ML18022A884

Forwards Rept,Summarizing Changes to Plant &/Or Procedures, as Described in FSAR for 1991,per 10CFR50.59.Tests or Experiments Were Conducted During Interval Which Are Not Described in FSAR & Require Reporting in Rept

ML18022A884
Person / Time
Site:	Harris
Issue date:	02/25/1992
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HO-920013-(), HO-920013-(0), NUDOCS 9203020047
Download: ML18022A884 (67)

Text

ACCELERATED DI TRIBUTION DEMONSTRATION SYSTEM ry'EGULAT Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9203020047 DOC.DATE: 92/02/25 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1 arolina 05000400-AUTH. NAME AUTHOR AFFILIATION RICHEY,R.B. -

Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Documen Control Desk)

SUBJECT:

Forwards rept, summarizing changes to plant 6/or procedures, as described in FSAR for 1991,per 10CFR50.59.Tests or experiments were conducted during interval which are not described in FSAR & require reporting in rept.

DISTRIBUTION CODE: ZE47D COPIES RECEIVED:LTR- i ENCL + SIZE: 5G TITLE: 50.59 Annual Report of Changes, Tests or Experiments Made W out Approv NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 PD2-1 PD 5 5 MOZAFARI,B. 1 0 INTERNAL: ACRS 6 6 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 N /~EQ/LHFB11 1 1 NRR/DOEA/OEABll 1 1 EG FILE 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 19

Carolina Power 8 Light Company P.O. Box 165 ~ New Hill, N.C. 27562 R. B. RICHEY Vice Piestdent Harris Nuclear Project FEB 2 5 1992 Letter Number: HO-920013 (0)

U.S. Nuclear Regulatory Commission 10CFR50.59 ATTN: NRC Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPORT IN ACCORDANCE WITH 10CFR50.59 Gentlemen:

In accordance with 10CFR50.59, the following report is submitted for the year of 1991. This report contains brief summaries of changes to the plant and/or procedures, which change the plant as described in the FSAR. There were no tests or experiments conducted it is

'uring this interval, which are not described in the FSAR and require reporting in this report.

R. B. Richey, Vice President Harris Nuclear Project MGW:dmw Enclosure cc: Mr. S. D. Ebneter (NRC - RII)

Mr. J. E. Tedrow (NRC - SHNPP)

MEM/H0-920013.0/1/Osl 9203020047 920225 PDR ADOCK 05000400 R PDP ~

Change to Facility as Described in the FSAR

.9203020047

Title:

RET-0252, Spent Fuel Pool Activity Concentrations Functional Summar RET-0252 evaluates'he affects of storing spent fuel bundles from other CP&L Nuclear Plants in the Harris Fuel Pools and updates the FSAR to include these affects.

Safet Summar The activity concentrations listed in FSAR Table 11.1.7-1 were exceeded upon addition of Brunswick Nuclear Plant spent fuel to the Harris Fuel Pools. The evaluation concludes that assuming worst case (a full spent fuel pool and no cleanup operation) dose to the public via an Reactor Water Storage Tank rupture would result in approximately one half of the 10CFR20 unrestricted limit. Storage of PWR and BWR fuel from other plants in the Harris Fuel Pool requires a change to the FSAR, but these changes do not affect the safe operation or safe shutdown of the plant. The evaluation identified no adverse impact on plant equipment important to safety.

The Fuel Pool activity concentrations can potentially become higher than previously allowed in the FSAR, but the higher activity levels will not result in exceeding the 10CFR20 unrestricted dose to the public. While there is some infringement on the margin of the 10CFR20 limit, the amount remains below the limit. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type'of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Tables 2.4.12-1, 11.1.7-1, and 12.2.1-22 Sections 2.4.12.1, 2.4.13.4, and 11.1.7 MEM/H0-920013.0/2/OS1

Change to Facility as Described in the FSAR

Title:

PCR-00858, Pressurizer Relief Tank Vent to Waste Gas System Functional Summar This plant modification adds a Pressurizer Relief Tank (PRT) vent line which ties into the Waste Gas System compressor suction.

Installation of the vent line allows PRT degas capability when the waste gas system is under normal operation. Previously, the waste gas system and associated technical specification hydrogen and oxygen monitoring instrumentation had to be shut down during PRT degas operation because the waste gas system is at a higher pressure than the PRT.

This modification improves the safe operation of the waste gas system by allowing the technical specification related hydrogen and oxygen monitors in the waste gas system to remain operable'during PRT venting to the waste gas system.

Safet Summar PRT venting prevents excessive hydrogen gas accumulation and reduces pressure in the PRT. If the PRT is not degassed periodically, the pressure could increase to the point that the rupture discs designed into the tank could burst resulting in the release of hydrogen and small amounts of fission gases to be discharged into the reactor containment. A PRT rupture has been determined in the SAR not to impose any offsite release to the public or the environment, although it is highly undesirable to release fission gases or hydrogen into containment. The venting of the PRT is to maintain normal pressure (3-8 psig) and thereby be prepared to accept pressurizer volume if the power operated relief valve (PORV) opens, without rupturing the rupture discs. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR Reference; Figure 11.3.2-01 MEM/H0-920013.0/3/OS1

Change to Facility as Described in the FSAR

Title:

PCR-00880, Fuel Handling Building Emergency Exhaust System Electrical Heating Coil Temperature Elements Functional Summar This plant modification relocates temperature elements installed in the Fuel Handling Building (FHB) Emergency Exhaust System. The temperature elements, TE-5021A and TE-5021B were previously'located between the electric heating coil (EHC) and the demister in air cleaning units E-12 and E-13, respectively. The temperature elements are the sensors for instrument loops that provide temperature indication only, and have no control function. The elements sense inlet air temperature to the heating coils.

Indication is required to monitor inlet air temperature during FHB Emergency Exhaust System operati'on. Since this system is an emergency system that is not normally operated, the indication is used most extensively during performance of Technical Specification surveillance testing. A delta T of greater than 10 degrees is the acceptance criteria for verifying EHC operation. A 10 degree delta T could not be verified with the location of the inlet temperature sensors. Readings were skewed by radiant heat from the EHCs, indicating a higher than actual inlet temperature and lower delta T.

This modification relocates the TE-5021A and TE-5021B upstream away from influence of the radiant heat of the EHC.

Safet 'Summar TE-5021A and TE-5021B are the only equipment involved in this modification. Only their physical location is changed. There is no functional change in the operation of the FHB Emergency Exhaust System. The temperature sensors will now provide true indication of actual inlet air temperature. This indication is necessary for performance of surveillance tests and for monitoring system operation.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 7.3.1-13 HEN/H0-920013.0/4/OS1

t Change to Facility as Described in the FSAR

Title:

PCR-01639, Rotary Air Compressor Functional Summar This plant modification adds the plants temporary Rotary Air Compressor (RAC) as a permanent load to 480 volt Auxiliary Bus 1E3.

The RAC is now a permanent component of the Compressed Air System (CAS). The RAC supplants the four reciprocating compressors as the principle source of supply for Instrument and Service Air. The RAC installation does not disable the reciprocating compressors from functioning. The operation of the compressed air system is such that if the RAC fails for any reason, the reciprocating compressors can pick up the load as they did before the advent of the RAC.

PCR-01639 changes the source of electrical power for the RAC from the less reliable offsite supplied transformer outside of the Turbine'uilding, to the much more reliable and preferred plant-internal 480 volt Auxiliary Distribution System. The new

'ource'Aux Bus 1E3) is non-segregated and non-safety related.

'Safet Summar The addition of the RAC will improve the reliability of the CAS thus decreasing the probability of loss of Instrument Air to safety and non-safety syste'ms. The Instrument Air System is a non-accident

~

initiating system and is not required for safe shutdown of the

.plant. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figures 1.2.2-64, 9.2.1-02, 9.3.1-02, 9.5A-35 and 12.3A-4 Table,9.3.1-1 Section 9.3.1.2 MEM/H0-920013.0/5/OS1

Change to Facility as Described in the FSAR Title PCR-01971, Computer and Communication Rooms HVAC Systems Revised Air Flows Functional Summar This plant modification revises the Reactor Auxiliary Building (RAB)

Computer and Communication Rooms HVAC System (CCRS) flowrate. The Computer and Communication Rooms are located on the 305'levation .

of the RAB. The CCRS supply fan AH-97 was unable to produce design flow of 15,900 CFM due to excessive static pressure losses. HVAC calculations were reevaluated and demonstrated that a reduced flowrate of 14,110 CFM to. areas would still maintain design space temperatures. Orifice plates were installed to -achieve balancing.

