ML19324B473
| ML19324B473 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/26/1989 |
| From: | Mcburnett M HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ST-HL-AE-3260, NUDOCS 8911060400 | |
| Download: ML19324B473 (229) | |
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! ' The Light l' company
- P.O. Ilox 1700 llouston. Ilxas 77001 (713) 228 9211
- Houston Lighting Ae Power,,_._..... _ ,
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- October 26, 1989 ST-ilL AE 3260 File No.
- G20.01, C21.01 10CFR50.59
.U.'S. Nuclear Regulatory Commission !
Attention: Document Control Desk Washington, DC 20555 e
- South Texas Project Electric Generating Station Units 1 and 2 Docket Nos. 50-498 and 50 499 Submittal of Annual Summary Report Eggardine 10CFR50.59 Evaluations ,
Pursuant to 10CFR50.59 Houston Lighting & Power Company (HL&P) submits ,
this annual report which describes changes, tests, and experiments associated- ;
with the South Texas Project Electric Generating Station and the required i safety evaluations. !
If there are any questions on this matter, please contact me at -l (512) 9/? 8530.
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Manager Support Licensing l -.
MAM/PLW/n1 Attachments: Summaries of Unreviewed Safety Question Evaluations 8911060400 891026 PDR ADOCK 05000498 R PNU ~'
}sl7 A1/Pl .NL7 1 A Subsidiary of Houston Industries incorporated
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' Ilouston 1.ightiiig & Power Conipany ST-HL-AE-3260 File No.: G20.01, G21.01
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- Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 Houston, TX 77001 George Dick, Project Manager U. S. Nuclear Regulatory Commission INPO Washington, DC 20555 Records Center 1100 Circle 75 Parkway J. I. Tapia Atlanta, GA 30339-3064 n Senior Resident Inspector y c/o U. S. Nuclear Regulatory Commission Dr. Joseph M. Hendrie P. O. Box 910 50 Be11 port Lane Bay City, TX 77414 Be11 port, NY 11713 J. R. Newman, Esquire .D. K. Lacker Newman & Holtzinger, P.C.. Bureau of Radiation Control 1615 L' Street, N.W. Texas Department of Health Washington, DC 20036 1100 West 49th Street Austin, TX 78756-3189 R. L. Range /R. P. Verret Central Power & Light Company P. O.' Box 2121 Corpus Christi, TX 78403 i
R. John Miner (2 copies)
Chief Operating Officer City of Austin Electric Utility L 721 Barton Springs Road l Austin, TX 78704 i '
L R. J. Costello/M. T. Hardt City Public Service Board i P. O. Box 1771 i San Antonio, TX 78296 ,
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- Receives attachments i
Revised 06/16/89 NL.DIST i
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4 Atttchment ST HL AE-3260 Page l'of 227 Unreviewed Safety Question Evaluation #88-008
Subject:
Replacement of TGB Sump Radiation Monitor Sample Pump
Description:
CCP 1 J-FST-0572 addresses addition of a new staple sump pump to the TCB Sump No. 1 for Radiation Monitor RT-8041. At present, monitor sample pump takes its sample from the discharge of the TCB drain sump #1 pump. Radiation honitor N1RA-RT-8041 experiences frequent loss of sample flow due to the sump pump not needing to run all the time.
Safety Evaluation:
- 1) Does the _ subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
l 1his modification has no impact on the probability of l occurrence of an. accident or its consequences because RT-8041 l is strictly a passive, nonsafety related monitor and it is L
not modeled as part of the accident analysis. This modification will not have ar.effect on the probability of occurrence of a malfunction or its consequences because RT-8041 is not safety-related and is not connected to a safety related item.
l 2) Does the subject of this evaluation create the possibility i for an accident or malfunction of a different type than any l evaluated previously in the safety analysis report?
The change has no effect on types of postulated accidents l since the TGB sump Radiation Monitoring System has no role in accident initiation.
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L 3) Does the subject of this evaluation reduce the margin of j i
safety as defined in the basis for any technical !
specification?
The proposed change will have no effect on the margin of safety provided by the Technical Specifications. The TGB l sump monitor is not considered in the bases for the Technical Specifications.
i Based upon the above, there is no unreviewed safety question.
Approved: 9/16/88 l
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Attachment ST.HL AE-3260 Page 2 of 227 Unreviewed Safety Question Evaluction #88 012
Subject:
Natural Circulation Cooldown
Description:
IPOP05-EO ES02, " Natural Circulation.Cooldown," was revised to utilize the reactor vessel head vent system..as necessary, to promote mixing and cooling of the rer.ctor vessel upper head .
during natural circulation cooldown without' Control Rod Drive Mechanism Cooling Fans.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ,
l analysis report?
l The subject of this evaluation does not increase the probability of occurrence or the consequences of an accident or malfunction of ,
equipment important to safety previously evaluated in the safety analysis report because use of the calculated upper head thermocouple subcooling uncertainties will not result in operation of the reactor vessel head vent system in a manner not previously analyzed in the FSAR or the Long Term Cooling Analysis.
- 2) Does the subject of this evaluation create the possibility for an L
accident or malfunction of a different type than any evaluated L previously in the safety analysis report?
The subject of this evaluation does not creata the possibility for an accident or malfunction of a different type than any evaluated i L
previously in the safety analysis report because use of the upper head o thermocouple subcooling uncertainty only affects operation of the reactor vessel head vent system. The Long Term Cooling Analysis previously analyzed use of the reactor vessel head vent system during natural circulation cooldown. During Natural Circulation Cooldown, the head vents are operated to prevent formation of a steam bubble in the reactor vessel upper head by maintaining a specified amount of i
! subccoling in the upper head. This evaluation concerns a change in the specified amount of subcooling due to different instrument l uncertainties than were used in the Long Term Cooling Analysis; however, the valves are operated in accordance with the Technical L Specification basis.
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4 <' I Unreviewed Safecy Question Evaluation w88 012 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The subject of this evaluation does not reduce the mergin of safety as defined in.the bases for any technical specification because the~ basis .
-for Technical Specification 3/4.4.11 states that the reactor vessel head vent systcm is "...provided to exhaust noncondensible gases and/or steam from the Reactor Coolant System that could exhibit natural circulation core cooling," and use of this system is. consistent with the Technical Specification basis.
Based upon the above, there is no unreviewed safety question.
Approved: 10/14/88 i
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Page 4 of 227
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Unreviewed Safety Question Evaluation *S8 013 I
Subject:
Natural Circulation Cooldown Without Letdown
Description:
The procedure for Natural Circulation Cooldown Without Letdown is being revised to address utilization of the reactor vessel head l
vent system to promote mixing and cooling of the reactor vessel upper head during a natural circulation cooldown without Control Rod Drive Mechanism cooling fans, a ,
Safety Evaluation:
- 1) Does the subject of. this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety analysis report?
The subject of this evaluation does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment it.portant to safety previously evaluated in the safety analysis report because the calculated upper head thermocouple subcooling uncertainties will not result in operation of the reactor vessel head vent system in a manner not previously analyzed in the FSAR or the Long Term Cooling Analysis.
- 2) Does the subject of this evaluation create the possibility for an L
accident or malfunction of a different type than any evaluated L previously in the safety analysis, report?
This change does not create the possibility for an accident or malfunction of a different type than any evaluated previously in the l safety analysis report because use of the upper head thermocouple subcooling uncertainty only affects operation of the reactor vessel head vent system. The Long Term Cooling Analysis previously analyzed use of the reactor vessel head vent system during a natural circulation cooldown.
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- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change does not reduce the margin of safety as defined in the basis for any technical specification because the basis for Technical L Specification 3/4.4.11 states that the reactor vessel head vent system is "provided to exhaust noncondensible gases and/or steam from the Reactor Coolant System that could inhibit natural circulation core cooling," so that use of this system is consistent with the Technical Specifications.
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Based upon the above, there is no unreviewed safety question.
Approved: 10/14/88 A1/Pl.NL7
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Attachment ST-HL AE 3260 L Page 5 of 227
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Unreviewed Safety Question Evaluation #88-079 i
Subject:
Spring Charging Motor Disconnect Switch on 4.16 KV Breaker a
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Description:
MOD 87 028 addresses abandoning in place the spring charging motor disconnect switch on 4.16 KV Class IE switchgear breakers by bypassing the switch contacts.
The class IE 4160 V circuit breakers at STPEGS have a toggle switch which controls power to the spring charging motor. .
I Placing this switch in the "off" position would prevent the.
breaker closing springs from being recharged after one breaker i I
closing, cycle is initiated. However, placing the toggle switch, which is located in the breaker inside the cubicle door, in the i "off" position does not actuato the loss of control power alarm.
An NRC. study which was documented in IE Information Notico 83-50 concluded that failure of Class 1E circuit breakers to close on demand is attributed to problems within the malfunctioning circuit breaker closing control circuits located inside the breaker cubicle. One of the causes for such failures is identified as malfunctions in the spring charging motor or.
associated spring position switch controls.
The purpose of bypassing the spring-charging mocor disconnect 'l switch on the 4160 V class IE breakers is to ensure that the j power supply to the spring charging motor is not disconnected. :
L l L Safety Evaluation: l
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safcty analycis report?
The purpose of bypassing the switch contacts is to avoid l'
equipment malfunction due to human error (e.g. , leaving the ,
switch in "0FF" position). Hence, this modification
, decreases the probability of occurrence or malfunction of l equipment important to safety as previously evaluated in the SAR.
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o Attachment ST-HL AE-3260 Page 6 of 227 j Unreviewed Safety Question Evaluation #88 079 (Cont'd)
- 2) Does: the subject of this evaluation create .the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Bypassing the switch contacts does not create the possibility of a new type of accident, nor does it change overall operation of-the breaker. Therefore, it does not create the possibility for j an accident or malfunction of a different type then any.
evaluated previously in the safety analysis report. 1 s
- 3) Does the subject of this evaluation reduce the margin of safecy-as defined in the basis for any technical specification?
l Based on the description above, the subject of this evaluation does not reduce the margin of safety as defined'in the basis for Technical Specification 3/4.8.
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Based upon the above, there is no unreviewed safety question. I Approved: 10/1/88 i
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Page 7 of 227
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Unreviewed Safety Question Evaluation #88 082 Subj ect : - Deletion of Excessive Cooldown Protection l
Description:
This proposed change deletes references to Excessive Cooldown
[ Protection from Tables 3.3-3, 3.3-4, 3.3-5, and 4.3 2 of Technical Specification 3/4.3.2. An application to amend the Operating.
License was submitted to the NRC by letter dated May 8, 1988
.(ST-HL-AE-2656).
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Attachment L ST HL AE-3260
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. Unreviewed Safety Question Evaluation #88 093 p
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Subject:
Addition of Electrohydraulic Cabinet Enclosure HVAC System
Description:
This change adds an Electrohydrualie Cabinet Enclosure HVAC Subeystem to the TGB HVAC System. The equipment added is a window type packaged air conditioning unit added to keep the enclosure below the maxin a design temperature limit.
L Safety Evaluation:
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- 1) Does the subject of this evaluation increase the probability of j occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety analysis report?
This change involves a nonsafety class system in the TGB. Therefore, it would have no impact on the safe operation or shutdown of the plant previously evaluated in the safety analysis report. Additionally, the change to keep the enclosure below its aaximum design temperature limit will help ensure that the electrohydraulics perform as designed.
- 2) Does the subject of this evaluation create the possibility for en accident or malfunction of a different type than any evaluated
.previously in the safety analysis report?
The subject change involves a nonsafety class system. Therefore, it l does not create a safety hazard from the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical siecification?
Thie subject change involves a nonsafety class system for which there are no Technical Specification requirements. Therefore, it does not i have any impact on the technical specifications including the safety )
l margins considered in the technical specifications.
l l Based upon the above, there is no unreviewed safety question.
1 Approved: 8/29/88 L l l
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!~ ST HLrAE 3260 Page 9 of 227
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I' l p Unreviewed Safety Question Evaluation #88-116-g
Subject:
Carpeting in MAB I
Description:
Carpeting is being added to the floor and walls of the MAB Room 230 (el. 41'-0") to act as a sound absorbing material. I Safety Evaluation:
1), Does the subject of this evaluation increase the probability of ,
occurrence or the consequences of an accident or malfunction-of equipment important to safety previously evaluated in the safety ,
analysis report?
Addition of carpeting to HAB Room 230 represents an increase in combustible loading above the value currently reported in the Flud for the'"below the suspended ceiling" portion of FA3Z147. The FSAR is being revised to redistribute the reported combustible values for FA3Z147 such '
that the FRAR reported value for the "below the suspended ceiling" is not exceeded by the: calculated value. This redistribution is possible
, due to the significant margin in the FRAR reported value. Additionally, the FSAR revision allows - the use of carpeting procured to testing-requirements equivalent to those of ASTM E-84 which is currently referenced in the FHAR. This change is necessary because the carpet I industry no longer utilizes ASTM E-84 as their testing standard, l-Neither of the changes increase the probability of occurrence or E consequences of an accident or equipment malfunction.
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- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated previously in the safety analysis report?
As described above, redistribution of reported combustible loading l values and the use of equivalent testing standards does not create the possibility for an accident or malfunction of a different type than those already evaluated in the SAR.
- 3) Does the subject of this evaluation reduce the margin of safety as -
defined in the basis for any technical specification? >
There are no technical specifications that are applicable to the items addressed by the FSAR change.
Based upon the above, there is no unroviewed safety question.
Approved: 9/16/88
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ST HL-AE-3260 l Page 10 of 227 l bi0 )
- E Unreviewed Safety Question Evaluation #88117
Subject:
Correction of Inconsistencies in Technical Specifications 3.3.3.7 1 (Toxic Cas) and 3.7.7 (Control Room Makeup and Cleanup Filtration !
System)-
Description:
This proposed change corrects inconsistencies between Technical Specifications 3.3.3.7 and 3.7.7. Action statements 3.3.3.7(a) and (b) require placing the Control Room HVAC in the recirculation mode. Action Statement 3.7.7(a) (Modes 5 and 6) requires placing-the system in the rectreviation and makeup modes. Conditions >
could exist whereby it would be impossible to meet both of these Action Statements at the same time. An application to amend the Operating License was submitted to the NRC by letter dated January 17, 1989 (ST-HL AE 2948).
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ST IIL AE-3260 i Page 11 of 227 Unreviewed Safety Question Evaluation #88-124
Subject:
Removal of Alarm Circuits from the Electrical Penetration Nitrogen l System
Description:
This change addresses removal of alarm circuits from the electrical penetration nitrogen system. The commitment to continually pressurize and monitor the containment electrical penetrations is deleted.
Safety Evaluation: ,
- 1) Does the subject of > this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Deletion of the continuous nitrogen pressurization and monitoring will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report as the electrical penetrations
'have been designed and qualified per Regulatory Guide 1.63 and IEEE317-1976 as described in FSAR Section 8.3.1.1. In addition, this changa deletes only the nitrogen pressurization requirement and its pressure alarm. It does not affect the penetration seals which perform the safety function.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The design basis has not changed, and the change does not affect the penetration seals, so the possibility is not created for an accident or malfunction of a different type than evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as 1 defined in the basis for any technical specification?
As the design basis is not affected and the change does not change the seal design, the margin of safety as defined in the basis for any technical specification is not reduced.
Based upon the above, there is no unreviewed safety question.
Approved: 8/30/88 A1/Pl.NL7
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Page 12 of 227 r ,
l 'Unreviewed Safety Question Evaluation w88 125
Subject:
Diesel Cenerator Breaker Timing Relay
Description:
This change addresses installation of an Agastat timing relay in the diesel generator breaker " LOOP" permissive circuit from the a sequencer. This is to eliminate a potential lockout (failure to i L close) of the diesel generator breaker and the 480 VAC Class IE load center breakers. ,
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The design change will reduce the probability of occurrence or consequences of an accident or malfunction of eqiupment. The delay imposed on the close signal to the diesel generator breaker will ensure r that the closing spring for the breaker is fully charged prior to receiving the close signal. The delay will also allow the Class 1E load center breakers close springs to be recharged (after being stripped due-to loss of offsite power) prior to receiving the close signal from the sequencer. This is the intended operation of the system as originally described in the FSAR and will not further delay the supply of power to the safety related equipment as committed in'the FSAR.
- 2) Does the subject of this evaluation create the possibility for an accident or nalfunction of a different type than any evaluated previously in the safety analysis report? -
l The design change does not create the possibility for an accident or l malfunction of a different type than any evaluated previously in the FSAR. The system logic was revised only to compensate for the action of the anti-pump relay in the closing circuit of the breaker which was previously unknown. The design change permits the system to operate and o meet the implied commitment in the FSAR for a LOOP occurring while the diesel generator is running.
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Unreviewed Safety Question Evaluation #88 125 (Cont'd)
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- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? l The margin of safety as defined in the basis for the technical l specifications remains the same. The potential is eliminated for the !
anti-pump relay to prohibit the diesel generator breaker and the load center breakers from reclosing because the closing spring was not recharged prict to receiving the close signal. The close signal is delayed to allow adequate time for the closing spring to be recharged i but still permits the loads to be sequenced on properly and within the required time constraint as described in the design drawings and committed in the FSAR.
Based upon the above, there is no unreviewed safety question.
