will not cause any limits associated with the fission product barriers to be affected.

8. Result in a departure from a method of evaluation described in the FSAR used in O Yes establishing the design bases or in the safety analyses? 0 No BASIS:

The design value of 8 GPM was selected during ANO2's original design and is not formally documented. The ER evaluates the lowered flow using two different methods that independently reach the same results. The lower value is the minimum Service Water flow required for the 2E-52 A&B heat exchangers to satisfy their heat transfer functions.. The SAR lists the 8 GPM value, but does not implicitly or explicitly explain the methodology for arriving at that value. Therefore the evaluation by this ER is acceptable and does not cause information in the SAR to be untrue.

ANO 50.59 Evaluation Number 2004-015

_ EN-S NUCLEAR QUAlr1 RELATED LI-101 Revision 3 w~ntMANAGEMENT ADMINTRAWE 5 J MANUAL INFORMATION USE ATTACHMENT 9.1 .50.59 REVIEW FORM Page 1 of 12

1. OVERVIEW / SIGNATURES Facility: ANO- Unit 2 Document Reviewed: ANO-2 Technical Reauirements Manual (TRM) Change/Rev.: 17 ANO-2 SAR la ANO-2 Technical SDecification Bases System Designator(syDescription: Pressurizer Heat Ug and Cool Down LImits Description of Proposed Chance The NRC approved the relocation of the pressurizer heat up and cool down limits (and associated Bases) from the TSs to the TRM InAmendment 253 on May 4, 2004. Therefore, this change incorporates the previous TS 3.4.9.2 Into a new TRM 3.4.9.2. The relocation resulted In minor wording and editorial changes In order to accommodate TRM formatting and usage rules (including minor expansion of the Bases) that meet the screening criteria of LI-1 01 and are, therefore, not discussed further in this evaluation. However, two other changes were made to these requirements during their relocation to the TRM. These include (1) revision of the pressurizer cool down limits Inaccordance with condition report CR-ANO-2-2003-1082, corrective action 007 which reduces the allowable cool down rate for given RCS temperatures (affects the TRM and the SAR), and (2) revision of the shutdown portion of the previous TS action consistent with industry TRM guidelines. Item (1) above is a more restrictive change and meets the exemption criteria of U-1 01. Item (2) above Is a less restrictive change and Istherefore evaluated in Section VI. Because the changes to the TRM meet all three criteria, all three boxes are checked below.

If the proposed activity, In Its entirety, Involves any one of the criteria below, check the appropriate box, provide a justification/basis In the Description above, and forward to a Reviewer. No further 50.59 Review Is required. If none of the criteria Is applicable, continue with the 50.59 Review.

o The proposed activity Is editorlalftypographical as defined InSection 5.2.2.1.

O The proposed activity represents an OFSAR-onlyV change as allowed In Section 5.2.2.2-(Insert Item # from Section 5.2.2.2).

If further 50.59 Review Is required, check the applicable review(s): (Only the sections Indicated must be Included In the Review.)

SCREENING Sectionsl, Ii, IiI, and IV required C 50.59 EVALUATION EXEMPTION Sections I, U,Ill, IV, and V required 0_50.59 EVALUATION (#:oyOLg III, IV, and VI required Sections 1,1l, I

Preparer: David Bice / _ ) I EOI I Licensing / 05-05-2004 Name (print) / Signature / Company / Department / Date Reviewer: Dana Millar / a /I EQI / Ucensing /05-05-2004 Name (print) / Signature / Company / Department / Date OSRC 0'tImoa Chfrman's Signature DNW asimloq- / J.NR.MtIeA,

[Required only for Programmatic Exclusion Screenings (see Section 5.9) and 50.59 Evaluations.]

EN-S NUCLEAR QuALTY RELATED L1-401 Revision 3 Ente~y E~MANUAL.__.

MANAGEMENT ADMINISTRATVE INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 2 12 List of Assisting/Contributing Personnel:

Name: Scope of Assistance:

None None

EN-S NUCLEAR Quu EAE I11 Revision 3

-EtoiAGEM- Entgy MANAGEMENT ~ NIi~1I ADMINISTRATIVE_ Ill Rvso MANUAL j INFORMATION USE ATTACHMENT 9.1 50.59 REVIEW FORM Page 3 of 12 II. SCREENING A. Licensina Basis Document Review

1. Does the proposed activity Impact the facility or a procedure as described In any of the following Licensing Basis Documents?

Operating License YES NO CHANGE # and/or SECTIONS TO BE REVISED Operating Ucense 0 0 TS 0 0E NRC Orders 0 0 El If "YES", obtain NRC approval prior to Implementing the change by initiating an LBD change In accordance with NMM W113 (Reference 2.2.13). (See Section 5.1.13 for exceptions.)

LBDs controlled under 50.59 YES NO CHANGE # andlor SECTIONS TO BE REVISED FSAR 0 0 ANO-2 SAR Section 5.2.1.5 and 5.5.10.1 TS Bases 0 0 ANO-2 Bases page 314 4-7 Technical Requirements Manual 0 0 New TRM 3.9.4.2 and associated Bases Core Operating Limits Report 0 0 NRC Safety Evaluation Reports' 0 0 If "YES", perform an Exemption Review per Section V QR perform a 50.59 Evaluation per Section Vi AND initiate an LBD change In accordance with NMM L-113 (Reference 2.2.13).