Smoke purge fan ES-7 flow was reduced from 16,000 CFM to 14,210 CFM in order to meet the AH-97 system flow, since these fans work together during the smoke purge mode on a once thru cycle.

Safet Summar The RAB CCRS is nonsafety-related except that the Seismic Category I duct penetrations to the RAB are provided with Safety Class 3, Seismic Category I tornado dampers to protect the RAB. The CCRS is designed non-nuclear safety since continuous operation of the system during design basis accident conditions is not required.

The air flow changes described above do not result in change to Control Room pressure valves, therefore Control Room habitability is not impacted. - This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Table 9.4.9-1 Table 9.4.0-1 Section 9.5A MEM/H0-920013.0/6/OS1

Change to Facility as Described in the FSAR

Title:

PCR-02055, Condensate Pump Suction Line Strainer 'Entrained Oxygen Removal Lines Functional Summar This plant modification provides continuous venting of entrained air which was collecting in the upper areas of the Condensate Pump Strainers. The entrained air was causing the dissolved'xygen in the Condensate Pump Discharge Header to be above plant chemistry limits.

Stainless steel tubing was added from the condensate pump strainers to the main condenser. Connection to the condenser is directly into the condenser vacuum performance test line. Venting reduces the amount of trapped/entrained air from being pumped through the Condensate/Feedwater Systems. This change also required that the Condensate Pump Strainer Vent Valves and the Condenser Test Connection Valves be repositioned to normally open. Leaving these valves open will equalize the pressure/vacuum in the tubing and allow the trapped air to vent back to the condenser.

Safet Summer The components affected by this modification are non-safety Q-Class E and are not required for safe shutdown of the plant. The worst case failure of this modification would be breakage or damage to the stainless steel tubing which would result in an opening to a previously closed process loop. The Condensate and Feedwater System is designed such that breaks in system components or piping will not result in adverse 'effects on the functional performance of essential systems or components. The. loss of condenser vacuum scenario and.a subsequent turbine trip are addressed in FSAR section 15.2.2.

Results of these analyses, indicate that the plant design is such that a turbine trip presents no hazards to the integrity of the Reactor Coolant System or Main Steam System. The condenser is not required for safe shutdown of the plant. This change does not increase the probability or consequences of analyzed accidents, d'or, introduce a different type or accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR Reference Figures 10.1.0-02 10.1.0-04" MEM/H0-920013.0/7/OS1

Change to Facility as Described in the FSAR

Title:

PCR-03418, Main Feed Pump Recirculation Valve Replacement Functional Summar This plant modification replaces the Main Feed Pump Recirculation Valves with new valves designed for cavitating service. This modification also removed previously installed orifices and changes the control circuit from open/close to a modulating configuration.

Main Feedpump Recirculation Flow Control Valves 4FW-1-1 and 4FW-2-1 have been sub]ected to excessive noise, vibration and trim wear since they were originally placed in service. PCR-1829 was initiated to resolve the problem on a temporary basis. The resolution implemented by PCR-1829 was to install flow restricting orifices downstream of the valve modulating to open/close.

After completion of PCR-1829, it was observed that the severity of the problem was reduced (as indicated by a reduction in the noise level). Later inspections of the valves revealed a vibration induced valve stem failure and erosion damage to the trim.

PCR-03418 was initiated to develop .a permanent solution to the problem.

PCR-3418 replaced the existing 6" Masoneilan flow control valves with new valves manufactured by Control Components, Inc. The new valves are model G5X6X6 "Drag" valves which utilize the tortuous path method for inducing, pressure drop and are internally designed for flashing and cavitating flow.

The valve vendor does not recommend orifices be installed downstream of the new valves. The downstream orifice plate pressure tap assembly, as well as the upstream tap'was removed with the orifices.

Removal of the orifices and flanges required the installation of an approximately 42" spool -piece.

The valve control logic was restored to modulating from the open/close configuration. The control switch in the control room was modified from the "auto-open" configuration to an "open-modulate-close" configuration. Additionally, an auto-close .

signal is now generated on loss of the feedpump. This change was requested by Operations to eliminate the need for the operator to manually close the valves on a Main Feed Pump trip.

MEM/H0-920013.0/8/Osl

Change to Facility as Described in the FSAR .

(continued)

Safet Summar The Main Feedwater Pumps are not required for safe shutdown of the plant. These changes restore the Feedwater Recirculation System to its original design configuration. System reliability and perfoimance characteristics are enhanced, thereby increasing unit efficiency and providing for improved response to feedwater system disturbances. The new auto-close feature for the main feedpump trip removes the need for manual operator action.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 10.1.0-3 MEM/H0-920013.0/9/OS1

Change to Facility as Described in the FSAR

Title:

PCR-03961, Essential Serv'ices Chilled Water System - Blackboard Functional Summar This plant modification to the Essential Services Chilled Water System (ESCWS) implemented I&C/logic changes to reduce the number of false alarms on the Main Control Board (part of blackboard concept) when either "A" or "B" train chiller is in the standby status.

The ESCWS consists of two essential chilled water trains. The trains are redundant and only one chiller is required for normal operations.. The redundant chiller is maintained in a standby operable mode. In the -past multiple alarms of the standby train were constantly energized because of their standby condition. This created a burden on the Control Room operators and had the potential to mask alarms which were valid and required immediate attention-;

Safet Summar The ESCWS is not an accident initiating system but is an accident mitigating system. This modification will not invalidate any FSAR Chapter 15 analysis assumptions regarding the performance of this system under accident conditions. All I&C/logic changes with the exception of the condenser recirculation pump were to silence the standby chiller Main Control Board alarms per the blackboard concept. The start circuit for the Condenser Recirculation Pump P-7 was =revised to operate based on service water flow instead of service water temperature. These I&C/logic, modifications increase the effectiveness of this mitigating system. This 'change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figures 7.3.1-16; Sheet 2, 12, and 15.

Figure 9.2.1-01 Sections 7.3 , 8.4 and 9.2.8.5 MEM/H0-920013.0/10/OS1

Change to Plant as Described in the FSAR

Title:

PCR-004105 '(Field Rev. 6), Spent Fuel Cask Basket Storage Functional Summar This plant modification installs a set of flanges, along with a spectacle- blind between these flanges, in piping (Line-¹ 7SF12-151-2+3) of the Fuel Pool Cleanup System located in the Fuel Handling Building. These flanges and blind separate the operational and nonoperational portion of this system. This will support the use of portions of the piping in treating fuel pool water in the Unit 2/3 transfer canal. The canal area is being used to store fuel cask baskets.

This modification provides storage for two (2) PWR fuel baskets and four (4) BWR fuel baskets which are used in conjunction with the 1F-300 spent fuel shipping 'cask. The s'torage location for the baskets will be the north (former Units 2 and 3) fuel transfer canal. The fuel baskets will be stored under water in the bottom of the transfer canal. Storage of the fuel baskets within the transfer canal will be freestanding. Also, included in this modification is a basket lifting rig (chain hoist) to be used in conjunction with the Fuel Handling Building auxiliary crane and the fuel basket lifting yoke assembly during the transfer of the basket, from the cask loading pool to th'e fuel transfer canal. This chain hoist is being provided so that the hook of the auxiliary crane does not have to travel under water during transfer of the basket. Storage racks for the fuel basket lifting rig and fuel basket lifting yoke are being provided in the cask head and yoke storage area.

Safet Summar Piping and components affected by this change are classified as nonsafety related. The flange and spectacle blind installation will provide pressure boundary integrity for the operational side of the Fuel Pool Cleanup System associated with the Unit 2 fuel transfer canal.

The fuel baskets are used in conjunction with the 1F-300 spent fuel shipping cask when stored in the former Unit ¹2 and ¹3 transfer canal. The fuel baskets are not considered to be safety related.