Approved: 8/29/88 A1/Pl .NL7
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Attcchm:nt i ST-HLaAE 3260 Page l's of 227 ,
Unreviewed Safety Question Evaluation #88-127 ,
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Subject:
Replace flow Switch on RCP 1A Upper Bearing Cooler
Description:
This change deletes a 120 VAC power circuit through a non-Class 1E containment ponetration as described in the FSAR and replaces a -
Mid West flow switch with a Static 0 Ring flow switch to prevent spuriouc alarms on power loss /testoration and provide the same kind of flow switch as ir. stalled on RCP's IB, 10, and ID upper bearing coolers. ,
Safety Evaluation: f
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The subject flow switch (Instrument tag No. N1CC FSL-4615) does not '
perform any safety-related functions. The replacement flow switch (Static-0-Ring Model No. 103-AS-K502-NA-CIA-RR) is qualified to maintain pressure boundary requirements per IC-II instrument class requirements and is identical to the instruments performing the same function on the !
other RCP's. Therefore, this change does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis repert. ,
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! 2) Does the subject of this evaluation create the possibility for an ,
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The subject instrument does not perform any safety-related functions.
The replacement switch is identical to those used to perform the same function on the other three RCP's. This change deletes a 120 VAC power circuit through a non-Class 1E containment penetration, therefore reducing penetration heat loads per Calculation No. 3E269EC5047.
o Therefore, this change does not create the possibility for an accident I or malfunction of a different type than any evaluated previously in the I safety analysis report.
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Unreviewed Safety Question Evaluation #88 127 (Cont'd) 3). Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The subject instrument does not perform any safety related function, and replacement of the instrument per ECN No. 88 E 0186 reduces heat loads -
on the affected electrical penetration, thus increcasing the margin of safety per Calculation No. 3E269EC5047. +
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Based upon the above, there is no unreviewed safety question.
Approved: 9/4/88 ,
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[ Page 16 of 227 Unreviewed Safety Question Evaluation #88-128
Subject:
. Airborne Concentration for Fuel Handling Building and Mechanical '
Auxiliary Building
Description:
The FSAR is being amended to reflect revised airborn concentation for FHB and MAB due to change in HVAC flow rates as measured by y startup tests.
Safety Evaluation: ,
L 1) Does the subject of this evaluation increase the probability of k . occurrence or the consequences of an accident or malfunction of '
L equipment important to safety previously evaluated in the safety analysis report?
No physical or system operational change has been made to the plant.
The increased airborne concentration is below the 10CFR20.103 limit accepted by the NRC. Therefore, the subject change does not increase the probability of occurrence or the consequences of an accident or r malfunction of equipment important to safety previously evaluated in the safety analysis report, f
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since no physical or system operational change has been made to the
_ plant, and the increased airborne concentration is below the 10CFR20.103 limit accepted by the NRC, the subject change does not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does tha subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
No technical specification is based on the airborne concentration values provided in the safety analysis report. Therefore, there is no impact p on the margin of safety for any technical specification.
L Based upon the above, there is no unreviewed safety ques; ion.
Approved: 8/29/88 l
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Page 17 of 227 Unreviewed Safety Question Evaluation w88-129 ;
Subject:
' East Gatehouse Phase 2 Modification
Description:
This change relocates the security officer (s) responsible for collecting security badges during personnel egress from the protected area. This process is described in the Physical -
Security Plan which will be revised to correspond to the new configuration. Badges will be left at the EGH Guard Island rather than at the turnstiles.
Safety Evaluation: .
- 1) Does the subject of this evaluation increase the probability of .
occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety !
analysis' report?
This modification is confined to the East Gatehouse and is sufficiently removed'from safety related equipment to preclude a malfunction of that equipment. The modification does not alter any design aspect concerning- o consequences of an accident or malfunction. This modification does not decrease the effectiveness of the Security Plan as required by 10CFR50.54(p).
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This modification is confined to the East Gatehouse and merely changes theclocation of the security officer responsible for collecting security badges to process personnel offsite. The change provides better owner l
control regarding 10CFR73.55(d)(5) which prohibits badges from leaving the protected area unless adequate safeguards are provided to assure that the security of the badge is not jeopardized (NUREG-0908). The modification will not result in an accident or malfunction of a type not L previously evaluated.
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Attachment ST HL AE 3260 Page 18 of 227
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Unreviewed Safety Question Evaluation #88 129 (cont'd)
- 3) . Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Technical Specifications describe no safety margins or bases relative to Nuclear Security. They do, however. require PORC review of Security ,
Plan and procedure changes which will be generated from this design implementation. Based on the remote location, this East Gatehouse change can not have an adverse affect on normal operations. -During emergencies Nuclear Security has authorization and means to suspend ,
safeguards measures. This modification does not hamper those.means that ,
are currently available to suspend safeguards measures. ,
. Based upon the above, there is no unreviewed safety question.
Approved: 9/4/88 4
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L Unreviewed Safety Question Evaluation #88 130 j
-Subjecti Request for Exemption to the Requirements of 10CFR50.54(w), " Property .
Insurance"
Description:
HIAP requests exemption from the requirements of 10CFR50.54(w),
specifically the decontamination priority requirement and the
, requirement to designate a trustee for insurance purposes.
. Safety Evaluation:-
r 1) Docs the subject of this evaluation increase the probability of-occurrence or the consequences of an accident or malfunction of ,
equipment important to' safety previously evaluated in the safety analysis report?
Exemption from those requirements has no effect on the operation of STPEGS. This only affects how insurance funds are to be disbursed following an accident. Exemption will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report, t
- 2) Does the subject of this evaluation create the possibility for an l' accident or malfunction of a different type than any evaluated previously in the safety analysis. report?
Exemption from these requirements has no effect on the operation of '
L STPEGS. This only affects how insurance funds are to be disbursed following an accident. Exemption will not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
l-p 3) Does the subject of this ovaluation reduce the margin of safety as defined in the basis for any technical specification?
Exemption from these requirements has no~effect on the operations of I l STPEGS. This only affects how insurance funds are to be disbursed I following an accident. Exemption will not reduce the margin of safety as defined in the basis for any technical snecification.
l Based upon the above, there is no unreviewed safety question.
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, Approved: 8/25/88 1
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Unreviewed Safety Question Evaluation #R8 131
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Subject:
Steam Generator Slowdown profilters
Description:
Temporary modificatien 71 58 88 81 addresses removal of the 5 l micron filter from filter assembly 75201MTR001A and replacing it h with a
- dummy cartridge
- which will allow free flow of blowdown water to the demineralizers, i
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equiptent important to safety previously evaluated in the safety analysis report?
bre are no accidents evaluated in t.he PSAR which require the Steam Generator Blowdown prefilters to be operable. Therefore, this does not increase the probability of occurrence or the consequences of an accident er malfunciton of equipment important to safety previously evaluated in the FFAR.
- 2) Does the a.4 ject of this evaluation create the possibility for an accident o malfunction of a differer.t type than any evaluated previously in the safety analysis report?
.The Steam Generator Blowdown filters do not. impact the safe operability of the unctor, nor do they provide a boundary to prevent an uncontrolled release of radioactivity to the environment. Therefore, this item does not create the possibility for an accident of a different type than any previously evaluated in the FSAR.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Steam Cenerator Blowdown prefilters do not impact the safe 6 operability of the reactor, nor do they provide a boundary to prevent
!. uncontrolled release to the environment. Therefore, this change does f not reduce the margin of safety as defined in the basis for any l' Technical Specification.
l Based upon the above, there is no unreviewed safety question.
Approved: 8/31/88 l
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Unreviewed Safety Question Evaluation 288 132 l
Subject:
Rsplacement of PASS Conductivity Monitor
Description:
This change addresses replacement of the Post. Accident Sampling Ssytem (PASS) conductivity monitor with a variable range monitor ,
'q with calibration adjustment on the front panel. The existing PASS conductivity monitor is en analog instrument that is very l difficult to calibrate, due to limited access to adjustment. The 1 new conductivity monitor is microprocessor based and can be I calibrated and range. changed from the front of the nonitor. The !
PASS Conductivity Monitor is a Quality Class 9 instrument as is j its associated conductivity sensor, which will also be replaced, j Also, conductivity measurement is not specifically required by j Regulatory Guide 1.97. The FSAR ranges are to be revised from l
'0 1000 mhos/cm" (Tables 9.3 38 and 7.5 1, and Appendix 7a) to :
- 0 1999 mhos/cm (variable)" ;
Safety Evaluation:
1 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of I equipment important to safety previously evaluateu in the safety i analysis report?
The PASS conductivity monitor does not perform a safety function. !
Failure of this monitor does not compromise any safety.related system ;
nor prevent a safe shutdown. Specifically, replacement of the i conductivity monitor with a like, or better, monitor Toes not increase ,
the probability of occurrence or the consequences of an accident or ;
malfunction of equipment important to asfety previously evaluated in the i safety analysis report since this is a nonitorint; instrument and not an !
accident mitigating type instrument. !
- 2) Does the subject of this evaluation create the possibility for an ;
accident or malfunction of a different type than any evaluated previously in the safety analysis report? ;
Replacement of the existing PASS conductivity monitor with a like, or j better, monitor does not create the possibility for a accident or t malfunction of a different type than any evaluated previously 11 the l safety analysis report since the monitor performs no active control or I protective function, f
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I Unreviewed Safety Question Evaluation w88 132 (Cont'd) l I
- 3) Does the subject of this evaluation reduce the margin of safety as 5 defined in the basis for any technical specification? I This instrument is not considered in the margin of safety as defined in 7 the basis for any technical specification. Hence, the margin of safety j is not affected. :
Based upon the above, there is no unreviewed safety question. I Approved: 9/11/88 .l i
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Unreviewed Safety Question Evaluation e88 133 l
Subject:
Manual Valves for MI Thimbles >
Description:
TSAR Section 7.7.1.9.2 describes use of a plug to isolate a [
thimble. MOD 86 214 adds non safety manual valves for isolation !
of botton. Mounted Instrumentation (MI) thimbles on the non safety . !
side of the thimbles, rather than using a plug. i j ,
Safety Evaluation. {
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of l equipment i.eportant to safety previously evaluated in the safety j analysis report? ,
i The new valves do not increase the probability of a thimble leak nor are ,
the consequences increased. Also, the values are installed and ,
seismically supported on the non. safety side of the seal plate. The thimbles will have a detector insertion check done as part of the ;
acceptance test of the new installation of the valves. This check will ensure that all the thimble paths are adequate for detector insertion.
(This check is done after any work is performed on the thimble system.) i The valve addition does not change the Action Statement of the technical .
specifications. Thus, the valve addition does not increase the probability of a malfunction or the consequences of a malfunction. In ;
addition, personnel will be exposed to radiation when manually closing a l valve in the event of a thimble leak. However, this exposure would be less than that received when plugging a leaking thimble, and the ;
plugging operation is described in the FSAR. Thus, the valve addition ;
does not increase the probability or consequences of a personnel i expostre accident. !
l
- 2) Does the subject of this evaluation create the possibility for an !
accider.t or malfunction of a different type than any evaluated ;
previously in the safety analysis report?
Addition of these valves does not create the possibility of a different type of accident or malfunction than these addressed in the safety 6 analysis report. These events are also eddressed (1).
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l i 1 Att= hment I ST.HL.AE.3260 l Fage 24 of 227 i I Unreviewed Safety Question Evaluation #88 133 (cont'd) i 1
- 3) 'Does the subjet;t of this evaluation reduce the margin of safety as I defined in the basis for any technical specification?
the RN! Technical Specifications are 3/4.2.4 and 3/4.3.3.2 which concern flux maps. Addition of the valves does not affect the flux mapping function of the BN! System. The bases of the Technical Specifications ,
will not change. The action statements for operability will not change. !
Thus, the velve addition does not reduce the margin of safety as defined !
in the basis for any technical specification. l r
Based upon the above, there is no unreviewed safety question.
,, Approved: 9/14/88 i
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Unreviewed Safety Question Evaluation w88134 l l
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Subject:
ESF Diesel Generator Fuel Oil Coolers
Description:
The ESP diesel generator fuel oil coolers are to be removed.
Safety Evaluation: ,
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analyvis report? !
This change does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to i safety previously evaluated in the safety analysis report. The oil ,
coolers are used to cool unused, recirculated fuel from the diesel fuel !
pump to a day tank which is commonly sued on diesel installations. !
STPEGS ESF diesels do not utilize a day tank since the fuel oil storage !
tank is located above the diesel rather than below the diesel which is a ,
normal practice at other diesel installations. The oil coolers are used l to cool the oil because day tanks are usually located in close proximity j to the diesel engine; this function is not reeded when there is no day '
tank. .
l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated i previously in the safety analysis report?
The fuel oil cooler is being removed since it is a source of corrosion and leakage of essential cooling water which is used as the cooling ;
medium. Removal of the fuel oil cooler will not cause a malfunction or !
accident of a different type that has not already been evalutaed or analyzed. ;
- 3) Does the subject of this evaluation reduce the margin of safety as I defined in the basis for any technical s}.ecification?
Removal of the fuel oil cooler is not related to, nor does it reduce, :
the margin of safety with respect to assurance of diesel starting requirements and generating capacity requirements as stated in Technical Specification 3/4.8. The margin of safety with respect to diesel function operability requirements remain the same as originally t designed.
l Based upon the above, there is no unreviewed safety question.
Approved: 1/30/89 A1/Pl.NL7 l
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Unreviewed Safety Question Evaluation w88 136
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Subject:
Quality Assurance During the Operations Phase !
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Description:
FSAR Section 17.2 is being revised to change the corrective action i
- section and the records section, reflect responsibility changes. l and provide consistent wording for matrixed organization reporting i F. j relationships.
! Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of
- occurrence or the consequences of an accident or malfunction of
!1 equipment important to safety previously evaluated in the safety ,
analysis report? l These changes are administrative only and will not increase the probability of occurrence or the consequences of an accident or ;
malfunction of equipment important to safety previously evaluated in the j safety analysis report, j g
- 2) Does the subject of this evaluation create the possibility for an :
accident or malfunction of a different type than any evaluated i previously in the safety analysis report? !
i These changes are administrative only and do not create the possibility ;
for an accident or malfunction of a different type than any evaluated !
previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specification? !
These chanegs are administrative only and do not reduce the margin of safety as defined in the basis for any technical specificattons.
l Based upon the above, there is no unreviewed safety question, j Approved: 11/15/68 ,
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Unreviewed Safety Question Evaluation aBB 137 !
Subject:
Relocation of Seismic Monitor !
Description:
Triaxial peak Accelerograph presently located "at about E1. 68' 0" l inside the RCB azimuth 270"" is to be relocated to "at about EL. !
68' .0" inside the RCB, azimuth 34*". This changes is to prevent ,
burnup of the accelerograph from excessive heat. ;
Safety Evaluation. .
- 1) Does the subject of this evaluation increase the probability of f occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety l analyets report?
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There is no increase in the probability of occurrence or the ,
consequences of an accident since this device is passive, with no electrical connections. The mounting has been analyzed to assure it l will support the device in the event of a seismic occurrence to prevent +
it from becomming a missilo. There is no increase in the probability of ;
malfunction of equipment important to safety since this device is :
passive and its mounting is analyzed for support during design events. *
- 2) Does the subject of this evaluation create the possibility for an i accident or malfunction of a different type than any evaluated !
previously in the safety analysis report?
The modification is to relocate a passive seismic peak accelerograph to preclude heat damage. It will not create the possibility for an !
accident or malfunction of a different type than any previously l evaluated. The mounting has been designed to adequately secure the j device to preclude damage to equipment important to safety. ;
t
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical sptcification?
The bases for the Technical Specifications are not affected by }'
relocating this device it will still perform its function. The Technical Specificatien for seismic monitoring is not altered by this relocation, t
Based upon the al+ve, there is no unreviewed safety question. i i
Approved: 10/3/88 t
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Unreviewed Safety Question Evaluation #88 138 i
Subject:
Revised Radiation Monitor Setpoints
Description:
Setpoints for Alert and Alarm for Radiation Monitor NIRA.RT.8039 (Failed Fuel Radiation Monitor) are to be revised to prevent continuous alarm. The original setpoints were based on the f ,. detection of e.ctivity from one isotope (CS 137). However, the detector for NIRA.RT 8039 is also sensitive to other gamma j radiation that is in the process fluid, which results in the monitor reading higher than the alarm setpoints. The new setpoints are calculated based on the range of isotopic activity that can be expected upon a failed fuel condition. NIRA.RT 8039 is a nonsafety related, Quality Class 9 monitor.
Safety Evaluation *
- 1) Does the subject of this evaluation increase the probability of occurrence or the cons,equences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Changing the alert and alarm setpoints for this monitor does not increase the probability of occurrence or the consequences of an accident since this is a monitoring instrument and not an accident mitigation type instrument. This change does not impact the malfunction of equipment important to safety since changing the setpoints does not affeet the operation of the radiation monitor.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
l Modifying the setpoints for alarming for NIRA.RT 8039 does not create the possibility for an accident or malfunction of a different type since
- the setpoints are calculated in accordance with SAR requirements and the i
monitor issued for monitoring gross gamma activity levels and not l accident mitigation. Changing the setpoints does not affect the CVCS letdown pipe rupture analysis since the change is in the software and not the process part of radiation monitor, i 3) Does the subject of this evaluation reduce the margin of safety as !
- defined in the basis for any technical specification?
l
- l. The margin of safety as defined in the basis of the technical i specifications is not affected since NIRA RT 8039 is not considered in the bases for any technical specifications.
