2CAN119404, ANO Unit 2 10CFR50.59 Rept for Period 930122-940423.W/

ANO Unit 2 10CFR50.59 Rept for Period 930122-940423.W/

ML20080A874
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/23/1994
From:	Mims D ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2CAN119404, NUDOCS 9411220299
Download: ML20080A874 (128)

Text

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Fkue 3. Sex 137G C,perations mss - n m oi M 501-964 3100 November 18,1994 2CANI19404

- U. S. Nuclear Regulatory Commission Document Control Desk Mail Station Pl-137 l Washington, DC 20555

Subject:

Arkansas Nuclear One - Unit 2 Docket No. 50-368  ;

License No. NPF-6 ANO-210CFR50.59 Report Gentlemen:

In accordance with 10CFR50.59(b)(2), enclosed is the Arkansas Nuclear One, Unit 2, 10CFR50.59 report for the time period ending April 23,1994. This repon contains a brief description of changes in procedures and in the facility as described in the Safety Analysis Report (S AR), tests and experiments conducted which were not described in the S AR, and other changes to the SAR for which a safety analysis was conducted, along with a summary of each safety evaluation.

Very truly yours, hw{ykC 9)$r.,l Dwight C. Mims Director, Licensing DCM/kjm i

Enclosures j l

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DR4n220299 940423 g ADOCK 05000369 PDR

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U. S. NRC November 18,1994 2CANI19404 Page 2 cc: Mr. Leonard J. Callan Regional Administrator U. S. Nuclear Regu% tory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One 1448 S. R. 333 Russellville, AR 72801 Mr. George Kalman NRR Project Manager Region W/ANO-1 & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 1

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ARKANSAS NUCLEAR ONE - UNIT-2 DOCKET No. 50-368 LICENSE No. NPF-6 10CFR50.59 REPORT This report contains a brief description of procedure and design changes made at Arkansas Nuclear One - Unit 2 (ANO-2). These summaries describe changes made to the ANO-2 Safety Analysis Report (SAR) for which an evaluation was determined to be necessary. It also contains evaluations for tests conducted which are not described in the SAR. This report is applicable for the period from January 22,1993, through April 23,1994.

The safety evaluations included in this report were performed in accordance with 10CFR50.59 and determined that none of the changes involved a change to the plant's Technical Specifications or an unreviewed safety question.

CONTENTS ,

SECTION I PROCEDURE CHANGES SECTION II DESIGN CHANGES SECTION III TEMPORARY MODIFICATIONS SECTION IV MISCELLANEOUS EVALUATIONS 4 P f

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ANO-2 PROC: 1000.043 Revision 14 Steam Generator Water Chemistry Monitoring Unit 2 This procedure revision incorporated the latest secondary chemistry recommendations provided in PWR Secondary Water Chemistry Guidelines -

Revision 3. The purpose of the procedure is to implement a secondary water chemistry monitoring program to minimize steam generator tube degradation.

Affected SAR Sections: 10.3.5, 10.4.6, 10.4.7.2, 9.3.2.1 Figures: 10.2-3, 10.4-2, 10.4-3, 10.4-5 Table: 10.3-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the changes to the chemistry requirements equaled or exceeded recommendations of the EPRI guidelines which are designed to reduce equipment corrosion and enhance steam generator reliability thus serving to increase the longevity of the steam generators as well as other associated components; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since all the possible accident scenarios relating to the effects of chemistry on the steam generators and secondary components have been addressed in the SAR; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since all the changes had no effect on the margins of safety as defined in the bases of the Technical Specifications.

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i ANO-2 Procedure 1015.000, Revision 10, PC-2

" Unit 2 SDC Control" l

j This procedure change allowed the throttling of manual valves in the Shutdown Cooling System to prevent significant changes in the event of loss of control air to flow control valves.

.Affected SAR Table: 6.3-22 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since if the control valve fails open, throttling manual valves does not alter the normal flow path; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the alignment created ensures shutdown cooling flow upon loss of instrument air to the control valve and the pocitions of the manual valves will not affect the ability to establish flow at a later time; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the configuration created ensures minimum shutdown cooling flow through the Reactor Cooling System as required by Technical Specifications.

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ANO 2 PROC: 2104.008 Revision 22, PC 2 Circulating Water System Operation This procedure change deleted a vent valve on the Cooling Tower bypass line from the valve lineup. The valve had been removed during Plant Change 93-8010 conducted during Unit 2 refueling outage 2R10. The purpose of the plant change was to correct air and water distribution problems.

Affected SAR Figure: 10.4-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since none of the accidents evaluated in the SAR could be initiated by the removal of this Circulating Water valve from the system nor did removal of the valve contribute to the probability of any equipment malfunction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the types of accidents evaluated in the SAR are determined by design features not affected by this change; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the removal of this valve did not contribute to any margin of safety defined in the basis for any ANO-2 Technical Specifications

l ANO-2 PROC 22104.044 Revision 21 PC-1 Containment Hydrogen Control Operations This procedure revision changed the normal position of valve 2SW-5031 from open to closed to isolate the Service Water system from the Hydrogen Purge system which has been abandoned in place.

Affected SAR Figure: 9.4-4 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety i evaluated in the Safety Analysis Report since the Hydrogen Purge system is not equipment important to safety and the capabilities of safety systems required to respond to analyzed accidents were not affected; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since isolating Service Water to the Hydrogen Purge system is not an accident initiator; or, (iii) reduce the margin of safety as defined in the basis of any 1 Technical Specification since there are no safety margins j related to the Hydrogen Purge system contained in the bases of Technical Specifications. ]

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ANO-2 PROC :2104.044 Revision 22, PC-2 and DRN 94-02087 Containment Hydrogen Control Operations l Procedure change 2104.044 revision 22, pc-2 revised the normal position of two Containment Atmosphere Monitoring System (CAMS) bypass valves from closed to throttled open. DRN 94-02087 corrected the description of valve 2PA-8233C (isolation for purge air to rad monitor filter 2F-414) on the P&ID from a 3-way to a 4-way valve to match as built configuration. Both of these changes were incorporated into the same revision of the drawing.

Affected SAR Figure: 9.4-4 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety I

evaluated in the Safety Analysis Report since throttling the valves allowed the CAMS units to be started from the control room without manual valve manipulation and there is no previously analyzed accident related to the CAMS units; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this is the normal configuration for operating the CAMS units; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there was no margin of safety for these valves defined in the bases of the Tecnical Specifications.

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ANO-2 Procedure :2106.014, Revision 13

" Domestic Water System Operations" This procedure revision changed the position of valves 2DW-58, 2DW-59, 2DW-60, and 2DW-61 to closed and changed their description to spare.

Affected SAR Figure: 9.2-7 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or raalfunction of equipment important to safety evaluated in the Safety Analysis Report since the position of these domestic water valves does not contribute to the consequences or probability of any accident or malfunction of equipment important to safety; or, I (ii) increase the possibility for an accident or malfunction of a ,

different type than any evaluated previously in the Safety I Analysis Report since the types of accidents evaluated in the SAR are determined by design features not affected by this procedure revision. The SAR includes the evaluation of the failure of active and passive safety injection components. This procedure revision does not create the possibility of any other type of equipment malfunction; or, 1

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since the position of these domestic water valves does not contribute to any margin of safety defined in the basis for any ANO-2 Technical Specification.

ANO-2 PROC :2106.014 Revision 13, PC-2 Domestic Water System Operation This procedure change changed the position of one valve in the Domestic Water System from open to closed and changed the description to spare.

Affected SAR Figure: 9.2-7 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no accident evaluated in the SAR can be initiated by the position of this domestic water valve; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the types of accidents evaluated in the SAR are determined by design features not affected by this precedure change; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the position of this domestic water valve does not contributa to any margin of safety defined in the bases for any ANO-2 Technical Specification.

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ANO-2 PROC : 2106.016 Revision 30, PC-4 Condensate and Feedwater Operations This procedure change revised the normal position of two valves from open to closed. These valves were used to isolate the condensate sample flow to sample coolera that were abandoned-in- place equipment.

Affected SAR Figure: 10.4-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no equipment important to safety was affected by the closure of these valves; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since neither the valves nor the sample coolers that the valves isolated were considered equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the Technical Specification bases do not establish a margin of safety for the Condensate and Feedwater System.

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ANO-2 PROC : 2106.016 Revision 30/PC-5 Condensate and Feedwater Operations This procedure change corrected the normal position of condensate pump seal supply valves 2CS-21A/B to "open".

Affected SAR Figure: 10.4-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since these valves remain open while the condensate system is in operation and changing the procedure and drawing to show these valves normally open does not alter the design, function or operation of the condensate system;or, (ii) increase the possibility .or an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the valves do not perform any safety function nor are they required for safe shutdown of the plant; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the position of these valves does not contribute to any margin of safety defined in the basis for any Technical Specification.

ANO-2 Procedures 2106.024, Revision 11

" Start up and Blowdown Demineralizer Operations" This revision to the procedure added a reference to a condition report, changed the normal operating position of demineralizer valves, and altered the instructions for putting the demineralizer in service.

Affected SAR Figure: 10.4-7 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the position of Ammonia Recycle Pump discharge isolation valve, 2BD-12, does not reduce the redundancy of safety related equipment or contribute to the probability of egiupment malfunction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the design features affected by this procedure revision could not effect an accident or malfunction which would be evaluated in the SAR; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the position of isolation valve 2BD-12 does not contribute to any margin of safety defined in the Technical Specifications. ,

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ANO-2 PROC :2106.028 Revision 13 Secondary System Chemical Addition This procedure was revised to minimize secondary system chemistry transients when batching hydrazine and amine. As part of the revision, two valve normal positions were changed on the system P&ID.

Affected SAR Figure: 10.4-5 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the secondary chemical addition system is not safety related and the two valves concerned are not in any safety related system; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since changing the normal position of the valves did not affect any safety related system or component; or, l

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since the secondary chemical addition system has no affect on the margin of safety as defined in the bases of the Technical Specifications.

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AN(-2 PROC :2305.036 Operations Control of Integrated Leak Test

'2hla procedure defines Operation's actions and responsibilities during the performance of the Containment Integrated Leak Rate Test. During development of the procedure it was discovered that information in the SAR regarding applicability of Appendix J testing to the Chemical Volume Control System (CVCS) Charging Line penetration 2P34 was not consistent with Appendix J requirements.

Affected SAR Table: 6.2-26 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the changes to the valve lineup for the CVCS Charging Line are consistent with the requirements of 10CFR50 APP J and the change to the valve lineup will allow utilization of the charging system as a makeup source to the Reactor Coolant System in the event of a Loss Of Coolant Accident; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the lineup changes require the system to remain filled and available which is consistent with the lineup ]

during post accident conditions; or, (iii) reduce the margin of safety as defined in the basis of any J Technical Specification since the lineup changes are conservative

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in regard to margin of safety. 4

ANO-2 PROC : 2403.002 Revision 4 PC-1 Safety-Related Battery Bank Performance Test This procedure revision added two additional methods of placing the 125v DC safety related battery banks on equalizing charge and slightly increased the maximum allowed charging voltages.

Affected SAR Table: 8.3-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the battery charging procedure is performed while the plant is in a refueling outage, the redundant battery is verified operable prior to taking a battery out of service for charging, and the procedure change does not affect the operational parameters of the battery banks or associated chargers; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this procedure change will not impact other safety-related equipment required to be operational during an outage and the battery bank is considered inoperable while the equalizing charge is in progress so that it would not be required at that time to perform its safety-related function; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the charging voltage of the batteries is not an element of any Technical Specification basis.

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l ANO-2 PROC :2403.027 Revision 5 PC-2 ,

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Safety Related Battery Bank Performance Test j I

This procedure revision added two additional methods of placing the 125v DC safety related battery banks on equalize charge and slightly increased the maximum allowed charging voltages, i Affected SAR Table: 8.3-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the battery charging procedure is performed while the plant is in a refueling outage, the redundant battery is verified operable prior to taking a battery out of service for charging, j and the procedure change does not affect the operational l parameters of the battery banks or associated chargers; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety ,

Analysis Report since this procedure change will not impact l other safety related equipment required to be operational during an outage and the battery bank is considered inoperable while the equalizing charge is in progress so that it would not be required at that time to perform its safety related function; or, 1

(iii) reduce the margin of safety as defined in the basis of any l Technical Specification since the charging voltage of the batteries is not an element of any Technical Specification basis.

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ANO-2 PROC 32618.015, Revision 3, PC-2.

Sampling Circulating Water l t

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! This procedure change corrected a valve number and reconciled P&ID M-2209 to the as-built condition. Valve number 2CW-1264, sample isolation valve from the circulating water outlet valve header, existed in the plant but was not shown on the P&ID.