The structure and canal liner were evaluated for the loading imposed by the fuel baskets and found acceptable.

The existing Fuel Handling Building auxiliary crane will be utilized for the transfer of fuel baskets between the cask loading pool and the fuel transfer canal. The design, capacity of the auxiliary crane is 12 tons which is much greater than the weight of the PWR and BWR fuel baskets.

MEM/H0-920013.0/11/OS1

Change to Plant as Described in the FSAR Safet Summar  : (continued)

The travel path of the fuel baskets between the cask loading pool and transfer canal is not over spent fuel. This travel path is enveloped by the safe load paths analysis and will be controlled administratively, The basket lifting rig (chain hoist) and fuel basket lifting yoke are nonsafety and nonseismic. These two (2) items neither provide nor support any safety system function.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figures 1.2.2-55, 1.2.2-56, 9.1.3-3 Sections 9.1.3., 9.1.4 MEM/H0-920013.0/12/OS1

Change to Facility as Described in the FSAR

Title:

PCR-04453, Continuous ERFIS Calorimetric Functional Summar This plant modification provides field instrumentation and Emergency Response Facility Information System (ERFIS) computer hardware and software required to implement an on-line calorimetric.

FSAR Section 15.0.3.2 requires that core power be known within +2 percent allowance for calorimetric error. This has been verified by the daily performance of Surveillance Test OST-1004, Power Range Heat Balance Daily Interval Mode 1 and further verified by EPT-052, Power Range Heat Balance via Precision Calorimetric, which is performed at least once per 18 months. Technical Specifications Table 4.3-1, requires comparison, of calorimetric to 'excore power indications above 15% of rated thermal power, and adjustment of excore channel gains if absolute difference is greater than 2% .

PCR-04453 is concerned with less than optimum plant output due to the lack of a continuous ERFIS calorimetric. After cycle 2/3 refueling outage, a gross Nuclear Instrumentation/Secondary Calorimetric mismatch occurred at approximately 30% power. This provides further incentive to have a tool available to the operator to display secondary thermal power on a continuous basis. This modification provides the required field instrumentation and ERFIS hardware/software required to implement this on-line calorimetric.

Safet Summar This modification supplements an already existing surveillance test (OST-1004) to determine the "Power Range Heat Balance". This is a Tech Spec related procedure which determines the NIS power Range channel alignment. The new calorimetric program had a V&V performed-prior to installation and post installation verification/testing to ensure the correct thermal output was being calculated/displayed.

Proper administrative controls are provided to ensure that critical constants are correct and analog points are not locked out of scan.

The ERFIS computer software changes are not related to any equipment important to safety. For the new flow, temperature, and pressure instrumentation in this modification, the installation meets the rigorous design basis requirements of the original plant design including material specifications, construction practices, seismic qualifications, and separation criteria. This change does not

~

increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

MEM/H0-920013.0/13/OS1

Change to Facility 'as Described in .the FSAR FSAR

Reference:

Figures 10.1.0-3 and 10.1.0-06

- MEM/H0-920013.0/14/OS1

Change to Facility as Described in the FSAR Ti.tie:

- PCR-04481, Marginal Containment Cooling Functional Summar This plant modification redirects portions of, the Containment Cooling System (CCS) airflow by relocating existing supply registers. Due to containment temperatures consistently approaching the 120'verage technical specification limit during summer, modifications to the existing ductwork were made which redirects air previously supplied to elevation 221'nnulus, upward through the grating to the upper elevations of the annulus.

Safet Summer The CCS is an accident mitigating system: However, this modification does not alter system operating parameters, airflow quantities or control logic. The redirection of airflow is expected to improve mixing and reduce temperature'tratification in Containment. No new equipment is added. Duct work is considered to be passive and is installed in accordance with approved specifications. Static pressure losses are minimized and should not affect system operation. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figures 1.2.2-03 and 6.2.2-10 MEM/H0-920013.0/15/OS1

Change to Facility as Described in the FSAR

Title:

PCR-04489, Residual Heat Removal (RHR) Midloop Modifications Functional Summar This plant modification consists of installing new instrumentation to monitor Residual Heat Removal pump differential pressure. The purpose of this instrumentation is to provide reliable indication of parameters that relate to operation of the Residual Heat Removal System while the Reactor Coolant System (RCS) is in a reduced inventory condition with irradiated fuel in the reactor vessel.

Safet Summar The subject instrumentation will only be used while the plant'is in the shutdown cooling mode and/or while in the RCS drain down reduced inventory operation. This instrumentation has no active interface with normal plant power operation or system structures/components which. initiate, mitigate, or effect the ability to deal with a nuclear accident.

Modifications to existing instrument racks, instrument impulse lines, Process Instrumentation Cabinets, ERFIS computer, and the Main Control 'Board do not alter the design bases, assumptions, calculations, or values- used in the plant safety analysis report, emergency plan, or the SER. The instrumentation. added by this modification is a benefit to plant operation and has no detrimental impact on plant safety. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 5.4.7-01 Section 5.4.7.2.1 MEM/H0-920013.0/16/OS1

Change to Facility as Described in the FSAR

Title:

PCR-04688, Circulating Water Flow Instrumentation Functional Summar k

This plant modification adds flow instrumentation to the Circ'ulating Water System (CWS). Pressure taps are added to the circulating water piping downstream of the outlet condenser water box. These taps are connected to differential pressure cells for the purpose of flow indication.

Safet Summer The CWS is a non-safety related system. New materials added by this modification are the same as already installed in. the system, therefore material compatibility is not a concern. Flood considerations could not have any safety impact since the floor drains can handle any flow potential from the added connections should they break. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.1-2 MEM/H0-920013.0/17/OS1

Change to Facility as Described in the FSAR

Title:

PCR-04865, Lube Oil Cooler Bypass Functional Summar This plant modification to the Turbine Lube Oil System installs a flushing connection made up of a piping tee, reducer flange and blind flange in the turbine lube oil piping. This connection will only be used during outages to bypass the lube oil coolers when flushing the lube oil system. The bypass is needed to maximize flushing velocity. The tee and flanges are installed in the lube oil cooler return piping located next to the turbine oil reservoir.

When the unit is operating the flange is fitted with a blind flange to prevent any oil loss from the system.

Safet Summar The turbine lube oil system is a non-safety related system and is not required for safe shutdown of the plant. The components added are of the same material composition and meet the same code requirements as the existing components. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR Reference; Figure 10.2.2-09 MEM/H0-920013.0/18/OS1

Change to Facility as Described in'he FSAR

Title:

PCR-04935, Turbine. Driven Auxiliary Feedwater Pump Electrical Overspeed Trip Removal Functional Summar This plant modification disabled the electrical overspeed trip on the Turbine Driven Auxiliary Feedwater Pump (TDAFWP) due to spurious trips. This overspeed trip device has caused inadvertent trips reducing TDAFWP reliability. The modification consisted of lifting leads in the Auxiliary Feedwater Control Panel to disable the electrical overspeed trip.

Safet Summar The electrical overspeed trip function is being disabled in order to increase TDAFWP reliability. The TDAFWP is still protected from overspeed by the speed control circuit (governor) and.the mechanical overspeed trip device set at 5125 RPM (125%). Operation at the speed corresponding to the mechanical overspeed trip setpoint will not create the potential for an internally generated missile. The turbine is designed for this and is protected by the redundant trip and control systems. The pump cannot generate a missile capable of piercing the pump casing when operating at the overspeed condition.

Deletion of the electrical overspeed trip will increase the reliability of the TDAFWP and will not affect the required pump flows. or pressures to maintain the mitigating function of the Auxiliary Feedwater System. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 7.3.1-10 Sections 3.5.1 and 10.4.9 MEM/H0-920013.0/19/OS1

Change to Facility as Described in the FSAR Title; PCR-05045, Pressurizer Power Operated Relief Valve (PORV) Upgrade Functional Summar This plant modification upgrades two of the three Reactor Coolant System Pressurizer PORVs (1-PCV-445A and PCV-444B) manual actuation components, control and power supplies to safety grade for use in the Steam Generator Tube Rupture (SGTR) event only. This will include Class 1E manual control circuits and power supplies, safety grade pneumatic power source and supply and qualified environmental and seismic components whose functions are required for the SGTR event.