Based upon the above, there is no unreviewed safety question.
Approved: 10/17/88 A1/Pl.NL7
i Att= hment I- ST.HL AE 32ti0 l Page 29 of 227 i
Unreviewed Safety Question Evaluation e88 139 g
Subject:
Regonerative Heat Cxchanger
Description:
ACI 349 allows a general temperature exposure for concrete up to 150'F and a local exposure up to 200'F without any adverre l- effects. However the concrete temperature at the supports is g 403'F(maximum) . Consequently, the concrete strength has been t considered reduced to less than 4000 pai. j o Safety Evaluation: ;
- i i
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of '
equipment important to safety previously evaluated in the safety analysis report? !
The anchor bolts have been evaluated for pullout and bearing based on l the concrete temperatures and reactions provided by Westinghouse. The !
analysis shows that the concrete will carry all design loads applied by ;
L the heat exchanger. Therefore, there will not be an increase in the '
probability of occurrence or the consequences of an accident or I malfuriction of equipment important to safety, t
- 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated i previously in the safety enalysis report?
Calculations show that even with concrete temperatures greater than .j 200*F, the concrete will still carry the design loads. Therefore, the possibility is not created for an accident or wa1 function of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as ;
defined in the basis for any technical specification?
[
The applicable Technical Specifications concerning operability of the !
CVCS would be those concerning boration systems addressed in Section ;
3/4.1 of the Tech. Specs. However, there is no impact on these as a j result of the increased concrete temperatures. l Based upon the above, there is no unreviewed safety question. I i
Approved: 10/28/83 !
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i Attachment ST.HL.AE 3260 Page 30 of 227 Unreviewed Safety Question Evaluation w88 142
Subject:
Spent Fuel Pool Cooling and Cleanup System
Description:
This change allows the use of either mixed resins (anton and cation) or cation or anion only in the Spent Fuel Pool Cooling and
, Cleanup (SFPCC) System do.sineralizers as indicated by the type of contamination detected by the required chemical Analysis.
, Safety Evaluation:
- 1) Does the subject of this evaluation increase t.he probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The purification subsystem (demineralizers and filters) of the SFpCC System is not required for safety functions. The subsystem (s) is not considered in the accident analysis and no credit is taken for the, system (s) operability. The ability of the system to cool spent fuel is not affected by the proposed change, the change does not affect reliability of the system, and there is no effect on the integrity of the spent fuel cladding. Therefore, the type of resin used in the purification subsystem (s) does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The purpose of the purification gubsystem is to raintain optical clarity of fuel pool water. The type of resin used in the demineralizer(s) does not affect the clarification capability. The change in resin ration enhances the efficiency of cation / anion removal. Therefore, the change does not create the possibility for an accident or malfunction of a different type.
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Page 31 of 227 l
r Unreviewed Safety Question Evaluation e88142 (Cont'd) [
- 3) Does the subject of this evaluation reduce the margin of safety as !
' defined in the basis for any technical specification? l The technical specification does not require that the purification loop of the SFPCC system be demonstrated operable. The purification loop !
does not form the bases for any technical specification. Therefore, the ,
change does not reduce the margin of safety as defined in the basis for ;
any technical specification. .
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i Based upon the above, there is no unreviewed safety question. -i Approved: 10/28/88 j l
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i Unreviewed Safety Question Evaluation e88 143
Subject:
ElectrAcal Auxiliary Building HVAC System
Description:
EAB Main Area HVAC return air fan operation requirement is to be deleted from normal plant operation of EAB HVAC system.
Safety Evaluation:
- 1) Does the subject of this evaluation inevease the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The system continues to meet its design function requirements for providing conditioned air for EAB areas. This change does not increase the probability of a failure of the EAB HVAC system.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Operation of EAB supply fans without their respective return air fans results in very little additional horsepower requirements for the supply fan motors during normal operation. However, the required power is less than the capability of the fan motors. Therefore, there is no malfunction of a dif ferent type which would jeopardize the reliability of the supply fans to perform their intended function during an accident or safe shutdown.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change does not have an impact on technical specification requirements since the return fans are still availabic for plant design basis accidents.
Based upon the above, there is no unreviewed safety question.
l Approved: 11/3/88 -
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Page 33 of 227 !
f Unreviewed Safety Question Evaluation e88 145- ,
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Subject:
Unit 1 Technical Specifications
Description:
The Unit 1 Technical Specifications are being revised to resolve .i l all outstanding issues to ensure that combined Technical l Specifications can be issued with the Unit 2 license. A request .i to amend the Unit 1 Technical Specifications was submitted to the j
- NRC by letter dated November. 3,1988 (ST.HL. AE.2854). The request !
g concluded that no significant hasards consideration exists. [
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- Unreviewed Safety Question Evaluation w88 146 l Subj ect
- Block Open ECW Valves
Description:
Due to actuator failure, under this temporary modification the actuator will be removed, a temporary handle installed and locked open, defeating the active function of this valve. These
[ temporary modifications result in required operator action when ECW pond temperature drops beow 54*F.
! Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of
- equipment important to safety previously evaluated in the safety analysis report?
FSAR Section 9.2.1.2.2.4 addresses automatic regulation of chiller condenser pressure by electrohydraulic valves. However, recent chiller operation at ECW temperatures below 53.3'F shows that ECW flow regulation through the chiller condenser section can be accomplished by throttling the manually. operated inlet valve by operator action.
The essential chillers will continue to perform their safety function.
, With the temporary modifications and operator actions, the consequences of accidents previously evaluated in the FSAR are not impacted.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The safety functions of the components modified, the effects, ramifications, and preventive measures taken have been considered.
This change does not create the possibility for an accident of a different type than previously evaluated in the FSAR since the chillers will remain operational by operator action.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The bases of the technical specifications have been reviewed; this modification does not reduce the margin of safety as defined in the technical specifications. Operating the upstream valves to regulate ECW flow through the chiller condenser will perform the same control function as the EHC valve located downstream of the condensers.
Based upon the above, there is no unreviewed safety question.
Approved: 3/5/89 A1/Pl.NL7
y AttGhment ST.HL.AE.3260 i Page 35 of 227 !
Unreviewed Safety Question Evaluation #88 147 L Subj ect: EAR Main Area Return Air Fans :
Description:
Existing 60 HP motors are to be replaced with 75HP motors for EAB l main area return air fans, ;
t i Safety Evaluation: -l
- 1) Does the subject of this evaluation increase the probability of -
occurrence or the coasequences of an accident or malfunction.of equipment important to safety previously evaluated in the safety '
analysis report? ,
This change increases the rating of the fan motors. The increase in horsepower is within the existing equipment capabilities . Therefore, there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to j safety previously evaluated in the safety analysis report, ,
f I
- 2) Does the subject of this evaluation create the possibility for an ;
accident or malfunction of a different type than any evaluated !
previously in the safety analysis report? !
There is no change in operating philosophy, All equipment and components will operate within their design parameters and therefore '
will not create the possibility for an accident or malfunction of a ;
different type. l
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specification?
There is no decrease in operating philosophy, All equipment and l components will operate within their design parareeters and thsrefore ;
will not decrease the margin of safety.
Based upon the above, there is no unreviewed safety question.
Approved: 12/12/88 ;
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Unreviawed Safety Question Evaluation #88 148
Subject:
PASS Containment Normal Sump Sample Pump l
Description:
This change adds a relief / pressure control valve which will regulate the sample pump discharge pressure so the pump will operate without a high discharge pressure being attained. This is a self regulated valve that does not require powetor operator assistance to perform its function.
l Safety Evaluation: ,
- 1) Does the subject of this evaluation increase the probability of occurrence or tha consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety t
analysis report?
Operation of the PASS System is not essential for plant safety, t
Portions of the PASS sample lines beyond the outside containmert isolation valve are not part of the Reactor Coolant Pressure Boundary (RCPB) and are not designed to seismic Category I requirements.
Failure of sample lines outside containment does not affect the RCPB or the capability to shut down the reactor. Therefore, adoition of this valve and tubing does not increase the probability of occurrence or the consequences of an accident or ualfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Failure of sample lines has already been evaluated in the SAR.
Addition of this valve and tubing does not create the possibility for an accident or malfunction of a different type than any evaluated previously since the tubing and valve will be installed downstream of the outside containment isolation valve, and will be installed in accordance with existing procedures.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The PASS containment sump sampling system outside the containment is not considered in the margin of safety as defined in the basis for any l
Technical Specification. Hence, the margin of safety is not affected I by this change.
l.
Based upon the above, there is no unreviewed safety question.
1 l Approved: 11/30/88 l
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l- Unreviewed Safety Question Evaluation e88 149 i
Subject:
Cable Separation
Description:
Separation criteria was not met between Class 1E and non. Class 1E
- circuits in two isolation transformers. Transformer primary (Class IE) and secondary (non Class 1E) Internal cables are j bundled together in the transformer cabinet.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurronce or the consequences of an accident or malfunction of equipnent important to safety previously evaluated in the safety analysis report?
The isolation transformer is intended to be the isolation devices; therefore, the circuit from t.he Class 1E source (thermal magnetic breakers) to the Class IE isolation transformer is Class 1E. Wiring l leavir.g the secondary site of the transformer is non. Class 1E:
separation beeveen this wiring is not maintained. However, the vendor hae provided protection for the isolation transformer and wiring by maans of a thermal magnetic circuit breaker. Even if protection wore not provided, a wiring fault would result in loss of the eseential AC lighting. However, lighting is crranged so that alternate fixtures are fed from redundant buses, in addition, backup lighting is provided by the emergency DC lighting system in the event of loss of essential AC lighting.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Based upon the vendor.provided circuit breakers, the possibility of losing the Class 1E MCC bus would be prevented and a failure at the subject area would only result in the loss of essential AC lighting, assuming simultaneoud failure at both transformers. Otherwise, only half of the essential AC lighting would be lost which would be
- supplemented by DC. backed li6 hting.
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Attachment ST.HL.AE 3260 Page 38 of 227 i Unreviewed Safety Question Evaluation w88 149 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as
- defined in the basis for any technical specification?
i, The vendor provided breaker will prevent the possibility of losing the Therefore, the margin of safety is not reduced for Class IE MCC bus.
loads fed from the MCC. Operator performance would not be dimished as j loss of this lighting has been anticipated and DC backed lighting f
provided.
l-I Based upon the above, there is no unreviewed safety question.
Approved: 12/16/88 Ir l
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j Page 39 of 227 Unreviewed Safety Question Evaluation #88 150 l-h
Subject:
Environmental Qualification
Description:
This change addresses:
L- 1) A change in the current methodology employed for environmental qualification of equipment located in a mild environment, j 2) Performance of ques 11fied life extensions on equipment located i in a harsh environment.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analyais report?
For enysronmental qualification of equipment located in a mild environment:
The consequences of an accident or the probability of malfunction of equipment do not increase because of replacements due to
! observance of failures, degradation and routine maintenance. On the contrary, plant safety and reliability can be improved.
For performing qualified life extension on equipment:
Chapter 15 (Accident Analysis) of the TSAR has resulted in various l temperature / pressure profiles and radiation doses that are documented in Design Criteria NQ100Q. The values and profiles identified in this Design Criteria are used to qualify tha subject equipment which is required to mitigate accidents such as thCA, HELB, and MSLB described in Chapter 15.
Since the subject equipment is required to mitigate the consequences of an accident, it must be shown that the ability of 1, the equipment to function throughout its extended qualified life is not diminished, Approaches for life extension involve reviewing numerous plant design documentation (P&ID's, Design Criteria, Logic diagrams),
Technical Specifications, Operating Procedures, Maintenance Procedures and Vendor Documentation.
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Unreviewed Safety Question Evaluation *88 150 (Cont'd)
The existing qualified lives were derived not necessarily utilizing i any of these approaches and parameters. Hence, by applying one or a combination of these approaches, a more realistic qualified life is obtained. This new qualified life does not increase the consequences of an accident or the probability of malfunction of equipment.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
For environmental qualification of equipment located in a mild environment:
Failure mechanisms are unchanged and hence no new accidents are introduced, no new malfunctions are identified, and the equipment ability to mitigate accidents is preserved. Note that as discussed earlier, common cause failures due to environmental conditions are absent and hence failures are expected to occur randomly. The redundancy of safety.related systems prevents random failures from adversely affecting the execution of safety functions.
For performing qualified life extensions on equipment:
Failure mechanisms of any type are not affected or changed by extending the qualified life of equipment. In establishing a new qualified life, the failure mechanisms are unchanged and hence no new accidents are introduced, no new malfunctions are identified, and the equipment ability to mitigate accidents is preserved.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
For environmental qualification of equipment located in a mild environment:
l The purpose of the equipment and its ability to function does not change. Replacements due to random failures, degradation and routine maintenance do not degrade operability and functionality.
, Therefore, the margin of safety as established in a T.S. basis which relies on qualified equipment also remains unchanged.
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Attachment ST.HL AE.3260 !
Page 41 of 227 f Unreviewed Safety Question Evaluation w88-150 (Cont'd) l' For performing qualified life extensions on equipment:
, By establishing a new qualified life for equipment important to l safety the purpose of the equipment and its ability to function l remain unchanged. Therefore, the margin of safety established in a
) 7. S. basis which relies on qualified equipment also remains
- unchanged, k
Based upon the above, there is no unreviewed safety question.
Approved: 5/9/89 i
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, Page 42 of 227 i
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i Unreviewed Safety Question Evaluation w88 151 l
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Subject:
Access to Fuel Transfer Tube Area During Fuel Transfer i I
Description:
This change to the FSAR will place administrative control of the l lockable barriers in rooms ntB.011 and FilB-304 in the hands of the !
Shift Supervisor or llealth Physics Supervisor pursuant to l Technical Specification 6.12.2. j Safety Evaluation:
1
- 1) Does the subject of this evaluation increase the probability of occucrence or the consequences of an accident or malfunction of
/' equipaint important to safety previously evaluated in the safety )
analysis report? '
The change is purely administrative and does not increase the j likelihood of an overexposure incident. No previously evaluated ;
accidents or malfunctions are affecteo. i
- 2) Does the subject of this evaluation create the possibility for an f accident or malfunction of a different type than any evaluated j previously in the safety analysis report? 2 This administrative change does not create the need for a new I evaluation as no new accidents or malfunctions are made possible by ]
the change.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
1 The change brings operation of the plant more precisely under the i established Technical Specifications. The margin of safety is not ?
reduced.
I Based upon the above, there is no unreviewed safety question.
Approved: 2/2/89 -
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t' Attachment ST-HL.AE-3260 Page 43 of 227 Unreviewed Safety Question Evaluation *88 152 l
Subject:
AMI Thimble Magnetic Ball Valves
Description:
A magnetic ball valve is to be added for each of the 58 thimbles of ,
the Bottoa Mounted Instrumentation (BMI). A magnetic ball valve is ;
used for isolation, rather than a plug. ,
Safety Evaluation
- 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety analysis report? ,
As described in FSAR Section 7.7.1.9.2, a plugging operaticn would take place if a thimble needs to be isolated due to excessive wall thinning or eventual leakage from wall thinn!.ng. The new valve does not increase the probability of occurrence for a thimbie leak, nor does it increase the consequences of an accident for a thimble leak. 7 When a seismic event is considered, the valvo addition doe.s not increase the probability of a seismic event accident, nor does it l increase the consequences of a seismic event since the valvas are !
seismically mounted using II/I criteria.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
l A malfunction of the flux detectors has been considered in which a detector could not be inserted through a thimble. (This is covered by i TS 3/4.3.3.3.2.) The thimbles will have a detector insertion check i done as part of the acceptance test following installation of the valves. This check will ensure that all thimble paths are adequate for detector insertion. The consequences of a malfunction are covered '
by TS Action Statement 3/4.3.0.4. The action statements for '
r operability will not change due to the valve addition. Note also that l inability to retract an inserted detector due to failure of a magnetic l
ball valve does not create a new a cident or malfuention. Malfunction :
in which a detector is stuck beyond the seal plate toward the core is >
the same as that which could happen with the present design. !
Therefore, this change does not create the possibility for a different
- type of accident or malfunction nor will the consequences of an accident be increased. ,
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Attachment-ST HL AE-3260 ,
Page 44 of 227 i
Unreviewed Safety Question Evaluation #88 152 (Con't)
t
- 3) Does the subject of this evaluation reduce the margin of safety.as defined in the basis for any technical specification? ;
BMI TS 3/4.3.0.4 and 3/4.3.3.3.2 address flux mapping function of the ,
BMI System. The bases of the Technical Specification vill not change.
Personnel safety considerations (ALARA) will be reduced since the plugging operation will not be required. In addition, the magnetic ;
4~ ball valve vill prevent leakage of reactor coolant into the incore :
instrumentation room following a thimble leak, thus reducing the personnel radiation exposure and cleanup operations. Furthermoro, the valve addition does not reduce the margin of safety as defined in the ,
bases for any technical specification. ;
Based upon the above, there is no unreviewed safety question.
Approved: 12/28/88 i
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Att= hment ST.HL AE 3260 i Page 45 of 227 c
, Unreviewed Safety Question Evaluation sB8 154 l t
Subject:
Replacement of Damaged Lube Oil Heater [
Description:
Standby DG s21 19KW heater on the lube oil bep warm system was damaged. A 12KW lube oil hoater that was previously used in this application will be installed until a 19KW replacement can be <
obtained.