Affected SAR Figure: 10.4-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the valve is not an accident initiator, the Circulating Water System is non-Q and is not a system important to safety, and operation of this valve will not affect a system important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the Circulating Water System cannot be an accident initiator; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the change did not affect any margin in the Technical Specification bases.

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ANO-2 PROC :2628.007 Revision 4 Operation of Circulating Water Chemical Injection System This procedure revision made miscellaneous changes to the operation of the Circulating Water Chemical Injection System including adding instructions for stopping and starting the chemical injection flow rate, flow rate monitoring and leak checking. The changes included revising normal operating positions of two valves from open to closed as an added safety precaution to prevent losing the contents of the bulk tank.

Procedure 2628.008 Revision 3, has been implemented for the other bulk tank in this system Affected SAR Section: 10.4.5.2 Figure: 10.4-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since changing these valves from the normally open to the normally closed position had no negative impact on the operation of the Circulating Water Chemical Injection System or the Circulating Water System and the change serves as an added precaution to prevent losing the contents of the bulk tauk; or, (ii) increase the possibili ty for an accident or malfunction of a different type than a7y evaluated previously in the Safety Analysis Report since the Circulating Water Chemical Injection System is non-Q, is r.ot important to safety, does not affect any system important to safety, and cannot be an accident initiator; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since neither the Circulating Water Chemical Injection System nor the Circulating Water System are addressed in the Technical Specification bases.

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ANO 2 PROC :2628.000, Revision 3 Operation of Circulating Water Chemical Injection System.

This procedure revision made miscellaneous changes to the operation of the Circulating Water Chemical Injection System including adding instructions for stopping and starting the chemical injection flow rate, adding instructions for flow rate monitoring and instructions for leak checking. The changes include revising normal operating positions of two valves from open to closed as an added safety precaution to prevent losing the contents of the bulk tank.

Procedure 2628.007, Revision 4, has been implemented for the other bulk tank in this system.

This change affected SAR Section 10.4.5.2 and Figure 10.4-1.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since changing these valves from the normally open to normally closed position had no negative impact on the operation of the Circulating Water Chemical Injection System or the Circulating Water System and the change serves as an added precaution to prevent losing the contents of the bulk tank; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the Circulating Water Chemical Injection System is non-Q, is not important to safety, does not affect any system important to safety, and cannot be an accident initiator; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since neither the Circulating Water Chemical Injection System nor the Circulating Water System are addressed in the Technical Specification bases.

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ANO-C PROC: 5000.017 Rev 0 l

Engineering Equivalency Evaluations l I

This procedure provides instructions so that equivalency evaluations of replacement items which are not identical to the currently installed item are l carried out to ensure that the design bases of the item and its interfacing systems are not degraded.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this procedure is administrative in nature; or,  ;

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety j Analysis Report since implementing this procedure affected only the definition of a modification contained in the Quality Assurance Manual, Operations; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since this procedure is not related to the margins of safety as defined in the bases of any Technical Specifications.

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-_m ANO-C PROC: 6000.010 Rev 6 Design Control Process Incorporated into this procedure revision are various administrative changes that have occurred within the design control process involving clarification of procedures for modification package development, the deletion of redundant instructions for Condition Reports and the deletion of instructions for the development of project plans that are no longer required.

It was determined that these changes did not-(i) increase the probability of occurrence or consequence of an j accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this change is administrative in nature and is consistent with design control requirements; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the revision only involves clarification and administrative changes within the design control process; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since this administrative change is not related to the margins of safety as defined in the bases for the technical specifications.

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SECTION II DESIGN CHANGES

ANO-2 DCP: 89-1022

" Alternate AC Power Source (IR11 Outage Work) "

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This design change installed a portion of the Station Blackout Project as l required by 10CFR50.63 during refuelling outage IR11. This portion of the I project mounted the 4160 Volt switchgear in ANO-2, installed electrical raceways in both units, and completed electrical tie-ins in ANO-1 in preparation for completion of the project. )

l This design change required the revision of ANO-1 SAR Figure 9-1 and the j ANO-2 SAR Figures noted below. j Affected SAR Figures: 8.3-1, 8.3-59, 8.3-66 i

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new cables, trays, conduits, and switchgear were installed in either the non-safety related Turbine Building or in existing raceways in the safety related Auxiliary Building. Connections to safety related equipment were isolated by circuit breakers or coil-to-contact isolation and therefore considered non-safety related, g Failures which involve this isolation will cause the loss of 4 only one safety bus, which is bounded by the " Loss of All AC Power" accident and the estimated off-site dose due to this accident was not affected; or, (ti) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since none of the equipment which was added is safety related and all connections with safety related equipment was isolated by qualified devices. Failures which involve this isolation can only result in the loss of one safety bus for which there is a redundant bus; or, I

(iii) reduce the margin of safety as defined in the basis of any l I

Technical Specification since the only Technical Specification bases which are applicable define a margin of safety as ,

maintaining one channel of the redundant safety related power system available during accident conditions and failures involving the isolation between the safety related and non-safety related equipment can only result in the loss of one safety bus.

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1 ANO-2 DCP :89-2001, DCPR #4

'ANO Unit 2 Intake Structure HVAC Deficiencies" This design change upgraded the ANO-2 Intake Structure Heating, Ventilation, and Air Conditioning (HVAC) System to prevent freezing instrumentation and piping on elevation 354'-0" and alleviate high ambient air temperatures on elevation 336'-0". In addition, this design change added flood relief doors to prevent flooding on elevation 354'-0" of the Intake Structure due to a service water pipe rupture.

Affected SAR Figure: 8.3-54 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since only the loss of service water pumps and flooding of the Intake Structure accidents were found to be related to this modification and this modification did not affect these accident analyses. The only related equipment important to safety are the ventilation exhaust fans 2VEF-25A and B. The consequences of a malfunction of 2VEF-25A or B were not increased; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the components being added, replaced, and modified per this DCP did not alter the design function of the Intake Structure HVAC System. The modifications did not create the potential for any new evaluated accidents; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

ANO-2 DCP 89-2017 Alternate AC Power Source Project This design change package covered the Unit 2 outage portion of the alternate AC power source (Station Blackout) project and consisted of 5 kV and control connections, boronmeter removal, Engineered Safety Features (ESP) room flooding alarm changes and Kirk Key interlock replacement.

Affected SAR Sections: 15.1.13.4.2, 15.1.4.1, 7.7.1.1.6, 8.3.1.1.8.11.8, 8.3.1.1.8.4, 8.3.1.1.9.4, 8.3.1.1.9.5, 9.3.4.2.2, 9.3.4.3.12, 9.3.4.4.1, CH 9 LIST OF TABLES Figures: 8.3-1, 8.3-24, 8.3-25, 8.3-32, 8.3-33, 8.3-34, 8.3-35, 8.3-36, 8.3-39, 8.3-4, 8.3-40, 8.3-49, 8.3-5, 8.3-66, 8.3-67 Tables: 14.1-1, 7.5-3, 9.3-20, 9.3-21, 9.3-22 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new electrical conduits, cables and control cabinets were located in the non safety related turbine building or installed in existing raceway when in the safety related auxiliary building, the Alternate AC generator, its support systems, interfaces and structure do not increase the consequences of a failure of equipment important to safety, the boronmeter was only one of several devices that provided indication of a change in boron concentration, the logic behind the interlocking circuit was the same as the logic currently used with the mechanical Kirk Keys, and the ESF pump room water level alarms have no control function and do not interface with any safety related system; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the Alternate AC generator is configured as a standby power source for use in the event of the simultaneous loss of offsite power and failure of onsite emergency diesel generators and this is beyond the design basis of either unit at ANO. Removal of the boronmeter can not initiate any accidents upon failure or malfunction, the new electrical interlocks provide a similar level of protection to the mechanical interlocks and the ESF pump room alarms cannot initiate any accidents; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the new switchgear and connections are isolated from other equipment and the boronmeter, the mechanical Kirk Key interlocks or the water level indications are not discussed in the basis of the Technical Specifications.

ANO-2 DCP :90-1051 "ANO-1 Black Battery' This design change installed a non-safety 125 VDC distribution system to supply power for most of the non-safety loads on the red and green train buses.

This change required a revision to ANO-1 SAR Sections 1.4 13, 8.1.2, 8.2.1.3, 8.2.1.4, 8.3.1.1.6, 8.3.2.1, 8.3.2.1.1, 8.3.2.1.2, 8.3.2.1.3, 8.3.2.1.4, 8.3.2.1.5, 8.3.2.1.6, 8.3.2.1.7, 8.3.2.1.8, 9.7.2.1, 9.7.2.2, and 9.11, Figures 1-3, 1-4, A-2, A-3, 8-1, 8-9, 9-13, and 9-14; ANO-2 SAR Section 8.2.1.3 and Figure 8.2-3; and FRA Sections 6.4.4, 10.0, and Figure A-2.

Affected SAR Section: 8.2.1.3 Figure: 8.2-3 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new 125 VDC system and its associated loads are not safety related and will help the station cope with a loss of electric power other than station batteries; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no new failure modes which have not been previously evaluated were introduced; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the non-safety 125 VDC bus and associated loads have no impact on any margin of safety. 1 1

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l ANO-2 DCP : 91-2001 i

Main Steam Isolation Valve (MSIV) Solenoid Operated Valve Logic Upgrade This design change package revised the actuation logic of the MSIV actuator supply air control system. The new configuration requires the energization of either solenoid valve to exhaust pilot air from the 3-way valves to allow the MSIV to close Affected SAR Figures: 10.2-3, 10.3-1, 7.3-9 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the solenoid valves do not directly interface from a pressure boundary or electrical standpoint with equipment whose failure or mis-operation is associated with the initiation of the accident scenarios in the SAR; or, )

l (ii) increase the possibility for an accident or malfunction of a 1 different type than any evaluated previously in the Safety Analysis Report since the function of the solenoid valves is to assist in mitigating the consequences of a Main Steam Line Break (MS LB) accident by providing the means for automatic closure of the MSIVs and this feature is unchanged by this modification; or, I

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since there is no margin of safety discussed in the Technical Specifications concerning MSIV closure, l

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l ANO-2 DCP :91-2003 "ANO-2 Hydrogen Monitoring Modification" This design change modified the ANO-2 Hydrogen Monitoring System to reduce the sampling time below 30 minutes to meet NUREG 0737 Item II.f.1.f. To accomplish this, the primary sampling point was moved from the containment dome :o elevation 405'. Also, several local operations were moved to the control icom to reduce operator burden, i 1

Affected SAR Figure: 9.4-4 l i

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since two independent, I redundant safety channnels were used for the safety related portion of the modification and since all Q components were seismically installed; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the unlikely failure of of both safety grade trains of hydrogen sampling would only lead to loss of hydrogen concentration indication. In this case, the hydrogen i recombiners could be activated in the possibility of a LOCA; or, )

(iii) r educe the margin of safety as defined in the basis of any Technical Specification since no Technical Specification bases establish a margin of safety for the operationof the hydrogen sampling system.

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ANO-2 DCP 292-2013

" Cooling Tower Chemical Addition" This design change provided direction and instruction for the permanent installation of a CUPROSTAT chemical addition system for the circulating water system. The permanent system includes a pump to transfer the chemical to a day tank. A metering pump will inject the chemical into the cooling tower basin upstream of the circulating water pumps. The 25 kVA transformer in the Calgon building was replaced with 37.5 kVA transformer.

Affected SAR Section: 10.4.5.2 Figure: 10.4-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this modification did not change the concentrations, injection rates, or chemicals injected into the cooling tower basin. Installation of the permanent CUPROSTAT addition system did not affect the safe shutdown capability of the unit or affect any safety related component or structure; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the CUPROSTAT system is nonsafety-related ]

and in a nonsafety-related portion of the plant. The changes l made by this modification did not affect any equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there is no defined margin of safety for the subject system presented in the basis of any Technical Specification.

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l ANO-2 DCP :92-2016

'ANO-2 Secondary Sample Room Chemistry Monitor Addition" 1 1

l This design change added a plant computer satellite display station (SDS) to i the secondary chemistry sample panel. The SDS allows trending and monitoring l of chemistry parameters which are monitored by the plant computer. Six L&N l strip chart recorders ( 2 AR - 4 0 51, 4052, 4053, 4054, 4061, and 4062) were deleted since their function is performed by the plant computer and the SDS. l Affected SAR Figure: 9.3-3 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since review of the LBD did not identify any previously evaluated accident probabilities l or consequences which are affected by using the SDS and plant i computer to replace the recorder functions and no important to safety equipment is impacted by the method of trending secondary chemistry parameters; or, 1

(ii) increase the possibility for an accident or malfunction of a  ;

different type than any evaluated previously in the Safety l Analysis Report since malfunction of the equipment associated l with the secondary chemistry SDS will result in loss of local monitoring capability without creating the possibility of a different type accident than previously evaluated in the LBD.