LBDs controlled under other regulations YES NO CHANGE # andlor SECTIONS TO BE REVISED Quality Assurance Program Manual 2 0 0 2

Emergency Plan 0 0 Fire Protection Program 3 03 0 (includes the Fire Hazards Analysis)

Offsite Dose Calculation Manual 3 03 9 0

if "YES", evaluate any changes In accordance with the appropriate regulation AND Initiate an LBD change In accordance with NMM LI-113 (Reference 2.2.13).

2. Does the proposed activity involve a test or experiment not described In the 0 Yes FSAR? No if "yes," perform an Exemption Review per Section V OR perform a 50.59 Evaluation per Section VI.

3. Does the proposed activity potentially Impact equipment, procedures, or facilities 0 Yes utilized for storing spent fuel at an Independent Spent Fuel Storage Installation? 0 No (Check "NIA" If dry fuel storage Is not applicable to the facility.) NWA If "yes," perform a 72.48 Review In accordance with NMM Procedure LI-112.

(See Sections 1.5 and 5.3.1.5 of the EOI I OCFR50.59 Review Program Guidelines.)

If 'YES," see Section 5.1.4. No LBD change Isrequired.

2 If 'YES," notify the responsible department and ensure a 50.54 Evaluation is perfwmed. Attach the 50.54 Evaluation.

3 I 'YES," evaluate the change in accordance with the requirements of the facility's Operating Ucense Condition.

EN-S NUCLEAR QUALITY RELATED LI-101 Revision 3 EntMANAGEMENT

&9 negMANUAL_._

ADMINISTRATIVE INFORMATION USE A H 5 I ATTACHMENT 9.1 1 50.59 REVIEW FORM IPage 4 iof12 B. Basis Provide a clear, concise basis for the answers given Inthe applicable sections above. Explain why the proposed activity does or does not impact the Operating UcensefTechnical Specifications and/or the FSAR and why the proposed activity does or does not Involve a new test or experiment not previously described in the FSAR. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simply stating that the change does not affect TS or the FSAR is not an acceptable basis. See EOI 50.59 Guidelines Section 5.6.6 for guidance.)

As stated previously, the editorial and administrative changes resulting from the relocation of requirements from the TS to the TRM meet the screening criteria of LI-101 and are not discussed further in this assessment. Further restricting the rates of pressurizer cool down is conservative to the previous TS limits. The new cool down rates have been Implemented in plant procedures since 2003 when a re-evaluation of the pressurizer heater nozzles was conducted due to Identification of nozzle leaks and Installation of MNSA clamps. This assessment indicated a need to reduce the pressurizer cool down rates to limit the extent of flaw growth and increase the life of the pressurizer heater nozzles. The ASME Section Xl fracture mechanics and fatigue analyses of the ANO-2 pressurizer heater sleeves to qualify J-groove weld/cladding flaws left in place following an outside diameter (OD) repair had been performed by Structural Integrity Associates (SI), reviewed by Central Engineering Programs and determined to be appropriate. From the SI analyses, the J-groove weld/cladding flaws in an outermost heater sleeve penetration meet ASME Section Xl, IWB-3600, for all transients as given In the Pressurizer Design Specifications and for the modified cool down transient. This modified cool down transient consists of a 175 °F/hr cool down from s 653 'F to

> 200 OF, followed by a 100 *F/hr cool down from s 200 'F to 2 80 "F. The detailed SI report is attached to Corrective Action 007 response to CR-ANO-2-2003-1082. Because changing the pressurizer cool down rates will bring the TRM/SAR into compliance with the current license basis and Is more restrictive than the previous TS limits, this change does not require further evaluation under 10 CFR 50.59. Furthermore, this change does not introduce a new test or experiment not previously described in the SAR. No other TS, OL, or other NRC-controlled document is affected by this change.

The omission of the shutdown requirement portion of the previous TS Action In the new TRM is considered a less restrictive change and is therefore evaluated under 10 CFR 50.59 (see Section VI). However, this change has no Impact on any other LBD nor does it Introduce a new test or.

experiment not previously described In the SAR.

C. References Discuss the methodology for performing the LBD search. State the location of relevant licensing document

-information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches per Section 5.3.6.4 of LI-101. NOTE: Ensure that electronic and manual searches are performed using controlled copies of documents. Ifyou have any questions, contact your site Licensing department.

LBDs/Documents reviewed via keyword search: Keywords:

LRS Unit 2 50.59 pressurizer w/1 0 rate*, pressurizer w/1 0 shut*,

cool* w/5 rate AND pressurizer, 200 w/2 F AND pressurizer, 175 w/2 F AND pressurizer LBDs/Documents reviewed manually:

SAR Sections 5.2.1.5, 5.2.4.3.1, 5.5.10.1, Table 5.2-1.

D. Is the validity of this Review dependent on any other change? 0 Yes (See Section 5.3.4 of the EOI IOCFR50.59 Program Review Guidelines) 1 No

E EN-S NUCLEAR QuATy RELATED LI-101 Revision 3 j,,,.,lg MANAGEMENT ADMINISTRATiVE MANUAL INFORMATION USE ATTACHMENT 9.1 . 50.59 REVIEW FORM Page 5 of If "Yes," list the required changes.

EN-S NUCLEAR QuALIrTY RELATED LI-101 Revision 3 Enterg MANAGEMENT ADMINIS~TATVE.

INFORMATnON USE ATTACHMENT 9.1 1 50.59 REVIEW FORM Page 6 of 12 Il1. ENVIRONMENTAL SCREENING If any of the following questions Is answered "yes," an Environmental Review must be performed In accordance with NMM Procedure EV-115, "Environmental Evaluations," and attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed Change being evaluated:

Yes No

1. 0 IInvolve a land disturbance of previously disturbed land areas in excess of one acre (i.e.,