Safety Evaluation: ;
- 1) Does the subject of t.his evaluation inercase the probability of occurrence or the consequences of an accf dent or malfunction of ,
equipment important to safety previously evaluated in the safety !
analysis report?
The function of the heater is to keep engine lube oil warm when in standby ir order to facilitate quick starts. Once lube oil temperature reaches steady a state (120'F 130'F), the heater cycles to maintain the temperature. The 12KW heater was previously used in this I application. The 19KW heater is needed under conditions of high air flow and/or low engine room temperature. This does not apply at ;
STPEGS. Therefore, use of the 12KW heater in lieu of a 19KW heater !
does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously ,
evaluated in the safety analysis report. l
- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated previously in the safety analysis report?
t The 12KW heater is adequate for the purpose of maintaining the engine !
in standby and will not affect its ability to fulfill its safety- l related function. Therefore, use of the 12KW heater does not create :
the possibility for an accident or malfunction of a different type i than any evaluated previously in the safety analysis report. .
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? i I
The 12KW heater will maintain standby lute oil temperature within the t 120'F 130'F range described in the safety analysis report to !
facilitate quick starts. Therefore use of the 12KW heater does not :
I reduce the margin of safety for any technical specification. ,
Based upon the above, there is no unreviewed safety quer, tion. ,
Approved: 12/2/88 A1/Pl.NL7
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- Attachment
! ST HL AE 3260 f' Page 46 of 227 Unreviewed Safety Question Evaluation w88 155
Subject:
Pressurizer Surge Line Stratification
Description:
Thermal loads on pressuri.er surge line hangers exceed the design loads due to thermal stratification, l
f Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of
! equipment important to safety previously evaluated in the safety analysis report?
The original analysis assumed uniform temperature in the pressurizer surge line. Reanalysis assuming stratification resulted in the discovery that two hangers are experiencing higher .ds than had been originally predicted. However, the integrity of the surge line :1 ping system has been established in its current support configur W.sn under stratified conditions, Westinghouse has provided confirmation and believes that the current configuration of the surge line is acceptable for Unit 1 to continue power operation until the next scheduled refueling outage.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since no physical change to the system is proposed and no failure of supports or loss of system functionality or operability is expected, the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report will not i
be created. .
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Tech Spec 3/4.4.1 , " Reactor Coolant Loops and Coolant Circulation,"
i will not be affected since no loss of system functionality or i operability is expected, and therefore, no margin of safety is
' reduced. Also, Westinghouse is able to confira validity of fatigue crack growth, as well as Leak Before Break criteria, to the original design. Thus, any potential leakage through the pipe will be well within prev!ously identified leak rate parameters. Note that no pressure boundary leakage is expected. Thus, there is no reduction in margin for leakage. The structural integrity of ASME Code Class 1
. components is maintained by visual inspection as well as monitoring of l the system. No damage to the supports has been noted.
l Based upon the above, there is no unreviewed safety question.
Approved: 12/12/88 A1/Pl.NL7
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!. ST HL.AE-3260 ;
l Page 47 of 227 ;
Unreviewed Safety Question Evaluation W88 156 l l'
Subj ect: Electrical Penetration Assemblies Citcuit Breaker Protection
Description:
This evaluation addresses FSAR Change Notices to:
a) correctly identify breakers used (thermalimagnetiev vs
[ magnetic only), and ;
i b) correctly identify the location of the primary breakers for ,
DRPI Data Cabinets A and B. ;
Safety Evaluation: .
- 1) Does the subject of this evaluation increase the probability of . .
occurrence or the consequences of an accident or malfunction of .
equipment important to safety previously evaluated in the safety ,
analysis report? +
Both thermal magnetic and magnetic only breakers are acceptable for use as a primary breaker. To reflect the as built condition of STPECS in Table 8.3 14, the listed type of device notation for some primary ;
breakers needs to be changed from a magnetic only to a thermal. .:*
magnetic device. Table 8.3 14 also identifies the location of each device listed. To reflect the as built condition of the plant, the .
listed locations of some primary devices need to *oe changed from one l qualified distribution source to another qualified distribution i source. Neither case represents a condition which has not been l' evaluated, and plant operability is not affected. Therefore, there is no increase in the probability of occurrence or the consequences of an l accident or malfunction of equipment important to safety. ,
l 2) Does the subject of this evaluation create the possibility for an
! accident or malfunction of a different type than any evaluated .
l previously in the safety analysis report?
Use of either a magnetic only or thermal magnetic breaker as an EPA i primary protective device has already been evaluated. ;
, 3) Does the subject of this evaluation reduce the margin of sefety as .
l- defined in the basis for any technical specification? ,
The technical specifications do not specify safety margins associated with EPA primary protection devices. This change does not reduce the margin of safety as defined in the basis for any technical specification.
Bated upon the above, there is no unreviewed safety question.
l l Approved: 12/16/88 l
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7 ii-Attachment ST HL AE 3260 t Page 48 of 227 Unreviewed Safety Question Evaluation #88 157 Subj ect: Pressurizer Surge Line Description. A pipe support is to be removed from the pressurizer surge line to provide adequate clearances to allow for additional thermal expansion due to thermal stratification. This change'is in ,
response to NRC IE Bulletin 88 11.
I Safety Evaluation:
- 1) Doss the subject of this evaluation increase the probability of ,
occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ;
analysis report? ,
The proposed change does not alter the functionability or operability of the pressurizer surge line. No breaking of the pressure boundary or changes to the physical layout of the pressurizer surge line is required. The clearance criteria as originally specified is being .
mainteined. The proposed change does not increase the probability of occurrence or the consequences of an accident or malfunction of ,
equipment important to safety previously evaluated in the SAR.
- 2) Does the subject of this evaluation craate the possibility for- an i accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since there are no physical changes to routine or pressure break boundary of the pressurizer surge line, this change will not create the possibility for an accident or malfunction of a different type than any evaluated previously in the SAR.
- 3) Does the subject of this evaluation reduce the margin of safety as -
defined in the basis for any technical specification?
There are no changes to previously approved operating procedures. The additional fatigue cycles expected due to thermal stratification are conservatively addressed, and the pressurizer surge line is requalified for 40 years of plant life, ASME Section III code stresses, fatigue crack growth, and leak-before-break analysis.
Therefore, the margin of safety as defined in the basis for any technical specification is not reduced. ,
Based upon the above, there is no unreviewed safety question.
Approved: 12/22/88 o
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Page C of 227 !
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Unreviewed Safety Question Evaluation #88 159
Subject:
_ Temporary Modification to Radiation Monitor
Description:
This temporary modification will disable the High Radiation and Operate Failure Trip of TCB Sump #1 sump pumps. '
Safety Evaluation: ;
l
- 1) Does the subject of this evaluation increase the . probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety
- - analysis report?
i The monitor and sump pumps are not safety-related. The modification will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment because this temporary modification must be removed and the design change implemented before initial criticality. l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? l l
This temporary modification is to be removed before any radioactivity 1 is' produced.- Therefore, the modification will not create the possibility for an accicent or malfunction, i 1
- 3) Does the subject of this evaluation reduce the margin of safety as ,
defined in the basis for any technical specification? l Technical Specifications do not apply to the monitor. Therefore, this temporary change does not reduce the margin of safety, 1
! 1 1
1 Based upon the above, there is no unreviewed safety question.
Approved: 12/14/88 l I
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y Attachment ST-HL-AE-3260 Page SC of.227 Unreviewed Safety Question Evaluation #88-161
Subject:
Repair of Leaking Valves
Description:
This evaluation provides justification for use of Team Inc procese for temporary repair of leaking ASME Code valves.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
i The subject of this evaluation does not increase the probability of l occurrence or the consequences of an accident or malfunction of equipment important to safety. Safety review and calculations support L the conclusion that the modification does not reduce valve l capabilities below ASME Code requirements. Actual wall thickness
'. exceeds that required to compensate for the holes drilled. Additional l forces applied to the bonnet do not approach the capability of the l- valve.
l 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
l L The subject of this evaluation does not create the possibility for an I accident or malfunction of a different type because the modification does not reduce valve capabilities below ASME Code mandated minimums.
L 3) Does the subject of this evaluation reduce th'e margin of safety as defined in the basis for any technical specification?
I The subject of this evaluation does not reduce the margin of safety as l l defined in the basis for any technical specification because the i l- safety evaluation and calculation supporrs the conclusion that the valve capabilities after modification still exceed AEME Code mandated minimums.
1.
l Based upon the above, there is no unreviewed safety question.
~
Approved: 12/30/88 j l:
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i Attachment i ST-HL-AE 3260- !
Page 51 of 227 Unreviewed Safety Question Evaluation #88-162
Subject:
Replacement Piezometer
Description:
A piezometer installed to measure the ground water level in the i "C" stratigraphic layer between the ECP and the power block is to be replaced.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability or occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The affected piezometer does not come in contact with or affect any of the STPEGS systems. It can have no adverse effect on operation of the. .
plant. The replacement will be installed in accordance with the same specifications used.to install the original. All materials, equipment, and labor will be supplied in accordance with the specification. The proposed neu uiezometer, although in a new location, will have the same impact on the plant as the decommissioned piezometer. Given an accident introducing contaminants into the ground water, the new piezometer will be able to characterize the phreatic conditions in the general area of the decommissioned piezometer. Therefore, this change does not increase the probability '
of occurrence or the consequences of an accident or malfunction of '
equipment important to safety previously evaluated in the safety
~
analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
As described in (1), this change does not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
As described in (1), this change does not reduce the margin of safety as defined in the basis for any Technical Specification.
Based upon the above, there is no unreviewed safety question.
Approved: 1/20/89 l
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Attachment ST.HL AE-3260 Page 52 of 227 Unreviewed Safety Question Evaluation #88 163
Subject:
High Density Spent Fuel Racks
Description:
This change revises the location of the BPRA handling tool from the spent fuel pool to the fuel transfer canal. A funnel handling tool is to be installed at the previous location of the BPRA handling tool.
Safety Evaluation:
- 1) Does the subject of this -evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equip.nent important to safety previously evaluated in the safety analysis report?
Calculations show that the BPRA handling tool is adequately supported for all design loads. The BPRA haadling tool is located in a non II/I area. In the event the funnel handling tool becomes dislodged from its supports, the impact force to the fuel racks and fuel will not be en> ugh to damage them. This is based on the load drop analysis which assumes the drop of a consolidated fuel canister on the racks which envelopes the drop of the funnel handling tool.. Therefore, this change does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an 3 accident or malfunction of a different type than any evaluated 4 previously in the safety analysis report?
Based upon the response to (1), the change does not create the possibility for an accident or malfunction of a different type than I any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as l defined in the basis for any technical specification?
i The load drop analysis shows that Keff will be maintained less than l-0.95 in accordance with Technical Specification 5.6 in the event of a i drop of the funnel handling tool since the funnel handling tool is enveloped by the fuel canister. ,
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Based upon the above, there is no unreviewed safety question.
Approved: 12/26/89 l
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Attachment ST HL AE 3260 Page 53 of 227 '
Unreviewed Safety Question Evaluation #88 164
Subject:
Relocatien of RCB Shell Accelerometer
Description:
The subject RCB shall accelerometer is to be removed from its l current location oa the outside face of containment azimuth 295' 'i and relocated to the outside face of containment azimuth 322'.
The new location is more accessible.
Safety Evaluation: *
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of am accident or malfunction of equipment important to safety previausly evaluated in the safety analysis report?
There is no increase in the probability of occurrence on the consequences of an accident since this device is passive, and the mounting is seismically designed to function during OBE and SSE and to ,
resolve seismic II/I concerns. l There is no increase in the probability of or consequences of a ,
malfunction since this device is passive, it is nonnuclear safety-related, it performs no safety-related functions, and its mounting is ,
analyzed for support during an OBE and SSE.
1
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The support for the relocated accelerometer is the same as was used in
- the previous location. Therefore, it will not create the possibility for an accident or malfunction of a different type than any evaluated previously.
- j. 3) Does the subject of this evaluation reduce the margin of safety as L defined in the basis for any technical specification?
l Per the bases of Technical Specification 3/4.3.3.3, operability of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety.
Operability will be maintained following relocation. Thus, the margin of safety as defined in the bases of the Technical Specifications is not affected.
Based upon the above, there is no unreviewed safety question.
Approved: 1/20/89 A1/Pl.NL7 1
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, o Attccha:nt ST HL AE 3260 Page 54 of 227
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Unreviewed Safety Question Evaluation #89 004 Subj ect: Inspection Port Covers
Description:
The subject inspection port covers are to be modified to prevent water leakage.
I Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of t
occurrence or the consequences of an accident or malfunction of
- equipment important to safety previously evaluated in the safety '
analysis report?
The purpose of the Reactor Containment Cavity ISI Inspection Port Hatches is to provide for both inspector or equipment access to the Reactor Coolant Hot and Cold Leg Piping for the required Inservice Inspection in accordance with the project commitment to ASME Section XI. The criteria for establishing accessibility are provided in Engineering Design Criteria Document SLC10RZ1007 "ISI Access Design Criteria", Rev. 1. 3 The current configuration for the ISI Port Hatch utilizes a gasket ring between the hatch and the surface of the Reactor Cavity Pool Liner, which is compressed through a bolted connection -
, . circumferential1y around the top of the hatch. In filling the Reactor Cavity Pool during the Rapid Refueling Test on Unit 2, an unacceptable amount of leakage was observed through the gasketed Port Hatch. This design change removes the gasket material and utilizes a circumferential weld to attach the Port Hatch (i.e.,
plate) to the Reactor Cavity Pool Liner. This design change will be performed for each Port Hatch in Unit 2. This design change will ensure that leakage will not occur.
Additionally, the design change will not prevent the performance of the required ASME Section XI Inservice Inspections. Alternate access has been identified by the HL&P Inservice Inspection Engineer through the primary Shield Wall openings for the Reactor Coolant Piping. Additionally, this access has been increased through the elimination of the associated Reactor Coolant System pipe whip ,
restraints through the application of the NRC approved " Leak Before i Break Methodology".
Further, the consequences of leakage through the weld have been considered in that the Reactor Cavity Pool is intended to be filled i only during refueling and would result in localized leakage of l contaminated water which would travel / migrate to the Reactor Containment basemat and ultimately to the Containment sumps.
L Al/P2.NL7 t
i Attachment i ST HL AE 3260 Page 55 of 227 Unreviewed Safety Question Evaluation #89 004 (Cont'd)
In summation, the'ISI Inspection Port Hatches serve no safety ,
function and are not required to mitigate the consequences of an accident. As a result, issuance of this design change does not' ;
increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the 7ossibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Based upon the information in (1), the design change does not creare the possibility for an accident or malfunction of a different type than evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as .
defined in the basis for any technical specification? ;
Based upon the information in (1), this design change does not reduce the margin of scfety as defined in the basis of the Technical Specifications (i.e., Sections 3/4.4.10 and 3/4.11.1.2) as the ,
technical criteria are being maintained.
Based upon the above, there is no unreviewed safety question. I 1
Approved: 1/17/89 t
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k Attachment r ST HL AE 3260 !
Page 56 of 227 l Unreviewed Safety Question Evaluation #89-009
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Subj ec t :- Energy Management and Control System (EMACS)
Description:
The proposed change involves addition of new nonsafety-related .
cable (that are being routed for the EMACS) in existing cable trays. Since these new cables have no safety function and do -
not perform any control function, the only effect of the cable routing would be the potential for an increased combustible loading and the corresponding increase in the potential for a fire. ,
i Safety Evaluation:
- 1) Does the subject of this evaluation increate the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
- The increase in the combustible loading for the affected fire areas <
is still bounded by the analysis provided in FRAR for Fire Areas described in Table 1, attached. Since the FHAR combustible loading still remains bounding, the consequence'of a postulated fire in the l affected fire areas / zones still remains bounding. Therefore, this e change does not increase the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety previously evaluated in the SAR.
l' l 2) Does the subject of this evaluation creare the possibility for an L
accident or malfunction of a different type than any evaluated i previously in the safety analysis report?
The changes identified are consistent with the evaluations in the '
FSAR and would not create the possibility for an accident or malfunction of a different type than that already evaluated in the f FSAR. ,
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The margin of safety is consistent with those identiff ad in the FSAR and technical specifications. Addition of cables under this t modification does not reduce the margin of safety as defined in the basis for any technical specification. The combustible loading of the new EHACS cables is bounded by the values presently in the FRAR '
for the affected fire areas / zones.
Based upon the above, there is no unreviewed safety question.
Approved: 1/26/39 Unreviewed Safety Question Evaluation #89-010 J A1/P2.NL7
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Att: chm:nt ST-HL AE-3260 !
Page 57 of 227 l
Subject:
. Inspection Port Covers
Description:
The subject inspection port covers are to be modified by welding them down in lieu of bolting to prevent leakage.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the' safety l analysis report?
The purpose of the Reactor Containment Cavity ISI Inspection Port i
Hatches is to provide for both inspector or equipment access to the -
Reactor Coolant Hot and Cold Leg Piping for the required Inservice Inspection in accordance with the project commitment to ASME Section XI. The criteria for establishing acceseibility is provided in ,
Engineering Design Criteria Document SLO 10RQ1007 "ISI~ Access Design Criteria", Rev 1.