No important to safety equipment malfunctions created by changing l the method of trending the secondary chemistry parameters were identified by the LBD review; or ,

(iii) reduce the margin of safety as defined in the basis of any 1 Technical Specification since no margin of safety was identified in the Technical Specification bases which is dependent upon l local secondary chemistry point monitoring.

ANO-2 DCP: 92-2021 and DCP: 93-1003

" Installation of Voltage Regulators for Offsite Power Sources

• This evaluation was associated with both Design Change Package (DCP) 93-1003 and DCP 92-2021. Together, these two design changes installed voltage regulators on Startup Transformers 1, 2, and 3 to insure operability of offsite power sources.

These design changes required the revision of Unit 1 SAR sections 8.2.1.3 and 8.2.1.4 and Figure 8-1 along with the Unit 2 SAR Sections and Figures noted below.

Affected SAR Sections: 8.2.1.3, 8.2.1.4 Figures: 8.2-2, 8.3-1, 8.3-21, 8.3-23, 8.3-3, 8.3-36 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the likelihood of a failure of a GDC-17 source is only slightly increased and is far outweighed by the regulators' ability to prevent a degraded voltage condition and since none of the evaluated failure modes would, by itself, lead to an increased probability of Loss of Offsite Power; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the only possible accident, Loss of Offsite Power, and all possible malfunctions associated with this modification have already been evaluated and; or,  ;

i (iii) reduce the margin of safety as defined in the basis of any '

Technical Specification since no margins of safety can be l related to the addition of voltage regulators.

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l ANO-2 DCP :92-2023 Critical Applications Programs Systems (CAPS) Migration To The Plant Computer This design change package removed the CAPS computer and all its associated peripherals and migrated all of its functions into the Unit 2 plant computer.

Affected SAR Sections: 7.2.1.1.2.2, 7.2.1.1.2.5.1.3, 7.2.1.1.2.5.1.4, 7.2.1.1.2.5.1.7, 7.2.1.1.2.5.1.8, 7.2.1.1.2.5.2, I 7.5.1.4.1, 7.7.1.1.1, 7.7.1.3.1, 7.7.1.3.2, l 7.7.1.4 Figures: 10.2-3, 5.1-3, 7.2-14, 8.3-16, 8.3-18, 8.3-20, 8.3-22, 8.3-23, 8.3-24, 8.3-25, 8.3-3, 8.3-32, 8.3-33, 8.3-34, 8.3-35, 8.3-36, 8.3-39, 8.3-4, i 8.3-40, 8.3-42, 8.3-44, 8.3-45, 8.3-47, 8.3-49, I 8.3-5, 8.3-50, 8.3-51, 8.3-52, 8.3-7, 9.2-1, 9.3-4, 9.4-4 Tables: 14.1-4, 7.5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the alarms and control functions and the limiting safety system settings did j not change as a result of the modification and there is no  :

equipment important to safety that will be impacted in any way by this modification; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the installation of this system had no negative effect on a safety related system or component; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the modification serves to enhance the reliability of the COLSS program, therefore the margin of safety will not be impacted.

ANO-2 DCP :92-2026 B&W Incore Instrument Assembly Replacement This design change package replaced the B&W incore instrument (ICI) assembly located at core position J-8 with a CE incore instrument assembly and upgraded the cable assembly to meet Reg Guide 1.97 requirements.

Affected SAR Section: 7.7.1.1.7 Figure: 4.2-16 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new incore instrument assembly and ICI cable subassembly were both environmentally and seismically qualified, the quality of information available from the incore instrumentation system will not be degraded by this modification and the new cable subassembly is considered an upgrade from the previous installation; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the new incore instrument assembly is identical to the other 41 incore instrument assemblies presently installed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the margin of safety as defined in the Technical Specifications has been restored to the same level as before installation of the B&W incore instrument assembly.

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ANO-2 DCP :93-2003

" Permanent Piping Installation Tor Vendor-Supplied Liquid Radioactive Waste System" This modification installed permanent stainless steel piping which replaced temporary flexible hose connecting the Liquid Radioactive Waste (LRW) system with the verador-supplied LRW processing system. Connections near the vendor LRW skid were provided from the Chemical and Volume Control System (for demineralised water) , the Instrument Air System, and a permanent non-vital power sourc(

Affected SAR Section: 11.2.1 Figures: 11.2-1, 11.2-2, 11.5-1, 9.3-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence cf an accident or malfunction of equipment important to safet7 evaluated in the Safety Analysis Report since all design bases associated with radwaste have been maintained and incorporated in this modification; system characteristics related to the contol of radwaste effluent have not been altered; and other associated equipment functions in accordance with original system design; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the system function is non-safety, non-Q, and no components important to safety were impacted by the addition of this modification; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the systems and components associated with this change operate and function consistently with the original design.

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ANO-2 DCP :93-2005 Electrical Penetration Modifications This DCP replaced selected Amphenol-SAMS Containment Building electrical penetration feedthrough modules with new Conax Electrical Penetration Assembly (EPA) modules due to replacements being unavailable from the original vendct.

Affected SAR Section: 8.3.1.1.13.G Figure: 3.2-5 It was determined that these changes did not:

(1) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the replacement feedthrough modules are of a superior mechanical and electrical design to the original modules and have virtually the same form, fit and function of the modules they replaced; or, (Ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the modules added were of equivalant form, fit and function to the modules being replaced and introduced no known unevaluated malfunction of equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the modules were designed and tested to meet or exceed all Environmental Qualification requirements for inside ANO-2 containment.

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ANO-2 DCP :93-2012 High Pressure Safety Injection (HPSI) System Injection Valve Replacement This Design Change Package replaced four of the eight motor operated throttling valves on the HPSI injection lines with motor operated isolation valves. Manually operated globe valves in series with the new motor operated valves (IS7Vs) were added. The manual valves were secured in a pre-selected throttle position to balance flow between the injection lines.

Affected SAR Section: 6.3.2.2.6.A Figure: 6.3-2 Table: 15.1.13-5 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the HPSI system pressure boundary quality, response, and function were maintained.

Also, the new manual valves perform the throttling function without relying on limit switches resulting in increased system reliability; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the modification had no effect on any existing equipment except for the MOVs which were replaced and the failure of one of the new valves is no different in effect from the failure of one of the replaced valves and is enveloped by the assumptions in the safety analysis, i.e., redundant trains are still able to function; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the new manual valves were throttled to produce the same system balance as existed previously and this balance was confirmed by surveillance testing to meet the requirements of the Technical Specifications.

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ANO-2 DCP :93-2015 Replacement of Containment Isolation Valves 2N2-1, 2SA-69, and 2BA-216 This Design Change Package replaced three containment isolation valves (2N2-1, 2SA-69, and 2BA-216) located inside of the ANO-2 Containment Building. Check valves 2SA-69 and 2BA-216 were replaced with manual gate valves administratively controlled as normally locked closed. Valve 2N2-1 was replaced with a bolted bonnet design to eliminate seat area distortion that was identified as a contributor to past leakage. Safety Analysis Report Table 9.5-2 was also updated to reflect changes of valve numbers 2IA-14 and 2IA-15 to 2BA-217 and 2BA-216 per DCP-79-2133.

Affected SAR Figure: 9.3-1 Tables: 6.2-26, 9.5-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the Containment Isolation system is not an accident initiator, the modifications did not change the system function, and the replacement valves meet or exceed the original design requirements. No new pathways for the release of radioactivity were created by by this change.

Administrative controls established per the directions in NRC Generic Letter 91-08 ensure the modifications will not in any way impede mitigating actions or restrict access to the vavles.

Containment isolation capabilities of the Nitrogen Supply, Service Air and Breathing Air systems were enhanced by the tighter valve shut-off provided by the gate valve design and the elimination of a contributor to past leakage; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since administrative controls addressed in NRC Generic letter 91-08 ensure that the valves are closed under accident conditions, the design of each of the associated penetrations remains in accordance with 10CFR50 Appendix A General Design Criteria 56, and no new accident initiators or failure r odes were introduced; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the ANO-2 Technical Specifications bases do not identify a margin of safety for 2SA-69, 2N2-1 or 2BA-216.

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ANO-2 LCP :91-6001 Install Temperature Controls on Sodium Hydroxide Tank Level Lines This LCP added two heat tracing thermostats to provide more accurate control of the temperature of the Sodium Hydroxide Tank narrow range level sensing instrument lines, thereby improving the accuracy of the instrumentation.

Affected SAR Figure: 8.3-56 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the added thermostats and heat tracing controls are not safety related, nor is the instrumentation served by the heat tracing functionally safety related; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the heat tracing controllers, due to their nature and application, cannot initiate an accident. All the components added are non safety related; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no credit is taken for any design feature related to these heat tracing circuits, either directly or indirectly.

l ANO-2 LCP 391-6016 Motor Operated Valve Modifications on Emergency Feedwater System 1

This Limited Change Package modified motor gearing and spring packs in the motor operators of four valves on the Emergency Feedwater System in order to allow correct torque and thrust to be transmitted to the valves. The change j resulted in increasing allowable closure time from 20 to 40 seconds. {

I Affected SAR Table: 6.2-26 ,

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(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety, evaluated in the Safety Analysis Report since the valves safety related functions and safety significant capabilities are either unchanged or improved by the new operator parts which enable the operators to function with enhanced reliability and the new valve stroke times meet requirements of Technical Specifications and applicable accident analyses; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since replacing the valve operator parts does not change the function or failure modes of any component, system or structure; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since replacing valve operator parts does not reduce the margin of safety in the basis of the Tech.

Specs.

i ANO 2 LCP 92-6001 Emergency Feedwater Pump Room Accessibility This License Change Package (LCP) provided a removable access platform in the emergency feedwater pump room to allow safer access to instrumentation by personnel performing inspections or surveillances. Installation of the platform required deletion and capping of a drain line shown on a SAR figure.

Affected SAR Figure: 10.2-4 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the installation of the removable platform provided safer access to various pieces of equipment that require routine inspection, the platform is seicmically designed as a class I structure and all piping modifications were done as per the original design specifications for material and construction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the modification did not change the function or failure modes of any component system or structure or introduce the possibility of any new malfunctions of equipment deemed important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since nothing in the modification affected the margin of safety defined in the bases of any Technical Specification.

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ANO-2 LCP :93-6011

" Service Water Pump 2P4A Cable Replacement" ,

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This LCP replaced the 5kV, 250 MCM power cables for service water pump 2P4A with SkV, 300 MCM cable. The new cable was routed in the same raceway as the previous 250 MCM cables.

Affected SAR Figure: 8.3-5 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since installation of this modification has no impact upon the initiation of any accident and no new failure modes are created; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this modification is bounded by existing accident and single failure analyses; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the use of a larger cable for service water pump 2P4A has no bearing on any of the stated margins of safety.

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l ANO-2 LCP 93-6015 Controlled Access Network for Entergy Radiological Information System (ERIM) 1 I

This limited change package installed hardware to extend this site computer l network into Controlled Access. )

Affected SAR Fi gure : 8.3-67 It was determined that these changes did not:

(i) increase the probability of occurrence, or consequence et an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the change was not associated with any cause or initiator of any previously analyzed accident and the conduit is a passive device that is not associated with a radiological barrier or system; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the conduit has no active safety function and the installation requirements met the standards and quality requirements for non-Q raceway; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there are no margins of safety associated with the addition of the conduit.

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ANO-2 LCP 393-6020 Turbine / Generator Instrumentation Upgrade The ANO-2 turbine supervisory control system has been upgraded to provide coincident signals for four turbine trip parameters and convert the low pressure turbine high hood temperature automatic trip function to a hood temperature high-high alarm.

Affected SAR Section: 10.2.2.4 Figures: 10.2-5, 10.4-2, 3.2-1, 3.2-6, 7.3-9 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the instrumentation installed neither performs nor interfaces with any safety related functions and failure of the equipment will not adversely affect any equipment important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safetr Analysis Report since the operating modes, operating rangas and capabilities of the turbine generator and its auxiliary systems have not been changed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since none of the changes impact the functionality or performance of the turbine overspeed protection features.

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ANO-2 LCP :93-6026 Removal Of Safety Injection Actuation Signal (SIAS) from Two Valves This limited change package removed the SIAS signal from two steam generator sample isolation valves while retaining all other functions. This change was made to ensure that a steam generator tube rupture cannot remain undiagnosed.