These changes have been previously referenced in correspondence to the NRC via Carolina Power and Light Company's Letter NLS-89-320, dated December 15, 1989 concerning the SGTR event, response to Generic Letter 90-06 (NLS-90-256) dated December 21, 1990 and our license amendment request (NLS-91-135) dated May 15, 1991.

Safet Summar The proposed modifications to the mechanical NSSS components and their respective interfaces with other supporting systems will not introduce new failure modes or change the basic function of opening/closing the PORV. These modifications do, however, represent an increase in the reliability of components and interfacing systems 'that support the operation of the two PORVs.

Because of this, the pressurizer PORVs and the manual actuation system control and'ower supplies are expected to be available in mitigating the consequences of an SGTR. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Sections 1.2, 1.8, 3.2, 3.5, 3.8, 3.9, 3.10, 5.1, 5.4, 6.3, 7.4, 7.6, 8.3, 9.3, 9.5, 9.5A and 15.0.

MEM/H0-920013.0/20/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05058, Switchyard Voltage and Setpoint Display Functional Summar This plant modification installed equipment and instrumentation that will allow the Plant Net Megawatt and Megavar measurements to be telemetered to the Energy Control Center (ECC) in Raleigh, N. C. for use in the new Energy Management System (EMS). This will enable more accurate calculation of "best estimate" voltages on the power system grid.

In conjunction with the above, the North and South 230KV Switchyard Bus Voltages are now displayed on the Control Room Main Control

'Board (MCB) along with the optimum Switchyard Voltage Setpoint. The voltages are recorded on a 'stripchart recorder installed in the recorder panel in the Control Room by this Modification. These displays will allow unit operators to compare "actual" switchyard voltages with "desired" voltages and make adjustments in generator excitation so as to maintain the optimum generator output/voltage level. The net result will be minimized transmission losses with less risk of violating any voltage .or Megavar generation constraints.

Safet Summar The circuits tapped for use in this effort are non-safety related.

These circuits provide ancillary current and voltage sensing, which, in the existing design is utilized to derive/display and/or telemeter the voltages, MWATTs and MVARs in question. Previously the instrumentation and circuitry, however, did not adequately allow the information to be used by the individual(s) who need it, where they need it, and in the form they need. This PCR serves to upgrade this situation by providing more appropriate, accurate information to the ECC and the Control Room. The new displays, recorder and telemetry are not associated with any accident initiating/mitigating system or equipment. The sole impact to nuclear safety is the mounting of the displays in the Control Room MCB vertical secti'on, 1BB and Recorder Panel. These mountings are designed seismically and therefore will preclude any physical impact on safety-related instrumentation or controls. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR Reference Section 8.2.1.2 MEM/H0-920013.0/21/OS1

1 Change to Facility as Described in the FSAR

Title:

PCR-05236, Reactor Coolant Pump (RCP) Motor Oil Reservoir Level Indication AOP-018 Rev. 4, AC 4/2, Reactor Coolant Pump Abnormal Conditions Functional Summar This plant modification replaced the six existing RCP oil level switches with level transmitters (LTs) and level indicating switches (LISs) ~ The LISs have been located outside containment such that they are accessible during power operation for observation of RCP upper and lower oil reservoir level. The previous design of the RCP oil level monitoring system includes a local sight gage and a level switch capable of detecting both .high and low levels and of providing input to the Control Room annunciation system. The local site glass is. inaccessible durin'g power operation, thereby leaving the operators without actual oil levels, fluctuations or trends.

FSAR Section 5.4.1.3.3 stated that the occurrence of a low oil level alarm requires the shutting down of the RCP, and Procedure AOP-018 required . tripping the reactor prior to tripping the RCP. The requirements to shutdown an RCP based upon a low level alarm:

occurrence is being deleted from AOP-018. It is being replaced with a requirement to shutdown if a low level alarm occurs concurrent with a steady increase in bearing temperature.

Safet Summar The existing oil level alarms and their setpoints will remain unchanged. The modification adds the feature of accessible indication of RCP oil level to be used in evaluating the validity/severity of the associated alarms. Overall plant operation will be enhanced by the added capability to monitor RCP oil level during plant operation.

1 Although the, system is not'safety-related, the new equipment to be installed in the Reactor Auxiliary Building and the Fuel Handling Building, including the LISs, junction boxes and conduit, will 'be sei:smically mounted, as required, so as not to disable safety-related equipment in the event of an earthquake.

MEM/H0-920013.0/22/OS1

Change to Facility as Described in the FSAR Safet Summar  : (continued)

In respect to the above mentioned change to AOP-018, the most reliable indication of bearing problems is bearing temperature, and i.t should be considered before subjecting the plant to potentially unnecessary shutdown and startup transients. A decreasing oil level wi,ll not result in motor bearing failure without a coincident increase in bearing temperature. This provides the basis for changing the shutdown requirement from "shutting down when a low level alarm is received" to "shutting down when a low oil level alarm occurs coincident with steady increases in bearing temperature".

Additional indication of RCP bearing/motor condition is provided by the RCP Vibration Monitoring System located in the Main Control Room. This system provides both indication and alarms on high vibration. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Section 5.4.1.3.3 MEM/H0-920013.0/23/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05204, Post Accident Sampling System (PASS) Chiller Service Water Valves Functional Summar This plant modification evaluated allowing the PASS Chiller Service Water return lines isolation valves to remain open during normal plant operation. Allowing the return isolation valves to remain open during normal operation will reduce the personnel actions required to place the PASS Chiller in service following an accident and can provide a significant reduction in personnel radiation exposure.

Safet Summar The subj ect isolation'alves are safety-related but the service water lines and the PASS Chiller itself is non-safety related and non-seismic. In an accident situation, these nonsafety-related lines are assumed to break.

PCR-5204 stipulates only the return isolation valves may be left in an open position during normal plant operation. Any service water lost through the PASS Chiller return lines will come from the main return headers and will not adversely impact the capability of the Service Water System to mitigate a design basis accident. In addition, any pipe break in these lines will not prevent other systems or equipment from accomplishing their safety-related functions.

Flooding and dynamic pipe effects caused by a pipe break have been shown to have no impact on safety-related equipment. Since the volume of water in the main and auxiliary reservoirs ensures sufficient water is available for Service Water System cooling requirements, the potential break in the chiller return lines will have no impact on Service Water System capability and the margin of safety as defined in the Technical Specifications will not be reduced. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type .

of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.1-01 MEM/H0-920013.0/24/OS1

I Change to Facility as Described in the FSAR

Title:

PCR-05288, Leak Repair "of 1RC-69 Reactor Coolant System (RCS) Hot Leg (Loop 2) RTD Bypass Isolation Valve Functional Summar This plant modification provided repair for the valve stem leak on the 1RC-69 RTD Bypass Isolation Valve. 1RC-69 was found,to be leaking and due to boric acid attack on the carbon steel bonnet, installation of a welded cap was required. The valve is left in the full open'osition and the manual operator is removed.

Safet Summar The seal cap was supplied by Kerotest to the same quality standards as the original valve components. The body and bonnet will remain as the primary pressure retaining parts with the seal cap as a back-up providing pressure seal capability. Seismic effects due to the weight of the cap offset by the elimination of the valve operator were evaluated and found to be acceptable.. The system is thus kept in the "as analyzed" condition. Valve operability is not required for plant operation or shutdown. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists. E FSAR Reference Figure 5.1.2-01 MEM/H0-920013.0/25/Osl

Change to Facility as Described in the FSAR Title PCR-05289, Leak Repair of 1RC-11 Reactor Coolant System (RCS) Hot Leg (Loop 2) RTD Bypass Isolation Valve Functional Summar This plant modification provided repair for the valve stem leak on the 1RC-11 RTD Bypass Isolation Valve. 1RC-11 was found to be leaking and due to boric acid attack on the carbon steel bonnet, installation of a welded cap was required. The valve is left in the full open position and the manual operator is removed.