The current configuration for the ISI Port Hatch utilizes a gasket ,
ring between the hatch and the surface of the Reactor Cavity Pool' '
Liner, which is compressed through a bolted connection circumferential1y around the top of the hatch. In filling the Reactor Pool during the Rapid Refueling Test on Unit 2, an unacceptable amount of leakage was observed through the gasketed 1 Port Hatch. This same leakage is expected in Unit 1. This design change removes the gasket material and utilized a circumferential weld to attach the Port Hatch (i.e., plate) to the Rector Cavity -
Pool Liner. This design change will be performed for each Port Hatch in Unit 1. This design change will ensure that leakage will l' not occur.
Additionally the design change will not prevent the performance of the required ASME Section XI Inservice Inspections. Alternate ,
access has been identified by the HL&P Inservice Inspe.ction Engineer through the Primary Shield Wall openings for the Reactor Coolant Piping. Additionally, this access has been increased through the elimination of the associated Reactor Coolant System pipe whip restraints through the application of the NRC approved " Leak Before Break Methodology". ,
Further, the consequences of leakage through the weld have been '
considered in that the Reactor Cavity Pool is intended to be filled only during refueling and would result in localized leakage of contaminated water which would travel / migrate to the Reactor Containment basemat and ultimately to the Containment sumps.
A1/P2.NL7
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[ Attachment ,
ST HL AE 3260 Page 58 of 227 Unreviewed Safety Question Evaluation #89 010 (Cont'd)
In summation, the ISI Inspection Port Hatches serve no safety function and are not required to mitigate the consequences of an accident. As a result, issuance of this design change does not increase the probability of occurrence or consequencas of an i eccident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an-accident or malfunction of a different type than any evaluated previously in the safety analysis report? ;
Based upon the information in (1), the design change does not create the possibility for an accident or malfunction of a different type I than evaluated'previously in the safety analysis report. l J
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Based on the information in (1), this design change does not reduce the margin of safety as defined in the basis of the technical specifications (i.e.. Sections 3/4.4.10 and 3/4.11.1.2) as the technical criteria are being maintained.
1 i: 1 Based upon the above, there is no unreviewed safety question.
1 Approved: 1/25/89 t
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[. , Att:chment ST.HL-AE.3260 Page 59 of 227 i
Unreviewed Safety Question Evaluation #89-011 Subj ect; RCS Flow Anomaly
Description:
This evaluation addresses the changes to the licensing basis required to support operations at the Tech.iical Specification i RCS flow limit of 395,000 gpm with the RCS flow anomaly. This subject was previously addressed in LER 88-052. This proposed change was submitted to.the NRC by correspondence dated April 18,1989 (ST.HL- AE 3040) . NRC acceptance was provided by correspondence dated September 7, 1989. ,
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Attachment k ST HL AE 3260 Page 60 of 227 Unreviewed Safety Question Evaluation #89 014
Subject:
Fuel Oil Storage Tank Room Exhaust Fans
Description:
The fan motor HP and RPM have been changed from 1.0/1800 to 1.5/1160. During startup testing, it was noted the 1.0/1800 motors overheated and drew heavy no load current.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
No change is made to the basic function of the exhaust fan capacity.
Since there is no change in basic function, and motor operability is enhanced by increased efficiency, the change does not increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since there is no change to the basic function of the exhaust fans ;
I in ventilating the Fuel Oil Storage Tank Rooms, the change does not ,
create the possibility for an accident or malfunction of a different type than any evaluated previously. ;
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- 3) Doen the subject of this ovaluation reduce the margin of safety as j defined in the basis for any technical specification? j j
The Fuel Oil Storage Tank Room Exhaust Fans are Quality Class 8, i L NNS. Tech Spec 3/4.8.1 requires no surveillances of these fans. ;
1 The fans are not mentioned in the bases for the Tech Specs l concerning operability of the Standby Diesel Generators. Since l there is no chan6e to the basic function of the exhaust fans, there is no reduction in the margin of safety. i l
Based upon the above, there is no unreviewed safety question. I Approved: 3/14/89 l
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Page 61 of 227 i i
Unreviewed Safety Question Evaluation #89 015 l
Subject:
Rewire Existing (Spared) Pressure Switches
Description:
Existing spare switches N2UI PSL6313B,C will be retagged as ,
N2EH-PSL 6313B, C and used for 1350 psig setpoints. This change revises FSAR Figure 10.2 8 (sheet 2 of 2) to retag and i
utilize existing installed spare instruments only, Safety Evaluation l
- 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Pressure switches N2EH-PSL-6313A, B, C are being rewired to be used for turbine trip interface. These switches are nonsafety, Class III ,
type instruments. No safety-related circuits are involved, and !
safety evaluations previously performed in the safety analysis report are not affected by this change.
NOTE: A different set of switches which are safety grade and Class I type instruments are used for reactor trip logic. <
These safety grade switches are not affected by this change. 1 l
- 2) Does the subject of this evaluation create'the possibility for an l
accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
l' There is no possibility for an accident or malfunction of a '
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- different type because
- 1). turbine trip interface is confined to nonsafety areas, and 2) there is no change in the basic design. The ,
l- plant modification is to make the hardware comply with design !
requirements.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
l Safety limits and limiting safety system settings as discussed in Section 2 of the Technical Specifications are not affected by this j change. The change is to make the hardware match the design l requirements. No change to the margin of safety will occur.
l Based upon the above, there is no unreviewed safety question.
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Approved: 2/8/89 l A1/P2.NL7
Attachment ST.HL.AE 3260 Page 62 of 227 Unreviewed Safety Question Evaluation #89 016 ,
Subject:
Bypass of Letdown Filters During Normal Operation f
Description:
High activity and loading of the Letdown Filters has led to !
axcessive changeouts. The Letdown Filters should be bypassed using existing valves during normal operation to i preclude this. (The mixed bed demineralizer would perform the filtering.)
Safety Evaluation: ,
- 1) Does the subject of this evaluation increase the probability of !
occurrence or the consequences of an accident or malfunction of equipment important to safety previously cvaluated in the safety ,
analysis report?
The accident of concern would be radioactive releases due to postulated failure of liquid containing tanks or vessels as analyzed in Chapter 15 of the FSAR. For the cases analyzed in Chapter 15, the doses are based on the failure of the evaporator concentrates tank (ECT) and the recycle holdup tank (RHT) which contain the most activity subject to release (see Calibrations NC 6030 and CC 7459).
For the Letdown Filters, the proposed change would result in less activity to be released during normal operation since the filters would be bypassed. ,
For the Mixed Bed Domineralizers, the proposed change would result l in more particulate activity contained within the demineralizer vessel. However, even with this addition loading onto the Mixed Bed demineralizer, the activitiee associated with the ECT and RHT are !
j' sti11' greater than for the Mixed Bed Demineralizer for the Chapter l i
15 dose calculations. Thus,.the consequences of an accident previously evaluated would not be increased.
l The probability of occurrence of ruptured filter does not depend on L the valve configuration. Presently, one filter is online and the other is valued out. the probability of a ruptured mixed bed demineralizer vessel does not depend on the Lotdown Filter valve ,
configuration. Thus, this change does not increase the probability of occurrence of the accident.
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Attachment ST HL AE 3260 Page 63 of 227 Unreviewed Safety Question Evaluation w89 016 (Cont'd)
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change involves no physical changes to the piping layout or to equipment locations. Thus, there are no possible accidents involved which might be caused by a hardware installation. The possible accidents concerning ruptured filter or demineralizer vessels are bounded by the accidents addressed in FSAR Chapter 15. Therefore, no new type of accidents is created by this change.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The applicable-technical specification is that for Specific Activity of the Reactor Coolant (TS 3.4.4.8). The Letdown Filters and Mixed Bed Demineralizers are not described in the technical specification in the basis. The technical specification does not describe the
. process equipment that is needed to maintain the specific activity limits given. Thus this change does not affect the margin of safety as defined in the basis for the technical specification.
The other applicable technical specification is TS 3/4.1.2 for Boration Syst.n.s. The proposed change does not affect the letdown function reqv.iad when borating since the bypass line will be used for the letdown flow rather than flowing through the filters. There ,
is no effect on the margin of safety as defined in the basis for this technical specification, i 1
l Based upon the above, there is no unreviewed safety question.
Approved: 3/9/89 l
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Attachment ST-HL AE 3260 Page 64 of 227 Unreviewed Safety Question Evaluation #89-017
Subject:
Change in Liquid Waste Evaporator Performance Test Schedule
Description:
Correspondence dated December 3, 1988 (ST HL AE 2870), made the-commitment to perform the Liquid Waste Evaporator Performance Test prior to Mede. 2 of Unit 2. Completion of portions of this test are to be deferred until prior to Unit 2 Commercial Operations.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety i analysis report?
l' This change in scheduling of the Liquid Waste Evaporator Performance l Test will not degrade the affected equipment. The remainder of the Liquid Waste Processing System has been tested and will adequately process liquid waste to meet the requirements specified by 10CFR20, as stated in STPEGS FSAR Chapter 11.
1 l The proposed delay will not increase the probability of rupture of i the Recycle Holdup Tank (FSAR Chapter 15) nor does it change the 1 consequences of such an accident. If such a rupture should occur, the liquid would still be transferred by the same method, and processed through demineralizers.
l The proposed delay will eliminate the possibility of the Concentrates Storage Tank rupture accident for the period of the l delay. The Concentrates Storage Tank is used only to collect !
P concentrates produced by the evaporator. Since the evaporator will l not be in service during the period of the delay, this accident can ;
not occur, i
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l 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated ,
i previously in the safety analysis report? !
Unavailability of the Liquid Waste Evaporator prior to commercial !
1 operations will not impact the handling of liquid waste streams.
l 1he remainder of the Liquid Waste Processing System is capable of processing all liquid waste streams during the period of delay in testing the evaporator, as stated in STPEGS FSAR Chapter 11, Unavailability of the evaporator means that the affected equipment will not be operated, nor will it contain radioactive liquid waste.
Thus, the chances of an equipment malfunction during the delay will decrease, as will the chances of a rupture or a leak from any affected component in this part of the system.
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Attachment ST HL AE *s260 Page 65 of 227 Unreviewed Safety Question Evaluation e89 017 (Cont'd)
- 3) Does the subject of.this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The delay of the evaporator test will be for the period up to commercial operations of Unit 2. The remainder of the Liquid Waste Processing System will adequately fulfill the requirements of the technical specifications during ths period when the c.vaporate is not available.
Based upon the above, there is no unreviewed safety question.
Approved:-
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ST HL.AE-3260 Page 66 of 227 ,
Unreviewed Safety Question Evaluation #89 019
Subject:
Core Exit Thermocouple Connector Replacement
Description:
Conax connectors are to be used in addition to Lemo B connectors.
- Safety Evaluation: ;
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The Conax connectors are also qualified to the post accident environment. Use of Conax connectors instead of Lemo B connectors will not increase the probability of occurrence or the consequences of an ' accident or malfunction of equipment important to safety -
previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The Conax connectors are also qualified to the pont-accident environment. Use of Conax connectors instead of Lemo-B connectors does not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
,' The Conax connectors are also qualified to the post-accident l~ environment. Use of Conax connectors instead of Lemo-B connectors I does not reduce the margin of safety as defined in the basis for any '
technical specification.
Based upon the above, there is no unreviewed safety question.
1 Approved: 2/14/89 I
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ST HL AE 3260 ~
Page 67 of 227 Unreviewed Safety Question Evaluation w89 020 !
Subj ect: Nameplate Revisions at Transfer Switch Panels and Auxiliary Shutdown Panels
Description:
Nameplate engravings at the transfer switch panels and '
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auxiliary shutdown panel are being revised to provide consistent nameplate information and procedure references r to switches.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety i analysis report?
The nameplate revisions are being performed to ensure that the !
procedures and nameplates are in agreement as to nomenclature. This change does not increase the probability of occurrence or the ,
consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated 1 previously in the safety analysis report?
Nameplate engravings which are consistent with the plant procedures ;
and appropriate for the equipment being controlled will not create the possibility for an accident or malfunction of a different type ;
than previously evaluated.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
I' The margin of safety as defined in bases for technical specifications is not reduced by having procedures and labels in agreement.
Based upon the above, there is no unreviewed safety question. 1 Approved: 2/17/89
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l Attachment i ST.HL-AE 3260 Page 68 of 227 Ilnreviewed Safety Question Evaluation #89 021
Subject:
Acoustical Monitor Serpoints
Description:
These PORV safety valve acoustical monitor setpoints are to !
be revised to prevent false indication due to noise from 1 adjacent valves.
Safety Evaluation:
1
- 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety ;
analysis report? '
i These instruments perform no safety function. They. provide display l and status change information to the ERF computer. Operation of j these instruments is not required per any safety analysis discussed '
in the SAR. Therefore, this change does not increase the probability or consequences of an accident or malfunction of equipment evaluated in the SAR. 1 1 2) Does the subject of this evaluation create the possibility for an I accident or malfunction of a different- type than any evaluated i previously in the safety analysis report? i Inadvertent opening of a pressurizer safety valve (or relief) has i already been analyzed in FSAR Section 15.6.1. The results and 1 consequences of this analysis are unchanged as a result of this 1 change, j
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? ;
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These instruments are not in the technical specifications and do not affect any item discussed in any section. Note that Tech j Spec 3/4.4.2 is not affected as a result of this change since these monitors do not affect operability of the pressurizer safety valves. I Based upon the above, there is no unreviewed safety question. I I
Approved: 3/1/89 j L
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! Page 69 of 227 Unreviewed Safety Question Evaluation w89 022
Subject:
Loose Parts Monitoring System l l
Description:
This FSAR revision clarifies the term " inoperable".
Safety Evaluation: ]
- 1) Does the subject of this evaluation increase the probability of _j occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
This change adds clarification to the term " inoperable" to make the FSAR and the governing Regulatory Guide 1.133 consistent. This clarification does not change the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety. The present FSAR commitment. to RG 1.133 requires redundant sensors in each location be operable. The proposed change allows i for one of the two sensors in a collection region to be inoperable, i Presence of a loose part can still be detected and evaluated. This ]
reduced number of sensors does not increase t.he probability of an 1 accident or malfunction of equipment. Two sensors in a collection i region are provided for redundancy only. They do not provide j sufficient information for exact loose parts location correlation. I Loss of one sensor is acceptable per the re5ulatory guide. This i
equipment is not safety related and total loss of all sensors is not L reportable to the NRC until after 30 days and then reactor shutdown i not required.
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- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated ;
previously in the safety analysis report?
l This equipment is not evaluated for its safety significance in the FSAR. This change is only a clarification. This instrumentation is for diagnostic purposes; this change does not create the possibility for an accident or malfunction of a different type than previously evaluated. This change only reduces the redundancy commitments in the FSAR. Changing the redundancy requirements does not create the possibility for an accident or malfunction of a different type than any previously evaluated.
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- ST HL AE.3260 l Page 70 of 227
} Unreviewed Safety Question Evaluation #89 022 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
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The Loose Parts Monitoring System is not listed in the STPEGS Technical Specifications, based upon the 'above, there is ne unreviewed safety question.
Approved: 4/10/89 l
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Attachment ST.HL AE 3260 Page 71 of 227 Unreviewed Safety Question Evaluation W89 023
Subject:
Pump Strainer Mesh Size
Description:
This change corrects an editorial inconsistency concerning pump strainer mesh size. The "40 mesh" modifier is incorrect with respect to the nominal rating of 840 microns. Vendor drawings confirm installed equipment contain 20 mesh (840 micron) strainer.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Since there is no physical change, this does not increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety,
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change is editorial only and no change to physical equipment is involved. Therefore, the change does not create the possibility of an accident or malfunction of a different type.
- 3) Does the subject of this evaluation reduce the margin of safety as i defined in the basis for any technical specification? I Tech Spec 3/4.11 mandates no surveillances for transfer pumps or their suction strainers. Neither do such equipment apply to any L bases for the technical specifications. Therefore, the change does I not reduce the margin of safety.
Based upon the above, there is no unreviewed safety question. l H
Approved: 3/14/89 i
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q Uh ' l Att:chment ST HL AE-3260 Page 72 of 227 I Unreviewed Safety Question Evaluation w89 024 i
Subj ect: Change in Solid Radwaste Concentrate Storage / Transfer, Chemical l Feed, and Dry Waste Compactor Performance Test Schedule ,
l
Description:
Correspondence dated December 3, 1988 (ST-HL AE 2870) made the commitment to perform the Solid Radwaste Concentrate i Storage / Transfer, Chemical Feed, and Dry Waste Compactor i Performance Test prior to entry into Mode 2 of Unit 2. I Completion of portions of this test are to be deferred until prior to Unit 2 Commercial Operations. ;
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ,
analysis report? j The Concentrates Storage Tank and Concentrates Transfer Pump provide the ability to store concentrated waste produced in the ifquid waste ;
1 evaporator, and to transfer this solid waste for shipment offsite.
Unit I has not used this part of the Solid Waste Processing System ,
to date, and its use is not anticipated in Unit 2 prior to j commercial operations. It will not be used prior to completion of j the test.
The Chemical Feed Tank, the Chemical Feed Pump, and the Chemical 1 Feed Tank Mixer have been tested satisfactorily and are available for use in Unit 2. The Dry Waste Compactor has also been tested i satisfactorily and is available for use in Unit 2.