The SIAS signal had been added as a conservative measure in response to Reg Guide 0737.

Affected SAR Section: 9.3.2.3 Figure: 9.3-2 Table: 6.2-26 I 1

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the removal of ]

the SIAS function has no relationship to the initiation of any i accident previously analyzed and the subject valves will retain their Containment Isolation Actuation System (CIAS) signal after the modification is completed, therefore the original configuration used in the plant design will be maintained; or, (ii) increase the possibility for an accident or malfunction of a 1 different type than any evaluated previously in the Safety Analysis Report since the possible malfunctions of the valves after removal of the SIAS function are no different from those analyzed for the CIAS which will still be used; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the Technical Specification bases related to these valves will not be affected by this LCP.

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ANO-2 LCP :93-6027 Permanent Modification to Ensure ANO-2 Reactor Building Sump Integrity In order to enhance the ability of the Reactor Building Sump to prevent debris from entering the Emer91ncy Core Cooling System (ECCS) during post-LOCA recirculation operatiena, the following modifications were performed:

1. The temporary screen cap strainer on the east side of the sump was removed and replaced with a permanent screen cap strainer.

2. Temporary perforated plates were removed from the curb openings and five of the seven holes were grouted. The other two openings were provided with permanent screens.

3. Existing floor drains into the sump were inspected and provided with permanent screens.

4. The divider wall screen between the two parts of the sump was replaced with a mesh screen.

Affected SAR Section: 6.2.2.2.1.B 7 Figure: 11.2-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this modification increased the ability of the RB sump to function correctly as an ECCS suction source by preventing particles from entering the sump without affecting accident initiators or prohibiting flow into the sump; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the changes introduced no new failure modes and improved the capability of the to sump function according to its design basis; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the subject change does not i affect the basis for any Technical Specifications.

l ANO-2 LCP :94-6004 l

1 Main Feedwater Regulating Valves (MPRVs) Modification This modification replaced the MFRVs lockup feature with a passive air accumulator which allows the valves to remain open upon loss of instrument air and replaced the existing non-linear valve position transmitters with linear valve position transmitters.

Affected SAR Figures: 10.4-2, 8.3-60 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this modification allows both the MFRVs and the MFRBVs to remain in operation for over an hour after instrument air is lost and the changes did not affect the ability of the valves to close during analyzed accident conditions; or ,

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the modification introduced no new failure modes nor did it have any effect on equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the modificction did not affect any margin of safety defined in the bases of any Technical Specifications.

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ANO-2 PC :89-8045

" Reroute Recirculation Line Around 2P138" This plant change rerouted the recirculation line on the discharge side of pump 2P138 so that the line is between check valve 2CT-81 and pump 2P138.  ;

I This modification allows check valve 2CT-81 to prevent resin and air backflow through the recirculation line. I l

Affected SAR Figure: 10.4-7 1

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l (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. The startup and blowdown ,

demineralizer system has no safety-related function. Any failure in the system would be confined to the system and would not affect  !

plant safety. Neither the design bases nor the system operation are affected by this modification; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since rerouting the recirculation line does not change the operation of any safety-related system and does not l affect the design bases; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the startup and blowdown demineralizer system has no safety function and the Technical Specifications do not indicate any margins of safety, i

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1 ANO-2 PC :90-8074 l i

" Removal of Unused Controller from 2VCC-26" This modification reF4ved temperature Controller 2TC-7865 and indicator 2TI-7865 and associated pneumatic tubing and instrument air supply lines.

Affected SAR Figures: 3.2-4, 9.3-1 It was determined that these changes did not:

l (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the temperature control equipment removed was used for personnel comfort and was not safety related nor did it affect any safety related component or system; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the equipment removed was part of a system which controlled temperature in an Auxiliary Building corridor for personnel comfort only and had no interaction with any safety related equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no bases were affected by the modifications.

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R ANO-2 PC 391-8014 Revision DCPR #2 Reactor Vessel Differential Pressure Loops Out Of Service The purpose of this plant change (PC) was to provide the capability of measuring the primary side pressure drop across one steam generator by restoration of operability for instrumentation used during initial plant startup and subsequently abandoned in place.

Affected SAR Figures: 5.1-3, 5.5-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the instrumentation affected by this plant change does not directly interface with any equipment important to safety; or, i

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since any malfunction associsted with the components affected by this PC would affect only components already in the system; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since this change did not cause any margins of safety as defined in the bases for any Technical Specification to be reduced.

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ANO-2 PC : 91-8074 i Elapsed Time Meters For Charging Pumps This plant change added elapsed time meters for the charging pump motors in the Chemical and Volume Control System, Affected SAR Figure: 9.3-4 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the elapsed time meters are non-Q, non-safety related and have no direct or indirect effects on any safety related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no new failure mechanisms were introduced by this modification; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the elapsed time meters were inserted into the circuit of the charging pump seal lube pumps which are not covered by the Technical Specifications or their bases.

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ANO 2 PC :92-7070

" Install Isolation Valve on Hydrant H-6*

The plant change installed an isolation valve on fire water hydrant H-6 so that the 12" Fire Water Main Loop wnuld no longer have to be isolated to perform maintenence on the hydrant. This modification also brings the hydrant into compliance with current N.F.P.A. standards.

Affected SAR Figure: 9.5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the section of piping in which the isolation valve is to be installed can still be isolated from the Main Loop should it require maintenence or removal from service and since there is safety-related equipment located in the area of the hydrant; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the affected section of piping can still be isolated in the event of a line break and there is no safety-related equipment located in the area of the hydrant; or, (iii) reduce the margin of safety as definod in the basis of any Technical Specification since the margin of safety presented in the Technical Specificatio is based upon the availability fire water to areas having equipment important to safety and this modification will not impair the '<ater supply to any of these areas.

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l ANO-2 PC :92-8008 Valve Operator Replacement This plant change replaced two electric motor operators on the steam generator blowdown control valves with pneumatic operators.

Affected SAR Section: 10.4.8 Figures: 10.2-3, 8.3-56, 9.3-1 It was determined that these changes did not: I (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the blowdown control valve failure position on loss of air remains unchanged from the electric operators (fails as-is) and valve operation is not a required safety function; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since replacement of the motor operator with a pneumatic operator did not create any new failure modes; or, (iii) reduce the margin of safety as defined in the basis of any j

Technical Specification since neither the steam generator blowdown control valves nor the instrument air are discussed in the basis of any Technical Specification. Therefore the margin of safety as defined in the basis for any Technical Specification was not reduced by the installation of this modification.

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ANO-2 PC :92-8024

• Emergency Diesel Generator (EDG) Air Compressor Unloader Drain Valves" This plant change installed low point drain valves (2ED-1040, 1041, 1042, and 7801) on diesel generator air compressors to allow moisture accumulation to be removed.

Affected SAR Figure: 9.5-8 4

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. The diesel generators do not play any part in the initiation of any design basis accidents. The addition of this PC will have no impact on any other systems besides the diesels and therefore does not increase the probability or consequence of an accident previously evaluated in the LBD. The original design requirements are maintained; therefore, the probability or consequence of a malfunction of equipment important to safety is not increased; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. The new valves and piping meet all original design requirements and therefore do not increase the probability of failure of a diesel or the probability of any new accident or malfunction occurring; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since all original design requirements are maintained to assure that the diesel generators will be available to perform their safety function and no unanalyzed failures are created.

ANO-2 PC :92-8027

" Install Additional Handswitch for 2CV-2330A and B" The plant change installed a handswitch in the Boron Management System to facilitate the emptying of both a boric acid condensate tank and a Liquid Rad Waste condensate storage tank at the same time.

Affected SAR Figure: 11.2-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the handswitch which was installed in the non-safety Boron Management System is redundant to existing switches and does not affect the system's normal design functions; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no new types of components or systems were added and the new switch is not connected to any safety related equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no Technical Specification bases address the discharge flow rate of the non-safety Boron Management System.

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ANO-2 PC :92-8045

" Diesel Generator Fuel Oil Pump Suction Pressure Gauge" This plant change added permanent non-Q fittings and a pressure gauge to the suction line of the fuel oil pump for both the 2K-4A and 2K-4B diesel generators.

Affected SAR Figure: 9.5-8 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. This PC only impacts the Unit 2 diesel generators which are not involved in the initiation of any design basis accidents. Therefore, the installation of pressure gauges on the diesel generators will not increase the probability or consequences of an accident previously evaluated in the LBD. This change does not affect the ability of the diesel generator to perform its safety function and no other equipment important to safety is affected; therefore, the probability or consequences of a malfunction of equipment important to safety is not increased; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. The diesel generators are the only equipment important to safety impacted by this PC and there are no credible events created by the installation of these pressure gauges that could lead to the failure of both diesel generators. The failure of a single diesel generator has been previously evaluated in the LBD and the failure of the passive gauge and/or fittings that are used for local indication only cannot initiate an accident.

Therefore, no new malfunctions of equipment important to safety or accidents different than any previously analyzed are created; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification. Installing a pressure gauge and fittings to allow fuel oil pumps suction pressure readings to be taken on the ciesel generators only impacts the diesel generators. The gauge and fittings do not affect the seismic qualification of the piping and they meet the pressure rating requirements of the system. Only one valve can be in service at a time and will normally be isolated except to take readings during surveillance testing. The gauges cannot be left unattended while the isolation valve is open. All of this assures that the diesel generators will be available as required by the Technical Specifications and i their bases.

ANO-2 PC 392-8047

" Vacuum Pump Separator Tank Drains" Drain valves and lines were installed on the condenser vacuum pump separator tanks.

Affected SAR Figure: 10.4-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no change in design or function was incurred from the installation and the added equipment does not interface with any safety related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the added equipment meets existing design requirements and does not interface with any safety related equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no bases address the main condenser or the evacuation system.

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ANO-2 PC 292-8048

" Refueling Machine Pneumatic Control Panel Replacement" This Plant Change replaced the current, non-Q refueling machine control panel with a new panel and associated control componets. The dry sipping system, which was part of the original control panel, had previously been abandoned and was not included as part of the new control panel.

Affected SAR Sections: 9.1.4.2.15, 9.1.4.3.2 It was determined that these changes did not: l l

(i) increase the probability of occurrence or consequence of an )

accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the dry sipping system had no affect on the operation of the normal fuel l handling equipment, did not serve to mitigate the consequences of a previously analyzed accident, and was not a safety-related component; or, (ii) increase the possibility for an accident er malfunction of a different type than any evaluated previously in the Safety 1 Analysis Report since remaining refueling equipment will be )

operated as originally designed, use of the dry sipping system J had not been attempted since the early 1980's, and there is no increase in potential for accidents due to removal of dry sipping system controls; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the dry sipping system is not a safety-related system.

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ANO-2 PC :92-8074 Pressurizer Pressure Control Loop Setpoint Change This Plant Change reprogrammed two controllers on the Pressurizer Pressure Control System (PPCS) to allow each controller to operate independently. The pressurizer backup heaters and spray valves now operate from controller 1 and Controller 2 controls the proportional heaters. The two pressure transmitters were also recalibrated for the 0-2500 psia range.

Affected SAR Sections: 5.6.2.2, 7.7.1.1.2 Figure: 5.1-3 Tables: 5.6-1, 5.6-1, 7.5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the changes made to the PPCS will have no effect on the consequences of any accident described in the SAR. There is no relationship between the PPCS and any equipment important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since any potential failure of the PPCS is considered an Anticipated Operational Occurence and is adequately covered by plant abnormal operating procedures, the redundant loop, and the operators ability to manually control proportional heaters or pressurizer spray valves; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the PPCS is not mentioned and no margin to safety is defined in the bases of the Technical ,

Specifications.

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ANO-2 PC 292-8081 '

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l Alarm System For Safety Shower And Eyewash Station j l

l This plant change removed the alarm from safety shower and eyewash station 2SSH-6 and amended the P&ID to show the correct as-installed position of a flow switch on safety shower 2SSH-12.

Affected SAR Figure: 9.2-7 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since neither the shower or the shower alarm are considered equipment important to safety nor do they support any equipment important to nuclear safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since neither the shower or shower alarm are l accident initiators; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there is no Technical Specification basis for the safety shower system.

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ANO-2 FC :92-8084 "CCW Corrision Coupon Racks' This Plant Change installed two coupon racks in the Component Cooling Water (CCW) system so the rate of corrosion could be monitored.

Affected SAR Figure: 9.2-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the racks were installed in a non-safety related portion of the CCW system in accordance with existing piping codes; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the racks were installed in a non-safety related portion of the CCW system in accordance with existing piping codes and a failure of the CCW system has already been analyzed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the CCW system is not addressed in the bases of the Technical Specifications.