Safet Summar The seal cap was supplied by Kerotest to the same quality standards as the original valve components. The body and bonnet will remain as the primary pressure retaining parts with the seal cap's a back-up providing pressure seal capability. Seismic effects due to the weight of the cap offset by the elimination of the valve operator were evaluated and found to be acceptable. The system is thus kept in the "as analyzed" condition. Valve operability is not required for plant, operation or shutdown. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 5.1.2-01 MEM/H0-920013.0/26/OS1"

Change to Facility as Described in the FSAR

Title:

PCR-05563, Flow Balancing of AH-16 Air Handlers Functional Summar This plant modificati'on provides for flow balancing of air handlers AH-16, lA-SA and 1B-SB which serves the Reactor Auxiliary Building (RAB) Electrical Equipment Protection Room Ventilation System.

AH-16 air handlers service the Relay Room, Process Instrumentation Control (PIC) Room, I&C Shop and HVAC Rooms, located on elevation 305'f the RAB. The design air flow into the I&C Shop was 2800 CFM. The I&C Shop has a very small heat load (much smaller than as originally designed for) as compared to the PIC Room. The system supply temperature is controlled based on the PIC Room heat load.

With the very high air flow in a small area (I&C Shop) and the air temperature controlled for an area with a much higher heat load (PIC Room), the I&C Shop was like a cold wind tunnel.

This modification reduced the direct supply air flow to the I&C Repair Shop from 2400 CFM to 1100 CFM. A restricting orifice was installed in the I&C Shop ductwork to help reduce air flow. Air flow to the PIC Room was increased from 5500'FM to 6800 CFM.

Safet Summar The Reactor Auxiliary Building Electric Equipment Protection Rooms Ventilation System is required to operate during both normal and accident conditions to maintain an acceptable operational environment for the safety related equipment located in each electrical equipment and protection room. Consequently, the system is designed to meet Safety Class 3 and Seismic Category I requirements. This modification does not change the operation or control features of the system. However, supply 'air temperature will be controlled more in accordance with room heat loads.

The installation of orifice plates will help to reduce air flow in the I&C Shop. If the plates were to become dislodged via seismic event, the installed location and the fact that supply air pressure is against its backside would prevent it from traveling downstre'am and restricting air flow. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.4.5-01 Tables 9.5A-12 and 9.5A-13 MEM/H0-920013.0/27/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05572, Secondary Waste Filtration Functional Summar This plant modification allowed installation of Secondary Waste bag filters in the Low Conductivity Secondary Waste Subsystem with a crosstie to the High Conductivity Subsyst'em. These bag filters may be used in lieu of the existing Vacco Filters.

Safet Summar The Secondary Waste System is not a mitigating system. It is part of the Liquid Waste Processing Systems. The loss of the Secondary Waste System would be part of the loss of all liquid radwaste 'iquid accident bounded by Chapter 15 accident analysis. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 11.2.2-08 Table 11.2.1-7 Section 11.2.2.8.4 MEN/H0-920013.0/28/OS1

Change to Procedure as Described in the FSAR Title FHP-003, Unpacking and Handling of New Fuel Assemblies, Fuel Inserts and New Fuel Shipping Containers Functional Summar With the installation of the new fuel racks (PCR-05246) in the new fuel inspection area additional space is needed to store and inspect new fuel. This procedure change allows the option to store full new fuel assembly containers and to open new fuel containers on the operating level of the Fuel Handling Building (FHB) or within the new fuel inspection area.

Safet Summar Westinghouse Fuel Division indicates that it is industry practice to utilize the operating level of the FHB to sit full fuel containers and to open the containers for inspection there. The floor'oading is within limits and by opening the fuel container on the operating level there is less opportunity for heavy loads passing by stored .

new fuel.

A new fuel accident in the FHB is. not a" Chapter 15 analyzed event.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Section 9.1.4.2.4 MEN/H0-920013.0/29/OS1

Change to Procedure as Described in the FSAR

Title:

PLP-106, Rev. 3, AC 3/2, Technical Specification Equipment List Program and Core Operating Limits Report Functional Summar This change revises the snubber visual inspection intervals described in PLP-106 Rev. 3 Attachment 4 and SHNPP FSAR'Table 16.3-4 Para. 4.2 to the inspection intervals provided in NRC Generic Letter 90-09, Alternative Requirements For Snubber Visual Inspection Intervals and Corrective Actions, dated December 11, 1990.

Safet Summar The revision to plant procedure PLP-106 is intended to affect all

snubbers at SHNPP, both accessible and inaccessible. PLP-106 is referenced by Technical Specifications to be the governing procedure for inspection and testing of snubbers. This change will require revision to SHNPP FSAR Table 16.3-4 paragraph 4.2.

Based on GL 90-09, the proposed change can be made while maintaining the same confidence level as the existing schedule. In GL 90-09 the NRC staff recommends adoption of the revised snubber inspection interval. This change does not result in any physical change to the plant. This change'oes not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Table 16.3-4 MEM/H0-920013.0/30/OS1

Change to Facility as Described in the FSAR

Title:

PCR-02676, Reactor Auxiliary Building Normal Ventilation System Exhaust/Supply Flows Functional Summar This plant modification makes changes to airflows, orifices and grills in the non-safety related Reactor Auxiliary 'Building (RAB)

Normal Ventilation System. The changes were made to accomplish an adequate flow balance of the system.

Safet Summar The only Q-list impact of this modification is the mounting of wire mesh screen to Q-list Isolation Damper No. AV-D535B-1 ~ Damper No. AV-D535B-1 is not part of an accident initiating system; however is part. of an accident mitigating system. The Damper closes to allow the RAB Emergency Exhaust System to maintain potentially contaminated areas below atmospheric pressure and prevent an uncontrolled/unfiltered release of radiation. However, the damper function will not be impaired by the mounting of an orifice or a wire mesh screen on the damper face since damper blades are fully contained within its frame. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.4.3-1 MEM/H0-920013.0/31/Osl

Change to Facility as Described in the FSAR

Title:

PCR-05895, Lead Shielding Storage Functional Summar This plant modification allows the installation of lead shielding around the Control Rod Drive Mechanism (CRDN) and thermocouple conduits just inside the lower shroud doors of the reactor head. An evaluation of installing and lifting the shield weight "along with the reactor vessel head was performed. The temporary shielding will be installed during Modes 5 and 6.

Safet Summar The limiting conditions of the Polar Crane have been reviewed and documented. The Polar Crane is structurally capable of lifting the head and shielding within applicable allowables. The shielding weight requested exceeds the weight allowed by the latest head drop analysis. To avoid invalidating this analysis the evaluation provides guidance on reactor vessel stud removal to keep the total head weight within analysis assumptions'.

Both the CRDM's and thermocouple conduits are sealed assemblies and installing shielding around them can" not have any affect on their mechanical operation. The lead is to be wrapped in herculite to prevent direct contact with the CRDM's/thermocouple assemblies.

This is a precaution necessary to avoid any corrosion concerns. The head insulation has been evaluated and deemed acceptable for shielding weight provided necessary precautions are taken to avoid damage. The shielding guidelines require that the lower shroud doors are closed to prevent the possibility of a lead sheet or blankets being dropped out of the head during transit.

The safety, reliability and operability of the reactor vessel internals and reactivity control systems will not be compromised as a result of this shielding. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already .

evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 1.2.2-3 and 1.2.2-7

. MEM/H0-920013.0/32/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05321, Circulating Water Return Line Pitot Tube Tap Repair Functional Summar This plant modification provides for capping the pitot tube test tap on the circulating water piping return line which was damaged during excavating. This tap is located on the north side of the south return line to the Cooling Tower. It also installed a protective concrete slab above the tap to prevent possible future damage.

Safet Summar The Circulating Water System is a non-safety related system. The capping components are the same material type, schedule, and grade as the balance of the welded portion of the system. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.1-2 HEM/H0-920013.0/33/OS1

Change to Facility. as Described in the FSAR

Title:

PCR-05748, Component Cooling Water Thermal Relief Valve Deletion Functional Summar This modification deletes the thermal relief valves on the Component Cooling Water (CCW) side of the heat exchangers listed below and replaces them with a combination locked open globe valve and check valve. The relief valve piping that was routed to drains is rerouted to connect to the CCW return header downstream of the outlet isolation valve. Each bypass line contains a restrictor orifice to limit the flow through the line to a value comparable to the relieving capacity of the relief valve being removed.