There are no accidents evaluated in the STPECS FSAR which reference the Concentrates Storage Tank, Concentrates Transfer Pump, the Chemical Feed portion, the Chemical Feed portion, or the Dry Waste Compactor portion of the Solid Waste Processing System. No malfunctions of Solid Waste Proceseing System equipment are evaluated.
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Page 73 of 227 !
Unreviewed Safety Question #89 024 (Con't) l
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- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
i Unavailability of the Concentrates Storage Tank and Concentrates Transfer Pump will have no impact on processing of liquid waste i streams in Unit ?. since there are no plans to utilize this equipment i prior to commercial operations. No additional accidents or malfunctions will be possible because of this unavailability, and the possibility of malfunctions, ruptures, or leaks from this equipment are reduced for the period of the delay.
The Chemical Feed Tank, Chemical Feed Pump, and Chemical Feed Tank '
Mixer have been satisfactorily tested and are available for use in ,
Unit 2. Their use will allow pH adjustment of various radwaste tanks in Unit 2 and will not create the possibility of any new accidents or malfunctions not evaluated in the FSAR. .
The Dry Waste compactor has been satisfactorily tested and is available for use in Unit 2. Its use in Unit 2 is not anticipated prior to commercial operations. Availability of this compactor will not create the possibility of any malfunction or accident not evaluated in the FSAR.
- 3) Does the subject of this evaluation reduco the margin of safety as defined in the basis for any technical specification?
The Unit 2 Technical Specifications do not require this equipment to i be operable prior to commercial operations in Unit 2. The Technical l Specifications affecting the Solid Waste Processing System only pertain to solidification of waste prior to shipping.
Unavailability of any of this equipment will not affect the margin of safety as defined in the basis for any Technical Specification.
3 Based upon the above, there is no unreviewed safety question.
Approved: 2/23/89 L
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l Attachment ST HL AE 3260 Page 74 of 227 Unreviewed Safety Question Evaluation #89-025 j
Subject:
Temporary Modification to the Liquid Waste System ]
Description:
This temporary modification will allow pressurization of the RCS without installing a blind flange on the upstream side of 3" WL1017WG7 as currently required by Note 3 on P&ID 5R309F05022 #2 Rev. 9.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety l analysis report?
The Reactor Coolant Drain Tank Subsystem of the Liquid Waste ]
Processing System is shown on P&lD SR309F05022 #2. This subsystem receives various valve leakoffs from the reactor coolant system, accumulator drains, transfers from the pressurizer relief tank, ;
and reactor coolant system loop drains. ]
The four reactor coolant loop drain lines joint into a common t'uree-inch line connected to the reactor coolant drain tank subsystem. This three inch line contains a spoolpiece, which is l only installed when the reactor coolant system is depressurized.
Normally, blind flanges are installed in place of the spoolpiece when the plant is operating. This is required per Note 3 on P&ID '
I SR309F05022 #2. I The loop drain lines contain two isolation valves prior to the 1ccation where the spoolpiece is installed. The valves have a small amount of leakage and over time the line upstream of the y
( blind flange would become overpressurized (reactor coolant system j pressure on a 150# line). This condition was identified as a j l
nonconformance and Engineering is preparing a modification which ,
will prevent this overpressurization. This line ir non safety l class 7 piping. l
- l. This temporary modification allows the removal of the blind flange l from the upstream side of the 3"WL1017WG7 piping. This would l
j prevent overprossurization of this line and allow entry into L
Mode 3. There is still double valve protection upstream of the E open pipe. This temporary modification does not affect the l p supports for this piping, and thus will not change the seismic l criteria.
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Page 75 of 227 ;
Unreviewed Safety Question Evar.tation #89 025 (Cont'd) l The FSAR and Technical Specifications were' reviewed for j applicability. No accidents or malfunctions evaluated in the FSt.R j reference loop drains or their input into the Reactor Coolant Drain Tank Subsystem. This temporary modification allows pressurization of the reactor coolant. system without '
overpressurizing any WL system piping'and will not affect the safe operation of the plant. I
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The Reactor Coolant Drain Tank Subsystem of the Liquid Waste !
Processing System is shown on P&ID SR309F05022 #2. This subsystem ;
receives various valve leakoffs from the reactor coolant system, accumulator drains, transfers from the pressurizer relief tank, and reactor coolant system loop drains.
The four reactor coolant loop drain lines joint into a common three inch line connected to the reactor coolant drain tank subsystem. This'three incb line contains a spoolpiece, which is only installed when the ret.ctor coolant system is depressurized.
Normally, blind flanges are instS11ed in place of the spoolpiece 7 when the plant'is operating. This is required per Note 3 on P&ID -
L 5R309F05022 #2.
l -
l This temporary modification allows the removal of the blind flange l from the upstream side of the 3"WL1017WG7 piping. .This would l
prevent overpressurization of his line and allow entry into
- h. Mode 3. Thore is still' double valve protection upstream of the ;
j open pipe. ,
The FSAR was reviewed for applicability. This temporary modification will allow pressurization of the reactor coolant system without over pressurizing this portion of the Liquid Waste l Processing System. The removal of this blind flange will not create the possibility for any new accidents or malfunctions not previously evaluated in the FSAR. It prevents a possible overpressurization accident from occurring on this pipe.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Reactor Coolant Drain Tank Subsystem of the Liquid Waste Processing System is shown on P&ID SR309F05022 #2. This subsystem receives various valve leakoffs from the reactor coolant system, accumulator drains, transfers from the pressurizer relief tank, and reactor coolant system loop drains.
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Attechnent ST HL AE 3260 !
Page 76 of 227 Unreviewed Safety Question Evaluation e89 025 (Cont'd)
The four reactor coolant loop drain lines joint into a cormon three inch line connected to the reactor coolant drain tunk subsystem. This three inch line contains a spoolpiece, which is '
only installed when the reactor coolant system is depressurized.
Normally, blind flanges are installed in place of the spoolpiece ,
when the plant is operating. This is required per Note 3 on P&lD '
5R309r05022 w2.
This temporary modification allows the removal of the blind flange '
from the upstream side of the 3'WL1017WG7 piping. This would !
prevent overpressurization of his line and allow entry into l i Mode 3. There is still double valve protection upstream of the l open pipe, i i
The Technical Specifications and their Bases were reviewed with ,
regards to this temporary modification. The loop drains, !
associated valves, and the Reactor Geolant Drain System are not mentioned in sny Technical Specification or any Basis for a ;
Technical Specification. This temporary modification does not !
t reduce the margin of safety as defined in the basis for any ;
l technical specification. It prevents over pressurizing the
) Reactor Coolant Drain Tank subsystem and will still provide double i valve protection for the reactor coolant system on this line.
i Based upon the above, there is no unreviewed safety question.
Approved: 2/20/89 ,
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Page 77 of 227 l 1)nreviewed Safety Question Evaluation e89 026
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Subj ect: Diesel Generator Engine. Mounted Intercooler Piping Spools !
Description:
Carbon steel spools which have corroded in service are to be '
replaced with carbon steel spools lined with a baked epoxy phenolic coating. 1 Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability l of occurrence or the consequences of an accident or !
malfunction of equipment important to safety previously '
evaluated in the safety analysis report?
I The probability of occurrence of an accident previously evaluated in the safety analysis report is not increased -
because the standby diesel generators are accident.nitigation devices and do not initiate accidents previously evaluated in '
the safety analysis report. !
r The consequences of an accident or malfunction of equipinent important to safety previously evaluated in the safety analysis report is not increased because the modification has been shown to not degrade the current leve.1 of reliability of the diesel engines. ,
- 2) Does the subject of this evaluation create the possibility for i
! an accident or malfunction of a different type than any ;
i eval...ted previously in the safety analysis report? !
No accidents of a different type than previously evaluated in ;
the SAR are envisioned that would be initiated by the SDGs. l' An unevaluated malfunction would involve loss of diesel intercooling in all three SDG trains. However, the .
reliability of the piping /coaing subsystem is such that there {
is reasonable assurance that this sort of malfunction will not occur. Failure to provide turbocharger intercooling in one l
train would be considered a single failure (already assumed) ,
and would result in reduced SDG capacity, rather than complete loss of the SDG source.
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ST HL AE 3260
( Page 78 of 227 Unreviewed Safety Question Evaluation e89 026 g' Cont'd) ,
l 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical i specification?
The margin of safety ensures that at least two redundant ,
i trains of standby diesel generators (SDC) are available and i operable during accident conditions with a single failure in i the other train. The reliability of the replacement !
h coating / piping subsystem is such that the reliability of the -!
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SDGs is not reduced. Thus, the margin of safety is not '
, reduced. [
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Based upon the above, there is no unreviewed safety question.
Approved: 4/18/89 ,
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Att:chment ST HL AE 3260
}(- Page 79 of 227 I
~0nreviewed Safety Question Evaluation #89 027 s Subject; Modifice. tion of the Liquid Waste System I
Description:
The Reactor Coolant Drain Tank Subsystem of the Liquid Waste Processing System is shown on P&lD 5R309r05022 el and w2.
l- This subsystem receives various valve lenkoffs from the
- reactor coolant system, accumulator drains, transfers from the
} pressuriser relief tank, and reactor coolant system loop
! drains, f !
The four reactor coolant loop drain lines join into a common three inch line connected to the reactor coolant drain tank subsystem. This three inch line contains a spoolpiece, which is only installed when the reactor coolant system is !
depressurized. Normally, blind flanges are installed vice the {
spoolpiece when the plant is operating. This is required per Note 3 on P&lD 5R309F05022 #1. !
The loop drain lines contain two isolation valves prior to the !
location where the spoolpiece is installed. The valves have a small amount of leakage and over time the line upstream of the j blind flange would become overpressurized (reactor coolant ,
system pressure on a 150# line). This condition was ;
identified as a nonconformance and Engineering is currently ,
investigating a problem report (SPR 89 0075). The line is !
non safety class 7 piping. l i
l This change allows the venting of the blind flange from the l l upstream side of the 3'WL1017WG7 and 3*WL2017WG7 piping. This !
would prevent overpressurization of this line. There is still .
double valve protection upstream of the open pipe. I l Safety Evaluation: .
- 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of l l equipment important to safety previously evaluated in the safety
- l analysis report? ;
i The FSAR and Technical Specifications were reviewed for ,
applicability. No accidents or malfunctions evaluated in the FSAR l reference loop dr .ns or their input into the Reactor Coolant !
D Drain Tank Subsyster. This modification does not affect the !
supports for t.his piping, and thus will not change the seismic
- criteria. This modification allows pressurization of the reactor coolant system without overpressurizing any VL system piping and will not affect the safe operation of the plant.
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Attachment '
ST HL AE 3260 i Page 80 of 227 i k ,
i
, Unreviewed Safety Question Evaluation wS9 027 (Cont'd) "
h
- 2) Does the subject of this evaluation create the possibility for an
- l- accident or malfunction of a different type than any evaluated previoenly in the safety analysis report?
j The venting of this blind flange will not create the possibility l
for any new accidents or malfunctions not previously evaluated in
- the FSAR. It prevents a possible overpressurization accident from !
occurring on this pipe. !
i ;
l Routing the leakage to the nearby floor drain will provide better [
j control of the Isakage and is consistent with ALARA philosophy.
l The addition of this potential leakage to the floor drain system !
(FSAR Figure 9.3.3.2) will not have a significant impact o.4 the drain system. The drain system lines are four inches and greater ,
and have significantly tore capacity than the three eights inch ;
tubing which will be used to vent the blind flange. This is also consistent with the design function of the floor drain system
['
which is to collect and convey various operational waste liquids j from their origin to a collection point (FSAR 9.3.3.1), i
- 3) Does the subject of this evaluation reduce the margin of safety as
- defined in the basis for any technical specification?
l The Technical Specifications and their Bases were reviewed with regards to this temporary modification. The loop drains, l associated valves, and the Reactor Coolant Drain System are not
- menti.oned in any Technical Specification or any Bauis for a '
Technical Specification. This modification does not reduce the ;
margin of safety as defined in the basis for any technical i specification. It prevents overpressurizing the Reactor Coolant Drain Tank subsystem and will still provide double valve ;
prctection for the reactor coolant system on this line.
I l Based upon the above, there is no unreviewed safety question. '
l Approved: 2/23/89 1
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ST.HL AE.3260 Page 81 of 227 i Unreviewed Safety Question Evaluation o89 024
Subject:
Change in Boron Recycle System and Evaporator Performance Preoperational Test Schedule
Description:
Correspondence dated December 3,1988 (ST.HL AE 2870) made the commitment to perform the Boron Recycle Systa.m and Evaporator Performance Preoperational Test prior to Mode 2 of Unit 2.
Completion of portions of this test are to be deferred until prior to Unit 2 Commercial Operations.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
There are no accidents discussed in Chapter 15 of the FSAR for the Boron Recycle System. STPEGS TSAR Chapter 15 addresses accidents associated with the Liquid Vaste Processing System. One of these accidents is rupture of a recycle holdup tank and the resulting radiological consequences. Deferral of the affected portions of this test will not increase the probability of this tank rupturing. This delay will not make either of the recycle holdup tanks more likely to rupture. In addition, deferral of testing will not change the radiological content of CVCS letdown into the recycle holdup tank; thus, it will not change the radiological consequences of an accident. The affected portions will not be used prior to completion of the test.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The proposed deferral of testing the affected portions of the Boron Recycle System will not create the possibility of any accident or malfunction not previously evaluated in the FSAR.
This deferral means that the boron recycle evaporator will not be available to process CVCS letdown from the tr; cycle holdup tanks during the period of the delay. Since the Boron Recycle Evaporator will not receive radioactive effluent during the period before testing begins, this delay also decreases the possibility of a malfunction, leak, or rupture of any equipment in the Boron Recycle Evaporator Package.
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Page 82 of 227 l l !
/ Unreviewed S.sftty Question Evaluation e69 028 (Cont.) *
- 3) Does the subject of this evaluation reduce the margin of safety as '
! defined in the basis for any technical specification?
i l The Boron Recycle System is not included or required by any Technical Specification.- The Boron Recycle System is not referenced in any basis for a Technical Specification. This
- deferral means that the boron recycle evaporator will not be
, available to recycle CVCS letdown from the recycle holdup tanks
- 1 until conclusion of testing. This will not reduce the margin of eafety in any basis for any Technical Specification.
Based upon the above, there is no unreviewed safety question.
Approved: 2/27/89 f f
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, I Attcchment .
ST.HL.AE 3260 [
Page 83 of 227 l Unreviewed Safety Question Evaluation w89 029 ,
"i.
Subject:
RHR Design Heat Removal Capacity
Description:
FSAR Table 5.4 8 shows heat removal capacity of RHR heat !
exchanger at CCW inlet / outlet temperature of 105/121.1 and .
Reactor Coolant I/O temperatures of 150/123.7 as 31.2 Mbtu/hr. l At those I/O temperatures, heat exchanged is 39.4 Mbtu/hr. l I
Safety Evaluation: i
~
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety
! analysis report? i There is no change to equipment, assumptions, or results. The change matches the results to the assumptions. The actual ,
equipment capacity for heat transfer is greater than that originally described in the FSAR. There is no increase or decrease in accident consequences as the correct value was used in accident analyses.
- 2) Does the subject of this evaluation create the possibility for an i accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The subject of the evaluation makes no physical change, but ,
corrects the heat exchanged value to match the assumed I/O temperatures. Therefore, this change does not create the i possibility for an accident or malfunction of a different type, t
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Section 3/4.5.6 does not consider heat exchanger capacity in the ;
bases. Since there is no change to heat exchange surface or flow i rates, the margin of safety is not reduced. [
4 Based upon the above, there is no unreviewed safety question.
Approved: 5/2/89 i A1/P2.NL/
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i 4 Att% hment ST.HL.AE.3260 l Page 84 of 22*/ i I !
L Unreviewed Safety Question Evaluation e89 030 t
Subject:
Metrology Laboratory f l-
Description:
Procedure NE.7,04Q has been developed which defines the
,' -4 organizational reporting structure and responsibilities for ;
the Metrology Laboratory Division. ;
Safety Evaluation: f 4 i I 1) Does the subject of this evaluation increase the probability of ;
! occurrence or the consequences of an accident or malfunction of p equipment important to safety previously evaluated in the safety ;
e analysis report? !
This is an organizational change and does not increase the l probability of occurrence or the consequences of an accident or I malfunction of equipment important to safety previously evaluated !
in the safety analysis report. !
! L
- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated :
previously in the safety analysis report?
This is an organizational change and does not create the possibility for an accident or malfunction of a different type ,
than any evaluated previously in the safety analysis report. l i
- 3) Does the subject of this evaluation reduce the margin of safety as i defined in the basis for any technical specification?
t This is an organizational change and does not reduce the margin of j safoty as defined in the basis for any technical specification, t
i Based upon the above, there is no unreviewed safety question. ,
Approved: 3/20/89 i i i l'
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Attachment 3T.HL AE 3260 Page 85 of 227
( Unreviewed Safety Question Evaluation w89 032
[
Subject:
Instrument Setpoint Revision for Caseous W ste System l
[
Description:
The setpoint of the pressure switch for the Boron Recycle Holdup Tank has been changed. Startup test results demonstrated that the as built pressure drop in the header is much higher due to piping configuration.