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l ANO-2 PC 92-8086 "Inline Filters for the Blowdown Radiation Monitors.

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This plant change installed two single canister filters upstream of two blowdown radiation monitor pressure control valves. The filters were installed to prevent contamination from damaging the pressure control valves which have a history of maintenance problems.

Affected SAR Figure: 9.3-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the filters and associated hardware were installed per existing tubing specification and the new filters have a much higher capacity than the previous ones making blockage of the monitors, which are facilitators in the diagnosis of steam generator tube leakage, less likely; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety ,

Analysis Report since possible equipment failures for the new I design are the same as those for the old; or, l

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since the monitors' ability to detect primary-to-secondary steam generator tube leakage has not been hampered.

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cammm l ANO-2 PC :93-8009 Replacement of Pneumatic Waste Gas Compressor Discharge Isolation Valves 2CV-2447 and 2CV-2457 with Manual valves This Plant Change replaces pneumatically-operated discharge isolation valves on the Gaseous Radwaste Compressors with manual globe valves. The original valves were ANSI 600 psi pressure rated and the replacement valves have an ANSI 1500 psi pressure rating.

Affected SAR Figures: 11.3-1, 8.3-56, 9.3-1 Table: 9.5-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an acciden: 5- malfunction of equipment important to safety evaluated in the Safety Analysis Report since the replacement valves have a higher pressure rating than the valves being replaced, the affected components are not classified as equipment important to plant safety, and no failure modes were identified which would result in an accident more severe than the previously-analyzed rupture of a waste gas decay tank; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the waste gas compressors are not considered important to safety and the only failure mode different than those previously analyzed would be an increased possibility of failure of a waste gas compressor due leakage back through the check valve which would result in an increase in cycling of the compressor that could occur in the absence of operator intervention.

Consequences of such a failure are bounded by the previously-analyzed rupture of a waste gas decay tank; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the operation of the Gaseous Radwaste System is not specifically covered in Technical Specifications.

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ANO 2 PC :93-8014 l

Provide Cooling To Radiation Monitors This plant change added ductwork to provide cooling air to the Containment Atmosphere Monitoring System (CAMS) units for day-to-day operations. The purpose of the change was to increase reliability and life of the CAMS units.

Affected SAR Figure: 9.4-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the change added cooling to units that have no effect on any equipment required for safe shut down of the plant; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the addition of cooling air had no safety function and was not used for safe shutdown of the plant; or, (iii) redgie the margin of safety as defined in the basis of any Technical Specification since the addition of direct cooling had no effect on the margin of Safety as discussed in the Technical Specification bases.

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ANO-2 PC 293-8016 Replacement Of Two Breaker Control Switches l

This plant change (PC) replaced two existing breaker control switches with new switches with a slightly different contact development. The switches are control room switches for Startup Transformer #2 feeds to buses 2A1 and 2A2.

The modification removed a potential failure mode related to " trip" and "close" signals existing at each breaker when the control switches were removed from " pull-to-lock."

Affected SAR Figure: 8.3-34 i

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(i) increase the probability of occurrence or consequence of an ,

accident or malfunction of equipment important to safety  !

evaluated in the Safety Analysis Report since installation of this mcdification has no impact upon the initiation of any accident nor were any new failure modes created for the 4160 '

VAC system or to any systein it supports; or, j (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety j Analysis Report since the modification is bounded by existing i' accident analyses; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since this modification did not impact margins of safety as defined by the bases. l l

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l ANO-2 PC :93-8019 "2PCV-5384 Pressure Sensing Line Alteration" This modification removed one of two pressure control connections for 2PCV-5384. This valve controls pressure in the Component Cooling Water (CCW)

System supply to instrument air compressors. It also added isolation valves for two instruments.

Affected SAR Figure: 9.2-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since only the CCW System, which is not credited in the mitigation of any accident, was affected and the modification did not change the function of the system or any component; or, j l

(ii) increase the possibility for an accident or malfunction of a j different type than any evaluated previously in the Safety Analysis Report since the system continues to function as i designed and the only possible accidents affected by the CCW l System have been previously evaluated; or, l 1

(iii) reduce the margin of safety as defined in the basis of any l Technical Specification since the portions of the CCW System impacted by the modification are not described in any of the Technical Specification bases.

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I ANO-2 PC 293-8022 DCPR 1 i

" Removal of the BMS to CVCS Supply Line"  !

This plant change removed a section of piping which connected the Boron  ;

Management System (BMS) to the Chemical and Volume Control System (CVCS) to l prevent contamination of the CVCS. I 1

1 Affected SAR Sections: 11.2.2.1, 11.2.2.2, 11.2.3, 9.3.4 Figures: 11.2-2, 9.3-4 I It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the modification has nc effect on equipment or operations which are important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the two concerned systems are not safety related and there is no connection between the removed piping and equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no safety margins are defined for transferring recycled water from the BMS to the CVCS.

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l ANO-2 PC :93-8037

' Heat Trace Upgrade

• This plant change documents the abandonment in place of 27 heat trace circuits in the Demineralized Water and Regenerative Waste systems. The design basis of these circuits was to prevent freezing and solidification in the lines of these two systems. However, the majority of these two systems are no longer in use. Those lines which are still in use are contained within heated rooms and do not require the circuits to maintain liquid flow.

Affected SAR Figures: 10.4-5, 11.2-3, 9.2-7 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an i

accident or malfunction of equipment important to safety l evaluated in the Safety Analysis Report since the abandonment of the heat traces had no impact on the initiation of any accident, did not affect any equipment or system required to mitigate an accident, and did not affect any equipment or system important to safety; or, l

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no safety related equipment was affected; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

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ANO-2 PC :93-8045 Instrument Piping Change This PC eliminated two isolation valves for one Containment Service Water Coil return line flow indicating switch.

Affected SAR Figure: 9.2-1 It was determined that these changes did not:

l (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the deletion of the redundant instrument isolation valves reduced the piping and components subject to failure and reduced the probability of the instrument lines clogging thus increasing reliability; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the change simplified the Service Water to Containment Coolers return pipe flow element sensing line routing; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since modification of the Containment Cooler Service Water return flow indicating switch sensing lines conforms to the piping specification and has been seismically i analyzed.

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ANO-2 PC :93-8046

" Spent Fuel Pool Underwater Lighting" This Plant Change replaced the 500 watt incandescent lighting in the Spent Fuel Pool with 1000 watt high pressure sodium vapor lighting.

Affected SAR Section: 9.5.3.1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new lighting system has been specifically designed for service in water with a high boron concentration or high temperature and does not contain sufficient quantities of corrosive material to cause significant damage to the Spent Fuel Racks, fuel pool, liner, Spent Fuel Pool Cooling System, fuel handling equipment, or fuel cladding; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since not enough corrosive material is contained within the new lighting system to cause structural damage to the fuel cladding or fuel pool liner or to initiate a failure of any equipment; or ,

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since quantity of corrosive material contained within the new lighting system is not sufficient to reduce the margin of safety concerning fuel storage.

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ANO-2 PC 393-8047

" Reactor Coolant Pump *B" Oil Level Transmitter Upgrade

• This change replaced existing Foxboro oil level transmitters on the "B" Reactor Coolant Pump (RCP) motor with Rosemont 1151 transmitters which contain internal amplifier electronics. The external amplifier electronics needed for the Foxboro transmitters ( 2 LY- 6012 and 2 LY- 6013 ) were removed.

The SAR text was corrected to delete reference to high level alarms which did not actually exist in the plant.

Affected SAR Section: 5.6.5.3 Figure: 5.5-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the changes to the oil level indication instrumentation maintain the original instrumentation function of indication and low level alarm and do not affect the flow coastdown characteristics of the RCP; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the proposed changes perform the same function as the equipment that was replaced and function in the same basic fashion as the original components; therefore, introducing no new failure modes; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there was no change to the RCP operating configuration for the various plant operating modes as a result of this change.

ANO-2 PC :93-8056 Upgrade Of Valve Parts For Unit 2 Turbine Bleeder Trip Valves (BTVs)

This plant change installed upgraded parts in two of the Unit 2 turbine BTVs, installed disc anti-rotation lugs in four other BTVs and installed instrument air isolation valves at each BTV to facilitate maintenance during power operations.

Affected SAR Figure: 10.4-3 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since these valve upgrdes did not change the system design, function or control logic for the turbine BTVs and no pressure retaining parts, safety related components or seismic class I piping systems were altered by this modification; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the original design, function and operation of the steam extraction system was not changed and the changes installed by this modification did not degrade any equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there are no Technical Specification issues or bases defined for the main turbine extraction steam system or the associated instrument air components and this change did not alter the original design basis of these components.

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ANO-2 PC 293-8060

" Installation of Main Chiller Taps" This change added blind-flanged tap connections with isolation valves to the main chilled water system to allow for the future main chiller replacement at power by the addition of a temporary chiller to supply necessary loads.

Affected SAR Figure: 3.2-4 It was determined that these changes did not:

(1) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the installation of blind-flanged taps with isolation valves did not alter the function, operability, or reliability of the main chilled water system and did not affect the function of any equipment important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the operation and function of the main chilled water system was unchanged by this modification andthe modification did not create any circumstances not bounded by previous evaluations; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the chilled water system is not part of the basis for any Technical Specification.

ANO-2 PC :93-8062 Emergency Penetration Room Ventilation System " Pull To Lock

• Annunciation Change I

I This plant change modifies the annunciation to the two fans on the Emergency Penetration Room Ventilation System so that one fan is designated as the standby and only the lead fan starts upon the initiation of the Containment ,

Isolation Actuation Signal (CIAS). This will allow the Radiological Dose I Assessment Computer System (RDACS) to reamin operable post-LOCA instead of l going into high flow alarm because both fans are running.

Affected SAR Section: 6.5.5 Figures: 6.5-1, 7.3-11 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the modification of the annunciator circuits for the pentration room ventilation fans has no impact upon the initiation of any accident and operation of the ventilation system has not been credited in the analysis of off-site dose consequences for any analyzed accident; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the system modified was not an initiator of an accident and there was no change in the ability of the system to function as required; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since these fans are not credited or addressed in the Technical Specifications or their bases.

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1 ANO-2 PC :94-8010 j Moisture Seperator Reheaters (MSR) Performance Monitoring Taps This Plant Change installed the test connections neccesary to perform a moisture carry over test to check the steam quality on the outlet of the MSR moisture separating chevrons. Two injection nozzles were installed on each MSR cross under pipe (MSR steam inlet from the main turbine) for a total of eight injection points where a tracer, such as lithium, can be injected into the steam flow. Additionally, a test connection was installed on each MSR on one of the shell side drain lines and one on the MSR drain tank outlet to the heater drain tank.

Affected SAR Figures: 10.2-4, 10.2-5 It was determined that these changes did not:

I (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the changes performed were to non safety related steam drain piping, did not affect any safety related equipment, and the installation was performed in accordance with the associated piping class specification; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the functions and operating modes of the Main Turbine were not affected by this Plant Change nor did this change affect any other equipment or system that is important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since it modified piping on the non safety related Main Turbine system and did not affect the operation or capabilities of any other system.

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SECTION III TEMPORARY MODIFICATIONS

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1 ANO-2 IM : 93-2-004

" Install RTDs on CEDM Cooling System Thermowells and CEDM Shrouds" This temporary modification (TM) installed Reactor Trip Devices (RTDs) in Control Element Drive Mechanism (CEDM) cooling coils thermowells and on CEDM shroud housing for performance monitoring. ,

This modification caused ANO-2 SAR Figures 3.2-4, 8.3-72, and 8.3-74 to be inaccurate for the duration of this temporary change.

It was determined that these changes did not: )

1 (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this modification added non-intrusive monitoring instrumentation which had no effect l on the function of any system or structure under any anticipated conditions and was not considered to be a potential accident initiator. This TM did not directly modify any safety-related l equipment nor did it have any indirect effects which could contribute to equipment malfunction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this modification installed passive instrumentation which had no effect on the function of any I systems, structures, or components and could not be postulated to be an accident initiator or cause an equipment malfunction; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification. This modification did not change the l capacity or function of any systems, structures, or components. l Therefore, no margins of safety as described in the Technical Specifications were changed.

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ANO-2 TM 293-2-009

" Temporary VCT Vent Path to 2T-10 Tanks" This tempolary modification provided a temporary flow path for gases in the VCT to be vented to one of the 2T-18 tanks (Gaseous Waste Decay Tanks). A 3/8" stainless steel tubing from valve 2PS-3 to each of the following drain valves on the 2T-18 tanks: 2GZ-2476A, 2GZ-2477A, and 2GZ-2478A was installed.