System over pressurization has occurred in the past and caused the thermal relief valve on the Reactor Coolant Drain Tank to lift consequently causing loss of CCW inventory.

Heat Exchangers affected:

Residual Heat Removal (RHR) Heat Exchanger lA-SA RHR Heat Exchanger 1B-SB Spent Fuel Pool Heat Exchanger l&4A Spent Fuel Pool Heat Exchanger 1&4B

~ - Seal water Heat Exchanger Letdown Heat Exchanger Boron Recycle System (BRS) Distillate Cooler BRS Evaporator Condenser BRS Vent Condenser Safet Summar This modification is intended to make the CCW System less likely to loose its inventory. By making this modification it is assumed that the system ,will be more reliable and be less prone to upset conditions where a relief valve could lift and fail to reseat.

By virtue of the fact that this modification adds additional components in the CCW system, there is greater probability of equipment malfunction. However, the increased incidence of equipment malfunction is offset by the greater level of operatimg margin that is provided by this modification. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figures 9.2.2-2, 9.2.2-4, and 9.2.2-5 Section 9.2.2.2.2 MEM/H0-920013.0/34/Osl

Change to Facility as Described in the FSAR

Title:

PCR-05457, Emergency Service Water Branch Connections Functional Summar This modificati:on installs two 24" branch connections and two 2"

., branch connections on the Emergency Service Water (ESW) System to

, facilitate maintenance on ESW System valves. The branch connect'ions are being added to the ESW piping system to facilitate maintenance on permanent ESW valves. The 24" branch connections are added to the ESW header to provide access for the installation of a temporary line stop. The 24" branch connections will be welded onto the piping at specific locations such that when the line stop is inserted, the flow path joining the two ESW trains will be blocked.

This will allow for the operation of one train while the other is shut down for maintenance with out risk of'significant inter-system leakage which could curtail the maintenance. The 2" branch connections are used to assist in draining the ESW header for the peiformance of maintenance and are also used as a connection point for providing equalization pressure to the temporary line stop mechanism when it is desired to remove the line stop. The line stop cannot be removed from the piping with a significant differential pressure across it.

Safet Summer The portion of 'the ESW system to which the modification impacts is Safety Related (ASME Section III, Class 3). This modification is being made in compliance with all applicable site specifications, applicable standards and all applicable regulatory requirements.

The branch connections are to become a permanent part 'of the ESW pressure boundary and meet the design basis requirements of the ESW System. The completion plug is part of the branch connection which is used to temporarily hold back system flow during the stop removal and until the permanent blind flange can be installed. It is not considered part of the permanent pressure boundary and is not designed to the ASME code. The portion of the retainer screw assembly that constitutes the pressure boundary is manufactured 'to .

the ASME Code,Section II for material requirements and Section III.

The other parts of the retainer that are not part of the pressure boundary (including the segment) are fabricated to manufacturer's standards. The branch connection. has been qualified to Seismic Category I criteria. The reinforcements on the 24" connections are structural components only and are not part of the pressure boundary. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists'EM/H0-920013.0/35/OS1

Change to Facility as Described in the FSAR (continued)

FSAR

Reference:

Figure 9.2.1-01 MEM/H0-920013.0/36/OS1

4 I Change to Facility as Described in the FSAR

Title:

PCR-05847, Replacement of Primary Make-up System Valve 1PD-63 Functional Summar This plant modification provided a replacement for valve 1PD-63 located in the non-safety portion of the Primary Make-up System that supplies make-up to the Pressurizer Relief Tank (PRT). Valve 1PD-63 is a normally open, manually operated valve, used as a boundary valve for Local Leak Rate Testing (LLRT) of Containment Isolation Valve 1RC-161. This modification changes 1PM-63 from a globe type to a diaphragm valve.

Safet Summar The Primary Make-up System is neither an accident initiating nor an accident mitigating system and therefore is not required for safe shutdown of the plant. The replacement valve will serve the same function as the existing valve. Although it is a different type, it is the same size, ANSI pressure rating, and material (stainless steel). The new valve is a diaphragm type with an EPDM diaphragm.

The design temperature is 140 degrees F. The specified replacement can be used in applications up to a maximum of 300 degrees F. The Containment Isolation Valve is also a diaphragm valve with an EPDM diaphragm. Therefore, the use of a diaphragm valve in this application is acceptable. This change does not increase the probability, or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus,'no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.3-2 MEM/H0-920013.0/37/OS1

Change to'acility as Described in the FSAR

Title:

PCR-05599, Alternate Reactor Head Vent Functional Summer This plant modification installs an additional vent path on the Reactor Vessel Head Vent. This alternate vent will be open to the containment atmosphere. This alternate vent is needed to ensure that the Reactor Coolant System (RCS) does not incur pressurization effects during flood up and drain down evolutions which can cause a bias on the RCS stand pipe.

The alternate vent consists of a branch connection that is being added to the Class 1 boundary. The vent is opened to the atmosphere by removing a blind flange on the branch connection. This, configuration ensures minimum pressure drop considering that the Class 1 boundary restriction orifice- and the majority of the head vent valves are bypassed when the flange is removed. This vent can only be used when the unit is shutdown, depressurized and drained below the vessel flange..

Safet Summar The alternate head vent is installed within the Class 1 portion of the RCS system and it is assumed this piping remains intact for all design basis events. Design requirements imposed by the ASME Code, Section III, Class 1 are met. This modification does not change the function of the head vent during normal plant operation or during postulated accident conditions. It is assumed that the alternate vent will be isolated (by manually installing the blind flange) before entering any plant condition where the RCS is pressurized.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 5.1.2-1 MEM/H0-920013.0/38/OS1

0 Change to Facility as Described in the FSAR

Title:

PCR-03088, Shotpot for Condensate Storage Tank Chemical Add'ition Functional Summar This plant modification adds a shotpot in the Condensate System piping for the purpose of Condensate Storage Tank (CST). chemical addition. The shotpot will be connected to the system by piping just upstream and downstream of Condensate Transfer Pump 1X-NNS.

Safet Summar The discharge and suction lines of the Condensate Transfer Pump 1X-NNS are non-nuclear safety related. These lines connect to the CST above the minimum water level line. This insures that in the event of a failure of a non-seismic pipe the minimum CST inventory for operation of the Auxiliary Feedwater System is maintained. This feature prevents the addition of the shotpot and lines from having'ny affect on any accident analyzed in Chapter 15 of the FSAR. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 10.1.0-04 MEM/H0-920013.0/39/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05448, Component Cooling Water Relief Valve Setpoint Change

. Functional Summar This plant modification increases the design pressure and the relief valve setpoint in the Reactor Coolant Drain Tank (RCDT) portion of the Component Cooling Water (CCW) System from 150 psi to 160 psi.

The thermal relief valve (1CC-186) setpoint is increased to prevent the possibility of placing the plant in an unsafe condition during ESF activation following a loss of offsite power when both pumps are started and immediate operator action cannot be taken to secure one pump .

Safet Summar Increasing the design pressure of the safety related RCDT portion of the CCW System increases the operational reliability of the CCW System. No physical changes of any plant equipment other than relief valves spring adjustments is required by this modification.

The valves within this portion of CCW are acceptable to operate at the new design pressure. The CCW side of the RCDT heat exchanger has been qualified to 160 psig by the manufacturer. During plant start up, the RCDT portion of CCW system was hydrostatically tested to 225 psi and documented per Section III of the Boiler and Pressure Vessel Code to at least 1.25 times the system design pressure of 150 psi. The increase in design pressure meets the requirements of ASME Section XI of the Boiler and Pressure Vessel Code which is the governing code since the plant is now operational. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in'he FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.2-1 and 9.2.2-3 MEM/H0-920013.0/40/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05076, Temporary Shielding For The Integrated Reactor Vessel Head Functional Summar This plant modification evaluated and designates storage areas for lead shielding on the 221'levation and 286'levation of the Reactor Containment Building. An evaluation was required to ensure the structural integrity of the building due to the additional dead load applied. As a result, 8,000 pounds of shielding is approved to be .stored inside the reactor vessel head laydown area on elevation 286'nd 10,000 pounds,,of shielding may be stored on the slab near azimuth 0'n elevation 221'uring normal plant operations.