Safety Evaluation:
1
! 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The change ensures operability of the system in accordance with design. The drainage does not impact Waste Cas System Failure analysis as described in FSAR Section 15.7.1.1. The instrument is non nuclear safety related. The change does not increase the probability or the consequences of an accident or malfunction of equipment important to safety.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The change ensures operability of the system in accordance with design. The instrument is non nuclear safety related. The change does not create the possibility for sa accident or malfunction outside current FSAR scope, 1 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change is to the range and setpoint to accommodate as built pressure drop in the vent header. This change has no impact on gaseous effluent releases mentioned in the Tech Specs because the volume and activity in the vent header remain unchanged. This change does not impact the margin of safety in the analysis or assumptions of Tech Specs concerning effluent releases of the Caseous Waste Processing System.
l Based upon the above, there is no unreviewed safety question.
Approved: 3/9/89 A1/P2.NL7
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Attachment ST.HL.AE 3260 Page 86 of 227 Unreviewed Safety Question Evaluation e89 033
Subject:
RHR Pump 2C Motor Struts i
Description:
Struts arm being added to the motor on RHR Pump 2C to reduce !
! vibration in the pump / motor assembly. The struts will I eventually be proposed for all RHR pump motors. The support ;
will enhance the assembly's vibration performance by changing [
!- the resonant frequency of the structure away from the pump i operating frequency. j i Safety Evaluation: !
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of L equipment important to safety previously evaluated in the safety
- analysis report?
l The RHR pump motor assembly is qualified for operation during design basis events. Addition of the struts will not affect the ability of the pump to perform its function. Westinghouse has performed an analysis to determine the effect of the struts on the seismic qualification of the pump / motor assembly. The conclusion was that the putrp/notor assembly will retain its structural integrity and its operability. The evaluation is shown in WCAP 11216. Revision 4, Based on this, the change does not increase the probability of occurrence or consequences of an accident previously evaluated in the SAR.
I
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
i Based upon the conclusions of WCAP 11216, Revision 4, and with no l changes to the function or performance of the RHR pump or RHR system, this change does not create the possibility of any new accidents.
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A Att hment ST.HL AE 3260 Page 87 of 227
'; O Unreviewed Safety Question Evaluatian e89 033 (Cont'd)
- 3) Does the subj$ct of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Addition of the mot.or supports will help maintain the current margin (s) or safet.y by minimizing the measurable effects of any minor imbalances in the RHR pump / motor assembly. The struts eliminate the uncertainty associated with the upper motor area vibration and allow the vibration monitoring program to concentrate on the vibration measurement trends at the pump and lower motor areas.
Based upon the above, there is no unreviewed safety question.
Approved: 3/8/98 l
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- ST.HL. AE. 3260 -
[
Page 88 of 227 j i 6 Unreviewed Safety Question Evaluation e89 034 t ,
Subject:
MAB HVAC Supply Air System Flow Changes !
Description:
The supply air at MAB el 60' is being readjusted to maintain ,
the area at slightly negative pressure with respect to :
atmosphere per design criteria. I i L Safety Evaluation: (
- 1) Does the subject of this evaluation increase the probability of l
, occurrence or the consequences of an accident or malfunction of L equipment important to safety previously evaluated in the safety analysis report?
The MAB supply air system is a nonsafety.related system and does !
not serve any safety function. The reduced supply air meets the cooling load, air change, and other design requirements, and therefore has no effect on any safety or nonsafety l systems / equipment. (The safety class equipment are provided with [
their own supplementary safety class cooling units.) All cooling :
requirements are maintained for nonsafety.related equipment. :
Therefore, nonsafety equipment utilized in Appendix R is not affected. l
[
- 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
Since the new supply air flow meets all design requirements, it i does not create any possibility for an accident or malfunction not described in the FSAR. The basic design requirements identified l l in the system design and FSAR have not changed, with the exception l~ of flow. This system is not required to operate during any ;
l transient or accident postulated in FSAR Chapter 6 or 15. !
L r l 3) Does the subject of tnis evaluation reduce the margin of safety as defined in the basis for any technical specification?
l The Technical Specifications have no requirements for MAB supply f air flows. Sections 3/4.7 and 3/4.13 govern areas served by I safety related HVAC. Since this system is non safety and does not
- provide any safety function, it is not governed by the referenced sections. Therefore, the margin of safety is not affected by this FSAR.
Based upon the above, there is no unreviewed safety question.
Approved: 3/8/89 t l
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Attcchment ST.HL. AE. 3260 Page 89 of 227 Unreviewed Safety Question Evaluation *89 036 l
Subject:
Decommissioning of 34 Main Cooling Reservoir Piezometers Description; Thirty.four Main Cooling Reservoir (MCR) piezometers located in the impoundment area of the MCR were decommissioned as water levels increased.
Safety Evaluation:
i'
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The subject piezometers were intended to provide initial data to establish an effective seepage entrance. This task has been accomplished and the seepage entrance is now analytically determined with data from the remaining plezometers outside the impoundment area. During all modes of operation, including emergency operations, the ground water conditions can be characterized with the remaining piezometers.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Piezometer data related to accidents was beyond the scope of the safety analysis report. Decommissioning the subject piezometers affects the ability to measure entrance gradients, but this information can be analytically derived. The analytical solution is an acceptable alternative to the measured seepage entrance.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
l I
Piezometers are beyond the scope of the technical specifications.
The subject piezometers were designed to be decommissioned after a seepage entrance was measured. No reduction in the margin of I safety is realized since the seepage entrance can be determined l
with data from the remaining piezometers.
1.
l Based upon the above, there is no unreviewed safety question, i
Approved: 3/29/89 l
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Attachment ST.HL.AE.3260 Pt.ge 90 of 227 Unreviewed Safety Question Evaluation e89 038
Subject:
Spent Fuel Racks
Description:
All High Density Spent Fuel Racks were intended to be installed prior to any spent fuel storage in the Spent Fuel Pool. However, permanent installation of racks 12 and 16 is to be delayed for several years to allow greater flexibility in the spent fuel pool area for fuel assembly and control rod inspections.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of ar accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The seismic analysis includes conservative assumptions for hydrodynamic coupling forces and their effects on adjacent racks for the conditions when the racks are immediately adjacent to each other as well as relatively large distances between racks. The absence of racks 12 and 16 from the pool will have no effect on the conservatively analyzed movement of the racks nor the rack mechanical stresses.
The Fuel Handling Building Structural analysis / design is based on all the racks in the pool, so that leaving out two racks decreases the induced loading on the support structure. Therefore the existing building analysis / design is conservative.
All thermal. hydraulic and environmental evaluations are based on all racks in the pool. Leaving two racks out has no effect on these evaluations.
The fuel's nuclear criticality analysis is based upon conditions (i.e. center to center spacing of fuel assemblies, poison material l between assemblies, presence of water, etc.) which are unaffected
( by leaving out two racks, 1
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Attachment ST.HL.AE.3260 i Page 91 of 227 Unreviewed Safety Question Evaluation e89 038 ' Cont'd)
[ Safety Evaluation Cont'd.
L Accordingly, delayed installation of two spent fuel racks does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety U previously evaluated by the safety analysis report.
Puture installation of racks 12 and 16 will be accomplished in accordance with the requirements of the ' Control of Heavy Loads
- Program (ST.HL.AE.1129, dated October 19, 1984). The future installation of the two remaining racks will be accomplished in a manner to assure' personnel radiological exposures as low as reasonably achievable. The NRC shall be notified prior to the installation of the remaining racks to outline the methods for handling the heavy loads and to address the ALARA considerations (See ST.HL.AE.2951).
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Installation delay does not create the possibility for an accident or malfunction of a different type than any previously evaluated in the safety analysis report. See discussion under (1).
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Tech Spec requirements as defined in the Design Features ,
Section (5.6) shall also be fully maintained. Keff $ 0.95, !
nominal center to center between fuel assemblies, natural absorber ;
between the fuel assemblies, and storage capacity (no more than l 1969 fuel assemblies), are all unaffected by this evaluation. '
Based upon the above, there are no unreviewed safety questions. )
Approved: 4/18/89 i l
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ST.HL. AE. 3260 !
Page 92 of 227 l Unreviewed Safety Question Evaluation #89 039 l I
Subject:
Temporary Diesel Cenarator Vater Jacket Heater i
Description:
A damaged 40 kw jacket water heater is to be replaced temporarily with an 18 kw heater on a standby diesel i generator. The 18 kw heater was originally supplied for use ;
in this application, and will be installed until a 40 kw ,
replacement can be obtained. !
Safety Evaluation: l
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of .
equipment important to safety previously evaluated in the safety l analysis report? L i
The function of the heater is to maintain a " keep warma jacket !
vater temperature above 120'F when the diesel is in standby mode ,
to facilitate quick starts. The 18 kw heater was originally f supplied and used successfully in this application. Because the 18 kw heater can maintain jacket water temperatures within the '
specified range, start times will not be adversely affected and the standby diesel generator will respond as analyzed in the SAR. ,
Therefore, use of a 18 kw heater in lieu of a 40 kw heater does [
not increase probability of occurrence or the consequences of an ;
accident or malfunction of equipment important to safety :
previously evaluated in the safety analysis report. !
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ;
previously in the safety analysis report? !
The 18 kw heater is adequate for maintaining the engine jacket water temperature while in standby, and will not affect its ;
ability to fulfill its safety related function. Therefore, use of the 18 kw heater does not create the possibility for an accident ;
or malfunction of a different type than any evaluated previously l in the SAR. l i
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Attachment ST.HL.AE.3260 Page 13 of 227
- 4 Unreviewed safety Question Evaluation $69 039 (cont'd) l
- 3) Does the subject of this evaluation reduce the margin of safety as j i defined in the basis for any technical specification?
The 18 kw heater will maintain standby jacket water t6mperature in '
the range 120'.130'T as described in the SAR. Therefore, use of the 18 kw heater does not reduce the margin of safety for any ;
technical specification. l l
3 :
Based upon the 'above, there is no unreviewed safety question.
i Approved: 7/18/89 l I
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I Att%hment ST l!L AE 3260 Page 94 of 227 o Unreviewed Safety Question Evaluation eB9 040
Subject:
Boric Acid Transfer Pumps and Reactor Makeup Vater Pumps ESF Status Monitoring
Description:
The pull to lock input to BYPASS /INOP indication for the boric acid transfer pumps and the reactor makeup water pumps is to
- be deleted. Previously, when the operator put one boric acid transfer pump and one reactor makeup water pump in pull to.
lock (thus inhibiting any automatic start signals from the
! CVCS makeup system), the ESP status monitoring system windows for BYPASS /INOP of these pumps would light.
L Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
i The probability of occurrence or consequonees of accidents are not affected by this change because this change does not affeet the operability of the pumps in question. Only the BYPASS /INOP indication is affected by the change, which is to avoid the nuisance alarm when one pump is put into pull to lock per procedure. Note that pumps do not receive automatic ESFAS start signals, and thus are not impaired from performing any safety function by being put into pull to lock.
- 2) Does the subject of this evaluation create the possibility for an accident or ualfunction of a different type than any evaluated previously in the safety analysis report?
This change does not create the possibility for an accident or malfunction different than those previously evaluated since only the BYPASS /INOP indication is affected. Operation of the pumps is not affected by this change. The change removes nuisance alarms when one of each set of pumps is put into pull to lock per procedure.
l
- 3) Does the subject of this evaluation reduce the margin of safety as Jefined in the basis for any technical specification?
l l The margin of safety as defined in technical specification bases l is not affected by this change because operation / operability of the boric acid transfer pumps is not affected by this change.
Based upon the ebove, there is no unreviewed safety question.
Approved: 3/29/09 A1/P2.NL7
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9 Attc hment i i ST.HL.AE.3260 l l page 95 of 227 l l
Unreviewed Safety Question Evaluation e89 041 l
l
Subject:
Critical Heat Flux (CHF) Correlation 9
Description:
The correlation used in design basis CHF calculations is being j changed from the V.3 to the VRB.1. Use of the VRB.1 CHF ;
correlation aflords additional Critical Heat margin for STpECS '
Units 1 and 2. This margin may be used to offset the effects of the RCS Flow Anomaly and Rod Bow.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of 1 equipe nt important to safety previously evaluated in the safety j analysis report? ;
The proposed change reflects an improved method of calculating the CHF margin to safety. The improved method ine.reases the j calculated CHF margin to safety. (Exceeding the CHF margin to l' safety results in fuel cladding failure.) The proposed change does not increase the probability of occurrence or the l consequences of an accident.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ;
previously'in the safety analysis report? !
The proposed change reflects a method of calculating the CHF !
margin to safety. It is used to calculate the consequences of an accident only. As such, it does not create the possibility for an ;
accident or malfunction. l
- 3) Does the subject of this evaluation reduce the margin of safety as ,
defined in the basis for any technical specification?
The proposed change increases the calculated CHF margin to safety. !
Based upon the above, chere is no unreviewed safety question. i Approved: 3/22/89
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Attachment ST.HL.AE.3260 Page 96 of 227
,' i
~~
Unreviewed Safety Question Evaluation e89 042
Subject:
Quality Assurance During the Operations Phase
Description:
This change to the FSAR reflects organizational changes and reassignment of responsibilities.
- ' Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
These changes are administrative only, and will not increase the probability of occurrence or the consequences of an accident or malfunction.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
These organizational changes are administrative only. They do not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in c'.te basis for any technical specification?
These organizational changes are administrative only. They do not reduce the margin of safety as defined in the basis for any technical specification.
Based upon the above, there is no unreviewed safety question.
Approved: 3/22/89 A1/P2.NL7
Attachment 3
ST.HL. AE.3260 Page 97 of 227 Unreviewed Safety Question Evaluation e89 043 ,
j
Subject:
Proper Tail.to. Actuate Alarms for RCP Seal Injection Containment !
Isolation valves ;
Description:
ERFDADS software is to be revised to provide proper alarm!ng of '
RCP seal injection containment isolation valves fail.co. actuate condition.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of f occurrence or the consequences of an accident or raalfunction of
- equipment important to safety previously evaluated in the safety analysis report? '
The probability of occurrence or consequences of accidents are not increased by this change because this change corrects the fail.to actuate alareing of the PCP seal injection containment '
isolation valves. There are no changes to the automatic response to an accident signal. On the basis that en improper alarm l condition is being corrected, which could potentially result in i operator action to close these valves when not necessary and thus ,
isolate seal injection to operating RCPs, the consequences of an i accident may be reduced by implementing this change.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated '
previously in the safety analysis report?
Implementation of this change will not create the possibility for an accident of nalfunction not previously evaluated since the change, results in a fail.to actuate alarm only when the valve should have actuated to the closed position. This result was the intent of the fail.to actuate system, and this change results in conformance to that design intent.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change has no effect on the margin of safety, unless it results in fewer changes to the RCP's, and therefore may increase I the margin of safety. The change results in a proper alarm condition for the operators.
l' Based upon the above, there is no unreviewed safety queration, Approved: 3/29/89 l
A1/P2.NL7
JJ Attachment ST.HL.AE 3260 Page 98 of 227 Unreviewed Safety Question Evaluation e89 045
Subject:
Revision of Channel 11 and III Battery Charger Bypass /Inop Indication
Description:
Bypass /Inop indication for Channel II and III Battery chargers is revised to indicated when either charger has input under voltage or both charger output breakers are open.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.?
This charge does not affect the probability of occurrence or the consequences of an accident because the change only affects the Bypass /Inop indication of the battery chargers. It does not alter the normal operating lineup of the battery chargers.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change does not affect the probability of occurrences or the consequences of an accident because the change only affects the bypass /inop indication of the battery chargers. It does not alter the normal operating lineup of the battery chargers in any way.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The margin of safety is not reduced in any way because only the bypass /inop indication for the battery chargers is altered, not the normal operating lineup. This change does not affect the operability of the battery chargers as defined in Tech Specs, 3/4.4.8.2 or 3/4.8.3.
l Based upon the above, there is no unreviewed safety question.
Approved: 4/17/89 i
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Att03hment l ST.HL AE 3260 i Page 99 of 227 l l
Unreviewed Safety Question Evaluation 89 047 i l
Subject:
Rosin Designation for UWPS Demineralizers l l
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Description:==
TSAR Table 11.2 3 has been changed from a specific brand name l resin to allow changes in resin to accommodate changes in waste '
characteristics.
I Safety Evaluation:
- 1) Does >:he subject of this eveluation increase the probability of occur 1ence or the consequences of an accident or malfunction of I equipment important to safety previously evaluated in the safety I analysis report? I i
No accidents in the UWPF are analyzed in Chapter 15. However, j ruptures of the Recycle Holdup Tank and Evaporator Concentrates l Tank are addressed, both of which are upstream of the UWPS. 1 Neither tank contributes a waste stream directly to the LWPS '
demineralizers. Therefore, the change does not increase the l probability of occurrence or consequences of an accident or J malfunction previously evaluated, i
- 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The change involves optimizing the resin type to more efficiently i remove ionic contaminants from the waste streams. No physical changes to equipment, piping, or layout are proposed. Thus, no new accident will occur due to hardware changes, and the change itself will not provide a basis for any new type of accident. 3
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? l Sections 3/4.11 of the Tech Specs does not discuss or refer to the ,
resin type employed in the LWPS. Demineralizer resins do not form l the bases for any Tech Spec. Therefore, the proposed change does not reduce the margin of safety. ;
l Based upon the above, there is no unreviewed safety question.