This modification caused ANO-2 SAR Figure 9.3-2 and 11.3-1 to be inaccurate for the duration of this temporary change.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the Gaseous Waste System is not required for safe shutdown or the reactor and no equipment important to safety is impacted by this TM; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no equipment important to safety is impacted by this TM; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

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l ANO-2 TM 193-2-012, Revision 1

" Capping of 2CV-4816 and 2CV-4817's Packing Leak Of f Lines" This temporary modification removed letdown control flow valves 2CV-4816 and 2CV-4817's packing leak off line from the valve and installed a welded cap in the leak off line's place.

This modification caused ANO-2 SAR Section 9.3.4.13.14 and Figure 9.3-4 to be inaccurate for the duration of this temporary change.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since 2CV-4816 and 2CV-4817 are redundant components that may be isolated from the letdown system or each other if required. The valves have no safety function and are normally isolated from the CVCS system during an accident. Capping the packing leak off lines does not have any effect on safety-related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since 2CV-4816 and 2CV-4817 are nonsafety-related components. Capping the packing leak off line in the 2CV-4816 and 2CV-4817 valves does not change the operating characteristics of the valves or the letdown system enough to create a new or different type of equipment malfunctions or accidents than those discussed in the SAR.; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the Technical Specification bases do not define any margins of safety for the 2CV-4816 and 2CV-4 817 letdown flow control valves. Capping the packing leak off lines does not change the characteristics of the valves and will not affect any safety margins.

umme ANO-2 TM 393-2-013

" Temporary Modification to CPC B and CEAC #1 Indications of CEA #33 Position" This temporary modification rendered the RSPT #1 indication for CEA 33 to CEAC 1 and CPC B inoperable by use of a dummy input signal vice the RSPT to indicate a constant near full out position.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. This TM only affects the indication of CEA 33 position provided to CEAC 1 and CPC B, not the method by which the CEA is held or moved. The ability of the CPC/CEAC to provide protection against anticipated operational occurrences is not degraded; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. This TM only affects the CEA position sensor inputs to CEAC 1 and CPC B. The failure of a CEA sensor and the failure of a CEAC have been previously evaluated in the SAR.

Failure of a RSPT to a CPC results in the CPC using a value essentially equal to the "dammy" RSPT position being installed for any calculations performed by the CPC. The possibility of other accidents or equipment malfunctions is not created by the temporary modification since no other components or systems are impacted; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification. The response of the CPCs/CEACs to all required CEA events is maintained even with this modification in place. Prompt operator action per the ACTION statements of Technical Specification LCOs are also credited in the Technical Specification bases as limiting the effect of CEA misalignments.

None of these actions are affected by this temporary modification.

Thus, the margin of safety as defined in the basis for any Technical Specification is not reduced.

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ANO-2 TM :93-2-014

' Containment Building Sump and Drain Temporary Modifications" This temporary modification evaluated the four items that will make temporary modifications to the containment building drains and sump to ensure that unwanted materials will not enter the samp. The four items are: 1) placing screened covers over the 2HCD-1-4" drain headers that enters the containment sump; 2) placing plumber's plugs into the two drains on elevation 405'-6" i around the reactor vessel head stand if there are no screens in these drains;

3) the installation of steel plates that will be bolted to the grating that makes up part of the sump walls; 4) the use of small sections of screen material and RTV to patch and repair small holes and tears as needed.

This modification caused ANO-2 SAR Figure 11.2-1 to be inaccurate for the duration of this temporary change.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since installing part or all of this TM will help to prevent foreign material from entering the sump and will increase the ability of the containment sump to perform its design function; or, i (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. Repairing the sump screens within the guidelines of this TM has no impact on accident scenarios since the screens act to filter out large particles from the water; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

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l ANO-2 TM 94-2-006

" Temporary Power for Fire Protection Panel 2C341" During the 2R10 refueling outage, an outage of the non-vital 120 VAC Green I Train was necessary. This required the de-energizaion of panel 2Y4 which  !

supplies the fire protection panel 2C341. This Temporary Modification i supplied power to panel 2C341 from the Red Train panel 2Y3 during this down I time.

SAR Figure 8.3-19 was temporarily invalidated during the duration of the Green Train outage as a result of this Temporary Modification.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since power was maintained to the Fire Detection and Alarm panels, only non-vital 120 VAC panels were involved, and the temporary power source met NFPA requirements; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since only non-vital 120 VAC panels were involved and no equipment important to nuclear safety was affected; or, (iii) reduce the margin of safety as defined in *,he basis of any Technical Specification since the Fire Detection and Alarm panels are not addressed in the Technical Specifications.

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ANO-2 TM 94-2-009 Bypassing hand switches for Reactor Coolant System' (RCS) temperature indicators and Reactor Coolant Pump (RCP) differential pressure indicators.

This Temporary Modification (TM) bypassed twelve hand switches in the circuitry of indicators in the control room control panel. Operation of these hand switches had been causing signal spikes on other loops. Four of these hand switches were used to select between loop 1 and loop 2 on the RCS cold leg temperature, four were used for the same purpose on the RCS hot leg temperature and four were used to select between 'A' and 'B' transmitters on the RCP differential pressure indicators. This TM was installed to bypass the switches while permanent dual channel indicators are procured.

During the time when this TM is in effect, the following parts of the ANO-2 Safety Analysis Report will be inaccurate: Section 5.6.1.1; Section 5.6.1.2; Figure 5.1-3; Figure 5.5-2; Table 7.2-5; Table 7.5-1; Table 7.5-3; Figure 7.2-16b; Figure 7.2-29; FMEA Diagram No.3; It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the channel check of RCS hot leg and cold leg temperatures will be carried out by each shift checking the CPCs. In addition each shift is required to perform a channel calibration of RCS flow rate above 70% rated thermal power. This is being accomplished using calorimetric calculations with RCP differential pressure indicators serving as a backup; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this TM does not involve a test of experiment not described in the SAR that could adversely affect safe operation of the plant; or, (iii) reduce the margin of safety as defined in the basis of any technical specification since the activities involved with this TM are considered routine activities that, when performed correctly, will not adversely affect any safety related  :

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1 ANO-2 TM :94-2-011 l

Disabling Start Up Channel (Neutron Flux) Local Indications l This Temporary Modification ('ni) removed the local indicators of start up channel neutron flux located on the signal processors from service by interrupting power to them. Indication remains available at the control panel (2CO3) in the control room for each channel. Heat by the local indicators, is believed to contribute to intermittent problems with the startup channels during refueling outages. This TM is allowing engineering evaluation of of this postulated effect.

This modification causes section 7.7.1.5 in the ANO-2 SAR to be inaccurate for the duration of this temporary change.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this temporary modification involved only local indications and recorders (not those in the control room) Since the startup channels perform no direct accident mitigation functions and the temporary modification increased equipment realiability by reducing the heat produced in the signal processor drawer; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this TM did not remove any existing indications or recorders used by control room operators and since this temporary modification affected only the local indications from the signal processor; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the startup channels, with or without this temporary modification, provide no margin to j safety as defined in the bases for any Technical Specification.

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ANO-2 TM 94-2-013

" Temporary Power for Fire Protection Panel 2C341' 1 During the 2R10 refueling outage, an outage of the non-vital 120 VAC Red Train was necessary. This required the de-energization of panel 2Y3 which supplies the fire protection panel 2C341. This Temporary Modification supplied power to panel 2C341 from the Green Train panel 2Y4 during this down time.

SAR Figure 8.3-19 was temporarily invalidated during the duration of the Red Train outage as a result of this Temporary Modification.

It was determined that these changes did not: J (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since power was maintained to the Fire Detection and Alarm panels, only non-vital 120 VAC panels were involved, and the temporary power source met NFPA requirements; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since only non-vital 120 VAC panels were involved and no equipment important to nuclear safety was affected; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the Fire Detection and Alarm panels are not addressed in the Technical Specifications.

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ANO-2 TM :94-2 022 Startup Transformer #3 Synch Switch Contact This Temporary Modification (TM) substituted a spare contact in place of a suspected bad contact on startup transformer #3 synch. switch 152-ll3/SS. The contact in question is used in the interlock / trip logic circuit of breaker 152-111.

During the time when this TM is in effect, ANO Unit 2 Safety Analysis Report Figures 8.3-33 and 8.3-21 will be inaccurate.

i It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the modification presented no new failure modes to the 4160 Vac system or to any system it supports and installation of this modification has no impact on the initiation of any accident; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the modification is bounded by existing accident analyses; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the modification does not impact any margin of safety as defined by the bases.

ANO-2 TM :94-2-025 Reactor Coolant System Cold Leg Temperature Transmitters 2tt-4611-1 and 2tt-4711-2 Wiring Changes The purpose of this Temporary Modification ('DH) was to provide a more accurate temperature input to the Core Protection Calculators (CPCs). Due to slight differences in various mechanical connections to the Resistance Temperature Detectors (RTDs) red and white leads connected to the same point at the RTD were found to have different resistances. These different resistances introduced errors in the RTD output that caused an out of specification condition when performing cross-channel checks. This TM swapped leads to correct this condition until the transmitters are replaced by a Design Change Modification during the next refueling outage.

This modification changed information in the ANO-2 SAR. Figure 7.2-16a and FMEA diagram number 3 will be inaccurate for the duration of this temporary change, It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since these temperature detection loops provide input to the CPCs. The CPCs, which remained unchanged by this temporary modification, are designed to trip on failure of their sensor inputs and the failure of these RTD loops cannot cause the CPCs to malfunction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since failures of the temperature detection loops cannot cause the CPCs to fail or respond in a manner not previously evaluated. No other plant equipment would be affected by a failure of these temperature loops; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since this temporary modification did not change the response time of the RTDs so the response time of the instrumentation strings also remains unchanged. The TM did not modify the number of channels that are required to ,

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ANO-2 TM :94-2-26 l

I Reactor Coolant Pumps (RCP) 0.1 Lift Pump Speed Switch This Temporary Modification (TM) eliminated the auto start feature of the 'D' RCP motor oil lift pump for the condition when the (RCP) speed drops below 90%. The speed switch was not reacting correctly and tended to chatter the relay. This could have led to failure of the lift pump by rapidly starting and stopping it. The TM will stay in place until there is an outage of sufficient duration for permanent repair. The TM does not affect the ability of the lift pumps to start upon loss of power to the RCP motor.

During the time this TM is in effect section 5.6.5.6 and table 5.5-1 of the ANO-2 Safety Analysis Report will be incorrect.

1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since failure to provide lift oil during RCP motor coast down would not result in breach of the Reactor Coolabnt System pressure boundary or cause a catastropic failure of the motor ; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the main function of the switch is to ensure that lubrication is provided to the RCP motor during coast down and start up. Manual control of the lift pump remains available and RCP motor bearing failure has been previously evaluated; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

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ANO-2 WP 22409.431 ,

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" Shutdown Cooling Piping Flush' This workplan was used to reduce area radiation levels in the vicinity of shutdown cooling piping by flushing from the Refueling Water Tank (2T-3) to the Auxiliary Building Sump using a drain upstream of the SDC Temperature Control valve (2 CV- 5093 ) on elevation 317'.

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. This workplan directs controlled draining of water from the Refueling Water Tank to the Auxiliary Building Sump through the LPSI Header and shutdown cooling piping. None of the accidents evaluated in the SAR can be initiated by this process. The malfunction of safety injection system equipment is mitigated by the availability of redundant equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the types of accidents evaluated in the SAR are determined by design features not affected by the performance of this workplan. The SAR includes the evaluation of the failure of active and passive safety injection components.

The performance of this workplan will not create the possibility of any other type of ewuipment malfunction. Therefore, the possibility of a malfunction of equipment important to safety of a different type is not created; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification. The performance of this workplan will not reduce the sufficiency of the Emergency Core Cooling System to limit peak cladding temperatures within acceptable limits for all postulated LOCAs. Therefore, the margin of safety as defined in Technical Specifications is not reduced.

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ANO-2 WP 2409.433 Implementation of Ethanolamine - Unit 2 This work plan provided instructions for converting from morpholine to ethanolamine (ETA) as a pH control additive in the Unit 2 secondary system.