Safet Summer Calculations were reviewed and revised to incorporate additional loading introduced by this change. The loading was determined to be acceptable. Potential interaction of the shielding with safety related components during a seismic event and the possibility of blocking the recirculating sump screens was evaluated. As a result it is determined that allowing storage of lead shielding in the aforementioned areas will not affect the safety, operability or reliability of the containment structure or any containment building system. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 1.2.2-11 Section 9.1.5.2.2.8'EM/H0-920013.0/41/OS1

Change to Facility as Described in the FSAR

Title:

PCR-02898, Residual Heat Removal System Automatic Closure Interlock Deletion Functional Summar The purpose of this plant modification is to delete the Residual Heat 'emoval Autoclosure Interlock (RHR-ACI) feature which represents a change to the basis of the plant's operating license.

The plant design utilized an RHR-ACI feature to automatically close the RHR suction isolation valves during plant operations, should the Reactor Coolant System (RCS) pressure increase sufficiently without operator intervention. The RHR-ACI setpoint was 700 psig. This feature was described in the plant's FSAR and Sections 5.4.7.2 and 7.6.2.1 of the NRC Staff Safety Evaluation Report NUREG 1038. "This interlock was also, subject to surveillance testing as required by the plant Technical Specification 4.5.2.d.l.(b). This requirement was deleted per License Amendment No. 24.

The deletion of this feature is, in part, an implementation of the corrective action identified in Licensee Event Report 89-22-00 in which the loss of an operating RHR train was incurred due to spurious closure of a suction valve during testing of interlocks.

In addition to deleting the RHR-ACI, the proposed changes will add an annunciator alarm for each RHR suction isolation valve such that at a predetermined setpoint on increasing RCS pressure in conjunction with a,suction valve not closed signal, the alarm will sound after a small time delay. The alarms and existing valve position indicators will be modified such that their control power will be supplied ahead of the valve circuit breaker. Hence, the racking out (circuit breakers in locked open position) of valve power should not affect the valve position indication in the Control Room or the availability of the alarm.

Safet Summar These changes were submitted to NRC, reviewed, and approval was provided in Amend 24 to the Operating License (NPF-63) on Harch 4, 1991. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Section 5.4.7, 7.4.1, 7.6.1 and 8.3.1 Figures 7.6.1-1, 7.6.1-2, 8.3.1-5 MEN/H0-920013.0/42/OS1

foal Change to Facility as Described in the FSAR

Title:

PCR-05138, Essential Chiller Expansion Tank Sightglass and Level Transmitter Functional Summar This plant modification replaces the existing Essential Chilled Water (ECW)'xpansion Tank sightglass with a pressure retaining level indicator.

In order to provide'isual indication of the water level in the expansion tank, a liquid'level indicator will be mounted in place of the existing sightglass. The new configuration consists of a vertical pressure retaining pipe flange t'o existing piping. Magnet equipped stainless steel balls tra'versing the height of the pipe will provide indication on an externally, mounted flag assembly.

Level indication will be continuous.

Safet Summar This modification will improve the reliability of the ECW Expansion Tank level indicator. The additional components added are designed to the same standards as the original ECW System (Safety Class 3, ASME Section XI, Seismic Category I). This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus,, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.8-03 MEM/H0-920013.0/43/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05679, Spare Containment Penetration Modification (S102)

Functional Summar This plant modification removes caps from spare containment penetration S102 and installs flanges and blind flanges. The spare penetration is being modified to allow access for shotpeening equipment during refueling outages. To allow use of the penetration during Mode 6 a closure piece has been engineered.

Safet Summar The penetration modification maintains the Containment Isolation System (a mitigating system) in a condition which satisfies all Technical Specification requirements. The flanges and blind flanges are equal to or better than the original caps. The closure piece for Mode 6 maintains the containment isolation in conjunction with the administrative controls. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Table 6.2.4-1 and 6.2.4-2 E

MEM/H0-920013.0/44/OS1

Change to Facility as Described in the .FSAR Title PCR-00942, Fire Detection System Annunciation Upgrade Functional Summar This plant modification installed a data link, with power supervision, between the plants Fire Detection Computer and the Emergency Response Facility Instrumentation System (ERFIS) Computer.

This modification enhances the control room staffs ability to monitor Fire Detection System alarms.

Safet Summar The addition of the data link is an enhancement which adds reliability to the Fire Detection Systems alarm capability. The ~

modification does not affect any previously evaluated fire scenario.

If the data link failed it would be independent from the rest of the Fire Detection System. This change does not increase the probability or consequences of analyzed accidents, nor introduce a differe'nt type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Section 9.5.1 MEM/H0-920013.0/45/OS1

Change to Facility as Described 'in the FSAR

Title:

PCR-01731, Steam Generator Blowdown Flow Indication Functional Summar This modification installs three flow elements in the following locations:

a. Steam generator blowdown flash tank steam outlet line (steam element).

b. Steam generator blowdown flash tank liquid outlet downstream of condensate cooling mixing chamber (liquid element).

Condensate cooling water inlet line to steam generator blowdown mixing chamber (condensate element).

Also installed are three thermowells directly downstream of each flow element. The three flow elements are provided with flange ends to facilitate ease of removal for maintenance and inspection.

This modification will enhance, the reliability of .the Steam Generator Blowdown (SGBD) System by minimizing the number of times the FCV-8405', B, and C valves are operated. Also, this modification will be used 'to ensure that steam generator chemistry is maintained without excess penalty to the overall heat rate. This modification will enable the plant to perform continuous calorimetry which has an overall effect of increasing unit output.

Safet Summar PCR-01731 installs flow elements in the nonsafety-related portion of the SGBD System. The components being installed are designed in accordance with original design codes and with consideration for erosion due to higher velocities and additional turbulence. Orifice plate type flow elements were not specified due to their susceptibility to flashing and subsequent erosion of downstre'am piping.

Failure of the blowdown piping in this part of the system cannot challenge steam generator inventory since the pressure boundary is maintained by safety-related, physically separate components located upstream in the Reactor Auxiliary Building and Reactor Containment Building.

MEM/H0-920013.0/46/OS1 I

Change to Facility as Described in the FSAR Safet Summar  : (continued)

The failure of the blowdown pressure boundary is a credible event and has been analyzed in the FSAR. The consequences of a pressure boundary failure could result in a radioactive release since the blowdown system is potentially contaminated; however, this accident is bounded by more limiting events which have greater radiological consequences and a higher probability of occurrence. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 10.1-0-6 MEM/H0-920013.0/47/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05501, Condenser and Service Water Tie-in Functional Summar This plant modification installs a tie-in connection on the condenser and the Normal Service Water System supply and return headers. The condenser connection will allow reusable sample liquid to be discharged from the Sample Reclamation System to the condenser. The service water supply and return connections are required to provide cooling water to the new Secondary Sample System conditioning equipment.

Safet Summar The tie-ins are all non-seismic and non-nuclear safety related. The valves, fittings, and piping are designed to meet or exceed the service environment this equipment is exposed to. Failure of these connections would result in lake water and/or condensate spilling on the 261'levation of the Turbine Building. This leakage would be captured by the industrial waste sump and processed either through radwaste or discharged offsite as required by sample analysis. Air leakage into the condenser from failure of the condenser connection would result in impurities (02, C02) entering the condensate system.

These impurities would be removed by hydrazine and the condensate polishers prior to entering the steam generators and causing corrosive damage. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 9.2.1-02 MEM/H0-920013.0/48/OS1

~ l 4 Change to Facility as Described in the FSAR

Title:

PCR-04746, Waste Processing Flow Monitoring Functional Summar This plant modification adds a piping crosstie from the discharge of the Waste Monitor Tanks Pumps to the discharge of the Secondary Waste Sample Pumps. The flow rate from the Waste Monitor Tanks through its normal discharge path has been reduced to 40 gpm. When the Waste Monitor Tanks are used as a backup to the Secondary Waste Sample Tanks, the usual 100 gpm discharge rate is necessary. The crosstie allows the Waste Monitor Tanks to be discharged at 100 gpm through the Secondary Waste Sample Tank discharge path and radiation monitor.