Affected SAR Sections: 10.3.5, 10.4.6, 10.4.7.2, 9.3.2.1 Figures: 10.2-3, 10.4-2, 10.4-3, 10.4-5 Table: 10.3-2 It was determined t these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysie Report since converting from morpholine to ETA as the pH control additive in the secondary system improved the quality of the secondary water and steam thereby reducing corrosion of the of the steam generators and related components; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the concern with using chemical additives was limited to the corrosive effects on the materials and based on the Materials Compatibility Evaluation and supporting documentation it was determined that ETA would have no detrimental effect on materials used in the secondary system ; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the conversion from morpholine to ETA improved the quality of the secondary water and steam thereby had no effect on the margins of safety as defined in the bases of the Technical Specifications.

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SECTION IV MISCELLANEOUS EVALUATIONS i

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I ANO-2 SSCA/FRA CLARIFICATION

• Fire Protection Program Description Clarifications

• This modification deleted the Safe Shutdown Capability Assessment (SSCA) from the Safety Analysis Reports (SAR) and revised the description of the Fire Hazards Analysis (FHA) to eliminate reference to its engineering calculation number.

This modification caused a revision to QAMO Append x B, Seciton 2.4 and every page of the FRA.

Affected SAR Sections: 9A.7, 9B, 9C It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no plant equipment or method of operation of plant equipment is modified by these changes, no saf ety-related equipment is affected, and the method of review of the SSCA and FHA when developing modifications is not affected; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since these administrative changes do not cause changes to any plant system or its method of operation. No plant processes or equipment have been modified; or, (iii) reduce the margin of safety as defined in the basis of any -

Technical Specification. Since no physical changes are being made, the Technical Specification bases related to any shutdown equipment remains unaffected.

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ANO-2 CR 22-91-0514

• Emergency Diesel Generator Valves 2ED-32A/B Position Change" This changes alters the normal valve position for 2ED-32A/B from open to closed to isolate the keep warm water that flows through the scavenging air coolers. This prevents the cross flow problem that occurs during engine operation. It does not impact operation of the engines or standby readiness.

Affected SAR Figure: 9.5-8 It was determined that these changes did not:

(i) increase the probability or occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this change closes two valves that are only needed in diesel standby conditions when ambient room temperature is below 40 degrees In the installed configuration, temperature is maintained above that point by room heaters and monitored to allow operator intervention if room temperature falls below 45 degrees; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since closing the subject valves has no effect on any component or system other than the diesels and does not adversely impact diesel operability because the diesel engines are located in closed, heated , monitored rooms; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the operability of the diesel engines are not impacted by the valve position change.

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ANO-2 CR :2-91-0557  !

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"ANO-2 Safety Analysis Report" A new Control Room Habitibility analysis was performed to include ESF valve and pump seal leakage outside of containment.

Affected SAR Sections: 15.1.0.6, 9.4.1.1.2 Table: 15.1.13-2 It was determined that these changes did not:

l (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no equipment was affected and dose results were within limits established by General Design Criteria 19 and Standard Review Plan 6.4; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no system, component, or equipment has been affected; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the results of new analysis were within the limits set forth in the bases of the Technical Spec 3fications.

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ANO-2 CR C-93-0076

• Document As-built Location of Smoke Detector QS-7905" This change corrects the location of smoke detector QS-7905 on two Safety Analysis Report figures to the actual as-built location.

Affected SAR Figures: 9.4-1, 9.4-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important-to-safety evaluated in the Safety Analysis Report since QS-7905 is non-Q, not important-to-safety, and its as-built location does not affect any important-to-safety component's ability to function; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the location of QS-7905 does not affect any important-to-safety component's ability to function; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no Technical Specification basis exists that defines a safety margin related to the operation of QS-7905 for smoke detection or Control Room isolation.

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ANO-2 CALC : 85S-00002-01 Revision 7 ANO-2 Diesel Generators Loading Calculation The Emergency Diesel Generator (EDG) load calculation was revised to incorporate all load changes up through refueling outage 2R10.

Affected SAR Table: 8.3-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the load additions documented ir. the calculation revision presented no new failure modes and did not alter the previously analyzed response of the EDGs when performing their design bases functions and no new equipment failure modes were presented by the EDG loading additions; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the load additions did not exceed the ratings of the EDGs, and the additions are bounded by existing accident analyses; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since there are no margins of safety ,

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ANO-2 Calculation: 90-E-0096-12, Revision 1

" Reload Analysis Report for Cycle 10" This revision justifies the extension of ANO-1 Cycle 10 beyond initial expected full power capability. This calculation will support a 490 Effective Full Power Day cycle burnup.

Affected SAR Sections: 4A.1, 4A.5.1.1 x It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no changes to plant equipment or operations were made, the function of safety related equipment was not altered, and no change occurred to any radiological release rate or mechanism; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no failure modes of safety related equipment were affected, no accident initiators were impacted, and the manner in which the unit operates was not altered; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no margin of safety has been established which relates to fuel cycle burnup.

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I ANO-2 CALC 291-D-2003-01

" Emergency Diesel Generator (EDG) Capacity Ratings" Revision 2 to this calculatio2 incorporated a vendor report for Emergency Diesel Generator capacity rating in order to more cleary define the load limitations of the ANO-2 EDGE at elevated service water temperatures.

Affected SAR Section: 8.3.1.1.9.9 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since no physical change was made to the plant and actions described and assumed in the Safety Analysis Report accident analyses were not altered or degraded; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the function of thc EDGs was not impaired, no new failure mechanisms were introduced, and no new hazards were created as a result of there being no physical changes made to the plant; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no Technical Specification bases were affected.

ANO-2 CALC :93-E-0048 Cycle 11 Reload Analysis Report - Unit 2 This change deleted the Cycle 10 Reload Report and replaced it with the Cycle 11 Reload Report. The ANO-2 Cycle '.1 Reload Analysis Report describes the fuel management, its associated analysis, and testing to support the operation of the cycle. The report is intended to be comprehensive in describing the impact of the reload upon all relevant aspects of the plant and its operation. The Cycle 11 design differs from that of the previous cycle in three ways: a longer fuel cycle, smaller fresh fuel batch size, and a different welding technique on new fuel assembly grids. The change was evaluated specifically in the areas of mechanical design, core neutronics and the Ur..cntrolled Boron Dilution Event .

Affected SAR Section: 4A It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new core design did not require any changes concerning equipment availability or failure modes, no equipment or operational change was caused and the function and duty of equipment important to safety was not altered; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the new core design did not require any new equipment or alter the way in which the plant operates, no initiators to any analyzed accidents were impacted, and no changes in the failure modes of equipment important to safety were assumed in the analysis; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the changes either did not affect or were bounded by existing marginr l

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ANO-2 CALC 293-E-0048 Revision 1 Unit 2 Cycle 11 Reload Analysis Report Linear Heat Rate Revision This revision of the Unit 2 Reload Analysis Report revised the Linear Heat Rate limit from 12.1 kW/ft to 12.8 kW/ft based on an updated Large Break Loss of Coolant Accident (LOCA) analysis.

Affected SAR Section: 4A It was determined that these changes did not:

(1) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since unit operation will remain consistent with Safety Analysis assumptions with accident consequences bounded by existing analysis and the change did not alter the manner in which the unit is operated or involve any equipment changes; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the re-analysis was shown to be consistent with 10CFR50.46 requirements, no accident initiatorL were impacted, and no changes in f ailure modes of equipment important to safety were assumed in the analysis; or (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the bases do not discuss how large the margin to the peak cladding temperature must be and the re-analysis resulted in a maximum value which was the same as previously accepted by the NRC.

I ANO 2 94-R-2003-01 Cycle 11 Core Operating Limits Report - ANO 2 .!

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The Core Operating Limits Report (COLR) provides the cycle-specific core operating limits for cycle 11. The report was prepared in accordance with tne requirements of ANO-2 Tecnical Specification 6.9.5 and in accordance with the NRC approved methodologies specified in this Technical Specification.

Cycle-specific values have been removed from the Technical Specifications and placed in the Safety Analysis Report.

Affected SAR Section: 4B It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since only the cycle 11-specific core operating limits for Azimuth Tilt and ASI were revised. The revisions were more restrictive than what was previously allowed and ensure that the unit is operated ~.

in a manner consistent with the assumptions used in the Safety Analysis; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the changes did not involve any changes in equipment and did not alter the manner in which the unit is operated; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the ranges for the cycle 11 operating limits are smaller and completely within the operating limits for cycle 10.

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1 ANO-2 94-R-2003-01 Revision 1 Cycle 11 Core Operating Limits Report (COLR) - ANO 2 Revision 1 of the Cycle 11 COLR revised the Linear Heat Rate Limit from 12.1 kW/ft to 12.8 kW/ft to provide adequate COLSS linear heat rate margin for full power operation based upon a revised ECCS analysis.

Affected SAR Section: 4B It was determined that these changes did not:

(i) increase the probe.bility of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since only the Cycle 11-specific core operating limit for Linear Heat Rate was revised, and this revision did not involve any changes in equipment and did not alter the manner in which the unit is operated; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no initiators to any accident were impacted and no change in the failure modes of equipment important to safety was assumed in the analyses; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the revision will ensure that the unit is operated in a manner that is consistent with the assumptions used in the Safety Analysis, i

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L ANO-2 DRN :92 01022 Change Normal Valve Position On P&ID Thin Drawing Revision Notice initiated a change in the normal position of a norien isolation valvo used for condenaato transfer to the boric acid mix tank on the P&ID to agree with the lineup in the syntem operating procedure.

Affected SAR Figure: 9.2-7 It wan determined that these changen did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the necondary boric acid system is not equipment important to nafety and cannot affect the consequences of a malfunction of equipment important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the nystem is not important to nuclear aafety; or, (iii) reduce the margin of safety ao defined in the basin of any Technical Specification nince the secondary boric acid nystem

.in not described in the Technical Specification banin.

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t ANO 2 DRN 392-04636

" Seal Oil Instrumentation" This change corrects a drawing containing instrumentation lines to the flydrogen Seal Oil System differential pressure and gas pressure instruments to -flect the actual plant configuration.

Affected SAR Figure: 3.2-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the seal oil instrumentation involved in the drawing change can neither initiate nor mitigate any of the accidents previously evaluated in the Safety Ananysis Report, and the change did not involve any safety related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the existing configuration has the same failure modes as the previously depicted configuration; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the equipment associated with the change is not mentioned in the Technical Specification bases.

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" Generator Gas Pressure Switch Root Valve Position" l This change alters the indicated normal position of the Generator Gas System pressure switch root valve (2 GG- 9 7 59 ) from closed to open in the P&ID to reflect a change to the associated operating procedure.

Affected SAR Figure: 3.2-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the instrument root valve can neither initiate nor mitigate any of the accidents previously evaluated in the Safety Analysis Report and does not affect any equipment important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since maintaining the valve open introduces no new failure modes; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the equipment involved in this change does not affect the Technical Specification bases.

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ANO-2 DRN :93-01580 Service Water System Operations l

l Revision 36 to procedure 2104.029 changed the normal valve position for the Service Water supply and return valves for the hydrogen analyzers to "open" in order to accomodate an automatic start without local valve manipulations. l The 50.59 determination for the procedure revision supplemented by a seperate evaluation for Drawing Revision Notice (DRN) 93-01580 were written to evaluate changes to the P&ID.

Affected SAR Figure: 9.4-4 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since none of the accidents evaluated in the SAR can be initiated by the position of these valves; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this change did not create the possibility of any type of equipment malfunction; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the position of these valves does not contribute to any margin of safety defined in the basis for any Technical Specification. ,

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ANO-2 DRN : 93-01733 Circulating Water System This drawing revision notice corrected P&ID M-2209 sheet 1 to show the correct operating positions for four drain valves and a sample valve, changed a sample point designator to a valve, showed the sodium bromide / sodium hypochlorite booster pump as being abandoned in place and showed the circulating water pump bearing water supply valves in their as built configuration.

Affected SAR Figure: 10.4-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since none of the valves are accident initiators, the Circulating Water System is non-Q and is not a system important to safety and operation of any of these valves will not affect a system important to safety; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the Circulating Water System cannot be an accident initiator; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the change did not affect any margin in the Technical Specification bases.

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ANO 2 DRN 93-11327 "As-Built of M-2216 Sheet 1 (Turbine Lube Oil P&ID)*

This documents the revision of sheet 1 of the Turbine Lube Oil P&ID. A valve and vent lines were added to the drawing and valve types were corrected in order to accurately reflect the as-built configuration of the Turbine Lube Oil system.

Affected SAR Figure: 3.2-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the lube oil l valve and vent lires which were added to the P&ID cannot be the initiator of any accident previously evaluated. They also cannot serve to mitigate the consequences of these accidents.

Nor can they affect any safety related equipment or influence the failure modes of this equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the design of the valve and vent lines is consistent with established standards of this plant and no new failure modes were created; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no Technical Specification bases address the components which were added to the drawing.

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ANO 2 DRN :94-01436

" Revise P&ID M-2219 Sh. 2 to Remove Tamper Switch 2ZS-3287 from Drawing" l

The design drawing M-2219 Sh. 2 was revised to delete the tamper switch 2ZS-3287 from the normally closed fire water valve 2FS-106.

Affected SAR Figure: 9.5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since tamper switches are not required to be installed on normally closed fire water valves and no evaluated accident addressed tamper switches; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since tamper switches ensure that fire water flow paths are open and 2ZS-3287 was installed on a normally closed valve; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the only margin of safety concerning the Fire Protection System addresses the capability to isolate a section of the system in the event of a line break and this capability was not decreased by removing the tamper switch.

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ANO-2 DRN 294-01582 Service Water Piping and Instrument Diagram (P&ID) Note This change added a note to the Service Water P&ID to provide information to the operators that the Emergency Cooling Pond (ECP) outlet valve to the Service Water system is pinned open when the ECP is required for operation.

Affected SAR Figure: 9.2-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the additional drawing note provided information that ensured the operators were aware of the status of the ECP outlet valve and reduced the possibility of the valve being damaged during manual operation; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the types of accidents evaluated in the SAR are determined by design features which were not affected by this drawing change; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the addition of this note to the drawing does not affect to any margin of safety defined in the basis of any Technical Specifications.

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ANO-2 LDCR :

'ANO-2 SAR Table 10.4-4" This review justifies a change to the ANO-2 SAR that will more j accurately reflect condensate pump design data.

Affected SAR Table: 10.4-4 l 1

It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the revision does not affect equipment used to mitigate the consequences of an accident and since the condensate pumps are not safety related; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since this revision does not change the operation of the condensate pumps or associated equipment and does not add or modify any equipment important to safety; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the actual and design capacities shall remain unchanged as a result of this revision and no Technical Specification basis margin is affected.

ANO*2 LDCR :

" Disc Material Change" This modification allowed the requirement of valve material to be a design approved, low cobalt hard surfacing material equivalent to stellite instead of requiring only stellite.

Affected SAR Section: 5.2.1.3 Table: 5.2-3 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report. The type of hardened seating surface will not influence the probability of an accident since the type of valve, its intended function, and its seating surface have not changed in their design or function. Since the new material can be evaluated as equal to the original material, the valves using the new seating material will not be affected in their design function and the consequences of an accident will not be affected by this change; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report. There is no accident scenario that is influenced by this material change since the function and design of the valves have not changed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

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ANO-2 LDCR :

Emergency Plan, Revision 16 Numerous changes to the Emergency Plan were referenced by this 10CFR50.59 Review, Reference in the SAR to Petit Jean airport was deleted since it is no longer operational.

Revisions to the QAMO, as well as SARs, were required as a result of these changes.

Affected SAR Section: 2.2.1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the Petit Jean Airport had no impact on the malfunction of plant equipment or the consequences of a malfunction; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the airport had nothing to do with plant equipment; or ,

(iii) reduce the margin of safety as defined in the basis of any Technical Specification since no Technical Specification bases address the Petit Jean Airport.

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I ANO 2 LDCR :

" Evaluation of Health Physics Changes Required for Revised 10CFR20 Implementation" This evaluation brought ANO documents into compliance with new terminology, format, and requirements contained in the revised 10CFR20.

SEE THE CORRESPONDING UNIT 1 LDCR FOR THE ACTUAL 50.59

SUMMARY

Affected SAR Sections: 11.2.9, 11.5.1, 11.5.6, 11.6.2, 11.7, 12.1.1, 12.1.1.3, 12.1.2.2, 12.1.2.4, 12.1.2.9, 12.1.5, 12.1.6, 12.2.6, 12.3.3.1, 12.5, 15.1.13.4, 3.1.6, 3.2.1.1, 5.2.8.1.3, 5.5.1.3, 9.1.4.3.3, 9.3.2.2.4, 9.4.1.3 Tables: 3.2-1, 3.2-6 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the administrative changes associated with 10CFR20 implementation can be neither the cause nor the mitigator of any accident and do not affect the operation of safety related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since these changes, which are administrative in nature, are not related to the cause of any accident and do not impact any safety related equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the administrative changes do not alter the meaning or intent of the Technical Specification bases, j l

T ANO-2 LDCR "P&ID M-2219 Sh.2" This change revised the P&ID to show the isolation valve for the Deluge System, 2FS-106, as normally closed.

Affected SAR Figure: 9.5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since closing this valve will prevent inadvertant actuation of the system in order to prevent flooding and water i.mpingement on safety related equipment; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the Deluge System will be isolated and inadverta t actuation will be prevented; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the only Technical Specification basis which addresses the Deluge System is concerned with the capability to isolate the system, which will remain unchanged.

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4 ANO-2 LDCR :

. " Quality Assurance Manual Operations" a

Revision 15 to the QAMO reflects reorganizational changes which have been 1

made at ANO.

Affected SAR Section: 9.5.3.5.1 j

It was determined that these changes did not:

1 (i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the reorganization

. and title changes do not relate to any accidents evaluated and do not affect the design basis; or, 1

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety

Analysis Report since no new equipment is being introduced and no modifications to existing equipment are being made; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since reorganization does not affect any margin of safety.

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i ANO-2 LDCR :

' Unit 2 Reactor Coolant Pump Seal Stationary Face Material Change" This modification revised the material for the Unit 2 reactor coolant pump seal stationary face to allow a slightly different type of carbon / graphite material.

Affected SAR Table: 5,5-1 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the new material is equal to or better than the original material. The design function of the reactor coolant pump is not affected. The strength of the new material is greater than and the wear resistance of the new material is nominally equal to the original material; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since, for all practical purposes, the new and old material are identical. This change only influences the reactor coolant pump seal and the change in material of the stationary face will not affect its ability to operate as designed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the level of detail in the Technical Specifications bases is inadequate to be influenced by this material change.

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ANO-2 LDCR :

" Schematic Diagram 480 Volt Load Center Transformer Feeder ACBs*

This review justified the deletion of design drawing E-2104 sh I from the SAR and its replacement with E-2104 sh 1A and 1B.

Affected SAR Figure: 8.3-45 Table: 1.7-2 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since only the format of information contained in the SAR was changed; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no physical changes were made to plant equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification.

ANO-2 LDCR

" Software Change Request #SPDS.126" This revision to the Safety Parameter Display System (SPDS) displays changed the arrangement of menus to provide the operator with quicker access to information.

Affected SAR Section: 7.6.2.5.3 It was determined that these changes did not:

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1 (i) increase the probability of occurrence or consequence of an acciden* or malfunction of equipment important to safety evaluated in the Safety Analysis Report since this modification increases the probability of operator detection of degrading conditions and *.aking action to prevent accidents. The probability of detecting conditions which could cause equipment

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malfunction is increased and the probability and consequences of equipment malfunctioning is decreased; or, (ii) increase the possibility for an accident or malfunction of a different type tnan any evaluated previously in the Safety Analysis Report since the way the plant is operated and physical equipment condition is not changsd. Available SPDS indications and the physical ties between the SPDS and equipment are not altered; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since SPDS display menu layout is not a consideration in any Technical Specification bases.

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ANO-2 LDCR :IRF-7073 Covers For Floor Openings In The Intaku Structure i

A prior design change package made changes to the ANO-2 Intake Structure including addition of grating to two of the three access hatches. A i pre-existing solid checker plate cover was used for the third hatch. SAR changes identified in the design change package did not accurately describe I

the change. This IRF changes the SAR to reflect the as-built condition that currently exists.

Affected SAR Section: 9.2.1.3 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Anolysis Report since the floor openings in the intake structure serve a mitigating function in the event of service water or other component rupture and the grated ,

openings are adequate]y sized to prevent excessive accumulations of water. Also, all safety related equipment in the Intake Structure is located on the second floor, well above the postulated levels occurring due to worst case pipe rupture; or, (ii) increase the possibility for an accident or malfunction of a

, different type than any evaluated previously in the Safety Analysis Report since gratings installed in the two openings are no different from those previously esaluated in the SAR and the covering of the third opening with checker plate will result in -o new failure modes; or, (iii) redd .he margin of safety as defined in the basis of any Technical Specification since the changes made are below the level of detail in the Tech Spec bases and no margins are based on these changes.

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" Add Drain Valves to P&ID M-2232" This PEAR revised L&ID M-2232 to include the Waste Management System (WMS) drain valves 2SI-1098 and 2SI-1099. These valves, which were inadvertantly left off of the drawing, isolate the Low Pressure Safety Injection mechanical pump seals from the WMS drain line funnels.

It was determined that these changes did not:

(1) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since these valves, which are installed in a non-safety related system, are procedurally maintained in the normally closed position, malfunction of the valves would not cause loss of integrity of a safety related system or seismic category 1 structure or system, and the likelihood of inadvertant closure of these valves during LPSI pump operation resulting in leakage into the Engineered Safety Features pump rooms, an accident which has already been analyzed, will not be increased by adding these valves to the P&ID; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since inclusion of these valves on the P&ID WMS drain lines does not create any circumstances different from those considered by previous Licensing Basis Document analysis; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the Technical Specifications do not address any safety related design bases for these valves,

i ANO-2 PEAR 291-7324

" Update M-2216 Sh. 1*

A pre-existing gate valve was identified on the drain line off the Turbine Oil Tank (2T-165) Loop Seal Header by field verification. The valve was not depicted on the P&ID for that area of the system, M-2216 sh. 1. The valve was assigned the tag number 2LO-366 and placed on the drawing.

Affected SAR Figure: 3.2-1 l

I It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since 2LO-366 does not perform a safety function and is not involved in the  !

mitigation of any evaluated accident; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the valve performs no safety function and interacts with no safety related equipment; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the addition of 2LO-366 to the P&ID does not affect the margins of safety contained in any basis of the Technical Specifications.

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ANO-2 PEAR 393-0423

" Circulating Water valve 2CW-32" This Plant Engineering Action Request Documented the removal ' flow element 2FE-1260 from the Circulating Water System and its replacemea sith a 3" ball valve numbered 2CW-32.

Affected SAR Figure: 10.4-1 It was determined that these changes did not:

(i) increase the piobability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the function of the non-safety related Circulating Water System was in no way altered or impeded and no existing safety related equipment or system was impacted; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety A ,1ysis Report since the function of the non-safety related Circulating Water System remained the same and the f ailure modes were not changed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since no margin of safety concerning the Circulating Water system is delinaated in any basis of the Technical Specifications.

l ANO 2 LIR L93-0041

' Revision of ANO-2 SAR Sections that Describe the Plant Makeup and Domestic Water System" The response to the referenced LIR revised the Unit 2 SAR to provide an accurate description of the Plant M.skeup System with demineralized water being supplied by a vendor.

Affected SAR Sections: 9.2.3, 9.2.3.1, 9.2.3.2.1, 9.2.3.2.2, 9.2.3.4, 9.2.3.5, 9.2.4.2, 9.2.6, 9.2.6.2, 9.2.6.3, 9.2.6.5 It was determined that these changes did not:

(i) increase the probability of occurrence or consequence of an accident or malfunction of equipment important to safety evaluated in the Safety Analysis Report since the Plant Makeup System performs no safety related functions, a failure of equipment, piping, valves, or controls in this system can not af fect equipmen' important to safety, and all required functions of the system have been maintained; or, f N

(ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since no function of the Plant Makeup System has been altered or changed; or, (iii) reduce the margin of safety as defined in the basis of any Technical Specification since the volume setpoint of the condensate storage tank as addressed in Technical Specification 3.7.1.3 has not been changed or altered and no other nargins of l safety for this system have been defined.

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I nummer ANO-2 LIR :L93-0056

" Boric Acid Corrosion Affecting Compatability with External Insulation and Environmental Atmosphere

• l This Licensing Information Request resulted in a revision to the ANO 2 SAR which clarified the recommendations on material selection for insulation used in the Reactor Coolant Pressure Boundary and its effects on corrosion induced by reactor coolant on ferritic stainless steels.

Affected SAR Section: 5.2.3.3 It was determined that these changes did not:

(i) increase the probability c- securrence or consequence of an accident or malfunction oi equipment important to safety evaluated in the Safety Analysis Report since information was only clarified based upon recent experimentation and operating experience and since administrative actions are in place which will reduce the potential corrosive effects of coolant leakage; or, (ii) increase the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report since the only scenarios which could result from boric acid corrosion, breach of RCPB or loss of an active component, have been evaluated previously; or, (iii) reduce the margin of safety as defined in the basic, of any Technical Specification since no margins of safety have been altered.

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