Safet Summar 1

The affected systems are part of the Liquid Waste Processing System.

The new piping i,s, installed per existing pipe specifications and standards. No new water volumes are created. Failure of this additional piping is bounded by the current analyzed accident of a total loss of Liquid Waste Processing Syst'm inventory which would be contained by the Waste Processing Building. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than

.already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Figure 11.2.2-4 and 11.2.2-8 MEM/H0-920013.0/49/OS1

Change to Facility as Described in the FSAR

Title:

PCR-03811, Low Head Safety Injection (LHSI) Recirculation Sump Pipe Vents Functional Summar This plant modification adds high point vents to the piping between Low Head Safety Injection (LHSI) Recirculation Sump Isolation Valves 2SI-V571'-SA-1 and 2SI-V573-SA-1 on "A" Train and 2SI-V570-SB'-1 and 2SI-V572-SB-1 on "B" Train. Through maintenance activities or testing, this piping had the potential to become void of water. No suitable means, existed to properly fill and vent this piping. Each vent consist of 1/2" piping, two 1/2" isolation valves, and a screwed cap which meets the original plant design requirements of ASME III for Class 2 systems.

Safet Summar High point vents are being added to the LHSI recirculation sump lines to provide a means of filling and venting piping between isolation valves. These vents will be opened for maintenance or testing only and are not used during normal plant operation. The addition of high point vents does not affect the operation or design of the system. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

'Figure 6.3.2-3 MEM/H0-920013.0/50/OS1

,Change to Facility as Described in the FSAR

Title:

PCR-05032, Manipulator Crane Upgrade Functional Summar This plant modification upgraded various control, operational and safety features of the plant refueling manipulator crane ~ These features include the gripper actuation system; speed control system; hoist limit switch and associated control circuitry; load cell and associated control circuitry; bridge/trolley position indication system; and the control console. In addition, the following new features will be added: underload safety circuit; slow speed zone in basket area; mast-" down overtravel safety circuit; light/heavy selector switch; and hoist, bridge and trolley jog switches.

Safet Summar The proposed manipulator crane upgrades will increase the safety and convenience of the refueling operation. The crane safety interlocks, outlined in FSAR Section 9.1.4.3.1, are not affected, with the following exception: a jog permissive is added to permit the machine to traverse with the gripper engaged and the guide tube extended, during positioning of the fuel assembly within the core.

Before, the interlock allowed,. only manual, traversing in this situation. Traversing is used as an alternate means of positioning the fuel assembly to avoid damage which may occur by the interaction between the fuel assembly being placed and the assemblies in-place.

The defeat of this interlock is acceptable for the following reasons: with the gripper engaged and the guide tube extended, the machine can only be traversed using the jog switches; the jog switches must be held in place by the operator to initiate movement (spring return to center); the use of the jog switches wi,ll allow a maximum speed of only 2 feet per minute for bridge and trolley movement and only 5 feet per minute'or hoist operation. The increased convenience to'he operator in comparison to the manual mode, in unison with the above listed restrictions, render this portion of the crane upgrade both safe and desirable.

The manipulator crane is non-safety related although it is seismically designed. The vendor, Stearns-Roger, has documented that the incorporation of this upgrade has no seismic effect on the manipulator crane since all parts replace similar parts which are removed. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunct'ion than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

MEM/H0-920013.0/51/Osl

Change to Facility as Described in the FSAR (continued)

FSAR

Reference:

Figure 9.1.4-2 Section 9.1.4 MEM/H0-920013.0/52/OS1

Change to Facility as Described in the FSAR

Title:

PCR-05193, Component Cooling Water Systems Corrosion Inhibitor Replacement Functional Summar This plant modification replaces the chromate corrosion inhibitor in the Waste Processing Building and Reactor Auxiliary Building Component Cooling Water Systems and the Boron Regeneration System with a molybdate/nitrite/tolyltriazole (MNT) inhibitor.

Safet Summar Issues regarding replacing the chromate inhibitor in the Component Cooling Water Systems have been reviewed. Based on literature reviews and vendor consultations, MNT mixed inhibitor is an appropriate replacement inhibitor. This change should reduce expenses associated with disposal of chromated solutions, reduce the amount of hazardous waste material in the plant, and reduce the potential for producing a mixed waste without compromising corrosion protection. This change does not increase the probability oi consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Tables 9.2.2-2 and 9.2.10-2 MEM/H0-920013.0/53/Osl

Change to Facility as Described in the FSAR

Title:

PCR-05222, Emergency. Exhaust Boundaries For Reactor Auxiliary Building Functional Summar This plant modification removes the spare Charging Safety Injection Pump (CSIP) room and Valve Gallery at column line 31/D-E from the Reactor Auxiliary Building (RAB) Emergency Exhaust System. This was accomplished by capping ventilation duct and disabling dampers.

Safet Summar The purpose of the RAB Emergency Exhaust System is to mitigate the effects of a long-term passive failure in the containment sump water recirculation system. There is no piping in the Spare CSIP Room.

The only piping in the Valve Gallery is associated with the boration portion of the Chemical and Volume Control System, which is not in use during the recirculation mode. These areas cannot contribute to an unfiltered, unmonitored release from a long-term passive failure in the containment sump recirculation system. Taking these areas out of the pressure boundary has no adverse impact on plant or public safety.

The 300 CFM previously exhausted from those areas will be redistributed by the system balance and is a change in the conservative direction, as other areas will experience a slightly higher flow rate (negative pressure). Total system flow will not be affected due to the flow controlling 'variable inlet vanes. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

FSAR Figures 9.4.3-1 and 9.4.3-2 MEM/H0-920013.0/54/OS1

Change to Facility as Described in the FSAR

Title:

PCR-04882, Radwaste Demineralization System Functional Summar This plant modification is considered to be a major change to the Radwaste Process System. The Modular Fluidized Transfer Demineralizer System (MFTDS) has been changed from an alternate process system to the primary process system for liquid radioactive waste. The Reverse Osmosis/Evaporator Systems have been designated as alternate process systems to be placed in long term shutdown.

The Volume Reduction System, Secondary Waste Evaporators, and the Solid Radwaste System are being abandoned in place.

The FSAR Chapter 11, has been revised and submitted reflecting these changes (Amendment 43, dated October 24, 1991). The Solid Radwaste section was updated to reflect liquid waste and dry active waste being processed by vendor services. The Liquid Radwaste section was updated to reflect current input volumes, no segregation of floor drains, equipment drains, chemical drains, or laundry and hot shower drains for processing through the Radwaste Demineralized System, and zero recycle of processed waste. The source terms and input volumes were updated to reflect the impact of spent fuel shipment from other CP&L Plants and draining of water from spent fuel pools to the Radwaste System. The use of the MFTDS results in decreased operational costs and reduced burial volumes.

Safet Summar The affected systems are not mitigating systems for any Chapter 15 accident analysis. The Liquid Radwaste System is an initiating system for Chapter 15 accident analysis, however, the changes had no impact on any evaluated accident or any other safety equipment.

Gale Code and LADTAP II computer programs were run to show compliance with 10CFR20 and 10CFR50 design objectives. The computer codes showed an increase in the concentration of radioactive isotopes in the liquid waste effluent and corresponding increase in effluent dose. This increase was small and in compliance with .

10CFR20 and 10CFR50 design objectives. A Plant Nuclear Safety Committee (PNSC) review concluded that although the concentrations in the revised FSAR tables were increased, the increases were below 10CFR release concentration levels and resulted in a minor infringement on the margin of safety.

MEM/H0-920013.0/55/OS1

Change to Facility as Described in the FSAR Safet Summar  : (continued)

The dry active waste is, being compacted by a vendor service and is shipped to burial either by the vendor or directly. This is an acceptable alternative to the use of the original compactor and poses no new hazards or safety concerns.

The resins are dewatered by a vendor service and shipped to burial in HIC's. This is an approved method of disposal. The amount of solid waste to be buried is significantly less using this alternative. This change does not increase the probability or consequences of analyzed accidents with the exception of the minor infringement noted above, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. Thus, no unreviewed safety question exists.

FSAR

Reference:

Section 11 MEM/H0-920013.0/56/OS1