Approved: 6/5/89 9
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Page 100 of 227 Unreviewed Safety Question Evaluation *89 048 l l
Subject:
West Catehouse HVAC Eysten l
Description:
The West Gatehouse HVAC Subsystem is to be replaced with a !
package AC unit increasing the cooling capacity from 261,250 ;
Btu /hr to 366.110 Btu /hr. l i
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of 1 occurrence or the consequences of an accident or malfunction of j equipment important to safety previously evaluated in the safety '
analysis report?
r Comfort air condition of outlying buildings serves no safety ,
function. Accident analyses in Chapter 15 do not consider comfort AC. The change does not increase the probebility of l occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated. ,
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? ;
Comfort air conditioning of the Catehouse serves no safety ,
function nor serves equipment having a safety function. Therefore, i i
tha change does not create the possibility for an accident or !
I malfunction of a different type.
- 3) Does the subject of this evaluation reduce the margin of safety as ,
I- defined in the basis for any technical specification?
Gatehouse comfort AC does not form the besis for any Technical Specification. Therefore, this change does not reduce the margin >
of safety. !
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. Based upon the above, there is no unreviewed safety question.
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, Approved: 6/13/89 1
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Attcnhment l ST.HL.AE.3260 Page 101 of 227 Unreviewed Safety Question Evaluation 89 049 r
Subject:
Steam Generator Manway Leak l
Description:
Steam Generator 1A, manway 13B, leaks at the 3 o' clock position. Repairs shall be implemented by sealant injection usder manway coverplate to stop the leak.
Safety Evaluation:
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- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety !
analysis report? i This repair does not impact any equipment associated with the safe
- shutdown of the plant, nor does it increase the probability of an
accident or malfunction to occur, because the sealant injection l
will not overstress the aanway closure. Chemical compatibility has been ensured through the Expendable Materials Program. The i sealant chemistry is compatible with secondary side chemistry and will not affect secondary chemistry for steam generator internals, t
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
. No different types of accidents are created by repair of this !
I steam generator leak because the design basis or function is not l being altered.
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- 3) Does the subject of this evaluation reduce the margin of safety as 4 defined in the basis for any technical specification? I i
This repair is to the secondary side of the steam generator and does not impact the margin of safety as described in the Technical Specifications. The seal assembly attaches to the outside of the ,
steam generator and therefore has no impact on the operability of ,
the generator. The sealant should not enter the generator; '
however, if it does, the sealant is compatible with the secondary ,
side chemistry. ;
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l Based upon the above, there is no unreviewed safety question. i l
Approved:
3/31/89 l
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i ST.HL.AE.3260 I Page 102 of 227 l t ,
l' Unreviewed Safety Question Evaluation wS9 052 i
Subject:
Deletion of Pseudo Rod Ej ection Test l l
Description:
The Pseudo Rod Ejection Test has been deleted from the South !
Texas Project Electric Ceneration Station Unit 2 Initial j Startup Test Progra.m.
I Safety Evaluation: l I
- 1) Does the subject of this evaluation increase the probability of occurrence or the ccnsequences of an accident or salfunction of l equipment important to safety previously evaluated in the safety 1 analysis report? l l
The testing performed on STPECS Unit 1 6emonstrated that the measured hot. channel factors for the Hot Zero Power (HZP) and 30%
power pseudo ejected rod configerations were less (more :
conservative) than those predicted in WCAP 11123 and assumed in 3 FSAR Chapter 15.4.8 (Safety Analysis). Additionally, Unit 2 HZP j testing verified that the measured hot channel factors were also >
less (more conservative) than those predicted in WCAP 11299 and assumed in FSAR Chapter 15.4.8. The actual Westinghouse design is !
conservative with respect to Safety Analysis assumptions, and the r Westinghouse calculational methodology for predicting hot channel i factors is consistent as well as conservative with respect to )
actual measured values. In addition, the seasurements made during '
Unit 2 HSP testing reaffirms the adequacy of both the Westinghouse !
design and calculational methodology for predicting hot.channi factors. Since the calculational models and design of Unit 2 are {
identical to those of Unit 1, the Pseudo Rod Ejection Test need :
not be repeated on Unit 2. This is in accordance with RC 1.68, l Appendix A.S.e, Revision 2. The deletion of this test will not '
increase the probability of occurrence or the consequence of an ,
accident or malfunction of equipment important to safety
( previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or salfunction of a different type than any evaluated previously in the safety analysis report?
The consequereces of a rod ejection accident are evaluated in STPECS FSAR Chapter 15.4.8, and the conservatism assumed have been i validated by Unit 1 testing. Therefore, deletion of this test will not create the possibility for an accident or malfunction of I a different type than any evaluated previously in the safety analysis report.
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L Att:::hment i' ST HL AE 3260 l
- Page 103 of 227
- i. Unreviewed Safety Question Evaluation 89 052 (Cont.) I i
- 3) Does the subject of this evaluation reduce the margin of safety as )
defined in the basis for any technical specification?
l i STPECS Unit 1 testing verified that the most limiting hot channel
! factor FQ(Z), when adjusted for uncertainty, was determined to be 2.2841 for the case when Rod D 12 was positioned 12 steps above l 6 its bank demand position. This was less than the limit established per Technical Specification 3.2.2 (FQ(Z) $ 5.000) for reactor power levels less than 50%. Since the adequacy of the Westinghouse calculational methods for predicting hot. channel i factors has been validated (as described in (1)), the margin of i safety will not be reduced, j 1
l Based upon the above, there is no unreviewed safety question. ;
i Approved: 04/18/89 1
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- - Page 104 of 227
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Unreviewed Safety Question Evaluation #89 054 Subj ect: Deletion of RHR Pumps Minimum Flow Orifices i
Description:
The ninimum recirculation flow orifices for the RHR pumps have l been deleted from the system because they were determined to cause excessive pipe vibration, Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of ;
t' occurrence or the consequences of an accident or malfunction of ,
equipment is,wortant to safety previously evaluated in the safety '
analysis report? ,
n Deletion of the orifices resulted in acceptable piping system and- 1 pump operation. Since this change resulted in better system j operation, there is no increase in the probability of occurrence l of an accident compared to the original system with the orifices installed. Similarly. . the consequences of an accident are not increased since this change results in better system operabilit y.
Acceptability of this change is documented in Westinghouse I calculations as listed in Appendix A of WCAP-11545, Rev. 1, "Desiga Basis Document Residual Heat Removal System".
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The basic configuration and operation of the RHR system is not changed by removal of the flow orifices. The orifices have been removed to prevent vibration in the miniflow lines. No new accidents or malfunctions have been created by this change and all system safeguards remain in place to ensure safe shutdown of the plant.
- 3) Does the subject of this evaluation reduce the margin of safety au defined in the basis for any technical specification? ;
This change does not impact the availability or function of the RHR pumps and will not reduce the margin of safety as defined in the Technical Specifications.
Based upon the above, .ere is no unreviewed safety question.
Approved: 8/18/89 l-A1/P2.NL7
Attachment ST HL-AE 3260 Page 105 of 227 Unreviewed Safety Question Evaluation #89 055
Subject:
Organizational Changes; Methods of Document Retention and Control
Description:
. This change reflects organizational changes and methods of document retention and control. The responsibility for )
document issue / distribution is changed from the Plant Manager to Document Control. !
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of I occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety analysis report? <
This is a change for administrative purposes and does not affect '
the operation or modification of equipment important to safety.
Therefore, this change does not increase the probability of i occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety analysis report.
I
- 2) Does the subject of this evaluation create the possibility for an ]
7 accident or malfunction of a different type than any evab ated l previously in the safety analysis report? l This change is'for administrative methods and organizational responsibilities of documentation. The change will not create the 4 possibility for an accident or malfunction of equipment important to safety.
- 3) Does the subject of this evaluatior. reduce the margin of safety .ns defined in the basis for any technical specification?
This change does not affect the basis for any technical specification since the technical specifications do not address the issue / distribution of procedures. The responsibilities for document issue / distribution are not specified for the Plant Manager in Section 6 of the Technical Specifications.
Based upcn the above, there is no unreviewed safety question.
Approved: 5/9/89 i
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Att:chment j ST HL AE 3260 !
Page 106 of 227 !
l, Unreviewed Safety Question Evaluation w89 056
Subject:
Energy Management and Control System - Unit 2
Description:
The change involves addition of new nonsafety related cables (that are being routed for the Energy Management and Control System) in existing cable trays.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important-to safety previously evaluated in the safety analysis report?
Since these new cables have no safety function and do not perform any control function, the only effect of the cable routing would be the potential for an increased combustible loading and the corresponding increase in the potential for a fire. However, the increase in the combustible loading for the affected fire areas is l still bounded by the analysis provided in the FHAR. Since the MIAR combustible loading remains bounding, the consequence of a postulated ffre in the affected fire areas / zones remains bounding.
L Therefore, this change does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the SAR.
l 2) Does the aubject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Review of the combustible loading calculation indicated that the present system will allow addition of the subject cables and will not create the possibility for an accident or malfunction of a different type than any evaluated in the FSAR (including the RIAR).
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Addition of the subject cables does not reduce the margin of safety as defined in the basis for any Technical Specification. The combustible loading of the new cables is bounded by the values presently in the MIAR for the affected fire areas / zones.
Based upon the above, there is no unreviewed safety question.
Approved: 4/13/89 A1/P3.NL7
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Attachment 3 ST HL-AE 3260 j Page 107 of 227 e
Unreviewed Safety Question Evaluation #89-057 Subj ect: Control Room Doses, TSC Doses, Offsite LOCA Dose, CWPS Doses, Puel
- Handling Accident Doses b
Description:
The proposed changes revise the FSAR descriptions of analyses and results for the subject doses. These changes were found to involve an unreviewed safety question. The changes have been submitted to the NRC under correr.pondence dated July 14, 1989 (ST.HL-AE-2940).
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Attachment ST.HL.AE-3260 Page 108 of 227 Unreviewed Safety Question Evaluation #89-058 Subj ect: Replace Small Bore Pipe Items in ECW Train C (as described below)
Description:
'ECW Train C is to be modified as follows:
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- 1) Cap selected vent and drain connections and delete the associated valve;
- 2) Replace piping stubs and piping root valves on annular pressure tap;
- 3) Replace remaining small bore fittings made of Al Br alloys susceptible to de-alloying.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the prc' .bility of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
s a) The vent and drain valves to be deleted were used for construction and hydrotesting convenience, but are not needed 1 or used for operation or maintenance of the system. The
, valves being removed were subject to passive failures of the valve stem packing and valve seat, both of which could result-in minor water leakage from the ECW system. The pipe caps replacing the valves have no credible failure mode. ,
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b) The 1/2" pipe stub and valve previously used for the annular root valves are not available in the CA614 Al-BR material, so these items are to be replaced by tube fittings and instrument i valves. All of the instrument tubing and instrument root !
valves in the ECW system are stainless steel so the replacement of several 1/2" Al-Br valves with 3/8" S.S. valves does not introduce any new failure modes or increase probability of failure of the system. 316 S.S. is cathodic I with respect to Al-Br, which means any gavanic corrosion will favor the 316 S.S. at the expense of the Al-Br material.
Because the volume of stainless steel added to the system is negligible in comparison to volume of Al Br the anodic affect on the aluminum bronze piping is negligible.
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[ Page 109 of 227 Unreviewed Safety Question Evaluation w89 058 (Cont'd)
I c) Replacement of small bore fittings and valves made of Al Br alloys susceptible to dealloying with a non-susceptible alloy (CA-614) will reduce (effectively eliminate) the probability of minor water leakage due to dealloying. The replacement alloy.is an approved material in this'applicat. ion. This replacement program was approved in Supplement 6 of the SER.
Therefore, none of the changes in this modification will ,
increase the probability of occurrence or consequences of an accident or malfunction previously evaluated in the SAR.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
a) The vents and drains to be deleted have no effect on system
' operation, so there is no possibility of creating a different type of accident or failure than previously evaluated. 1 b) The added stainless steel tubing and instrument valves are 1 identical to instrun.ent tubing and valves used throughout the l ECW system, so there is no possibility of creating a different type of accident or failure than previously evaluated. J c) The replacernent fittings and valves are functionally the same 1 as the old fittings, and the replacement material has been l extensively used in piping, valves, and other fittings throughout the ECW system; so there is no possibility of I creating a different type of accident or failure than i previously evaluated.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? l l.
[ The bases for Tech Spec 3/4.7.4 ensure that sufficient cooling l capacity is available for continued operation of safety-related oquipment during normal and accident conditions. None of the '
changes on this modification affect operation of the ECW system, so there is no reduction in the margin of safety as defined in the Tech Specs.
Based upon the above, there is no unreviewed safety question.
. Approved: 4/18/89 l
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' Tl Page 110 of 227 j l
Unreviewed Safety Queetion Evaluation #89 059 )
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Subject:
Isolation Valves Across the Fire Main Loops
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Description:
P&ID is to be revised to reflect the as-built isolation valves l
across the permanent and temporary fire main loops, f Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of i
occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety t
analysis report? ;
I I This change has no impact on the safety function of the Fire !
Protection System, nor any system, subsystem, or component. This change meets the requirements of 10CFR50 Appendix R and Appendix A of APSCB 9.5 1. The change does not increase the probability of occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety y analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change has no impact on the safety function of the Fire l Protection System, nor any system, subsystem, or component. This change meets the requirements of 10CFP50 Appendix R and Appendix A i l
of APCSB 9.5-1. The change does not create the possibility for an l accident or malfunction of a different type than any evaluated I previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as ,
defined in the basis for any technical specification? l l l L The Fire Protection System is not governed by any Technical l Specifications. This change does not compromise the safety margin i which has already been analyzed in the Fire Hazard Analysis Report i I
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Based upon the above, there is no unreviewed safety question.
Approved: 4/28/89 l
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l Attachment ST.HL AE 3260 Page 111 of 227 Unreviewed Safety Question Evaluation #89-060 ;
Subject:
Deletion of Axial Xenon Oscillation Test
Description:
The' Axial Xenon Oscillation Test has been deleted from the South Texas Project Electric Generating Station Unit 2 Initial Startup Test Program. Deletion of the test is in accordance with RC 1.68, Appendix A.S.d. Revision 2.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ,
analysis report?
Deletion of this test from the Unit 2 initial startup testing program will not increase the probability of occurrence or the consequences of an accident. Protection against fuel design limits being exceeded as the result of a xenon induced axial power imbalance is still provided by the Overtemperature Delta-T reactor trip function which uses measured axial flux difference an an input.
- 2) Does the subject of this evaluation create the possibility for an 1
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The testing performed on STPEGS Unit i demonstrated that the reactor core is controllable with respect to xenon oscillations. The Unit I reactor core index of stability was determined to be 0.024 hr-1, indicating a slightly divergent stability characteristic. This result was consistent with the FSAR which states that the reactor core index of stability can be positive throughout core life as long p as it is controllable. Since the design of Unit 2 is essentially
- identical to that of Unit 1 and the ability to suppress axial xenon l oscillations using control rod manipulation has been proven during Unit 1 testing, the Axial Xenon Oscillation Test need not be repeated on Unit 2, as stated in Regulatory Guide 1.68, Appendix A.S.D.
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l Attachment ST HL AE 3260 Page 112 of 227 Unreviewed Safety Question Evaluation #89 060 (Cont.)
- 3) Does the subject of this evaluation reduce the margin cf safety as defined in the basis for any technical specification?
Deletion of this test from the Unit 2 Initial Startup Test Program will not reduce the margin of safety assumed in the bases of any technical specification. Maintaining the axial power distribution in accordance with Technical Specification requirements ensures that any xenon induced axial power imbalances do not reduce the margin of safety. In addition, the Overtemperature Delta T reactor trip function provides protection against exceeding any fuel design limits.
Based upon the above, there is no unreviewed safety question.
Approved: 5/9/89 l
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Attachment ST.HL.AE.3260 Page 113 of 227
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Unreviewed Safety Question Evaluation #89 064 Subj ect: FHB Exhaust Flow Setpoints
Description:
The FHB Exhaust Flow setpoints are to be revised from 26,260 cfm i lot to 29,000 cfm 10% (corresponding to Tech Spec requirements). In addition, the priority of the Hi/Lo Flow Alarm is being revised - the FSAR is being changed to clarify when Hi/Lo flow rate alarm is effective.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
This change does not alter the response of the FHB HVAC equipment to -
an accident. It only modifies tne alarming provided 1) to agree with the accident response flowrate and 2) to alarm only when performing Tech Spec surveillance, or in emergency mode of operation
! of FHB HVAC system, as indicated by positions of filter inlet dampers. Therefore, this change does not increase the probability of occurrence or consequences of accidents / malfunctions previously evaluated..
, 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated previously in the' safety analysis report?
, This change does not affect the mode of operation of the FHB HVAC
! nystem. It only affects the alarming provided. Therefore, it does not create the possibility of an accident or malfunction different than those previously evaluated.
l l 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Since this change does not affect the mode of operation of the FHB HVAC system, it does not reduce the margin of safety as defined in the Tech Spec bases.
l Based upon the above, there is no unreviewed safety question.
Approved: 5/2/89 A1/P3.NL7
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Att:chment ST-HL AE 3260 Page 114 of 227 j Unreviewed Safety Question Evaluation #89 065 i
Subject:
Results of Engineering Review of FSAR Section 11.1
Description:
Revisions were made to source terms identified in Tables 11.1 4, 11.1 6, and 11.1-7 for consistency with calculations.
Safety Evaluation: !
1
- 1) Does the subject of this evaluation increase the probability of j occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safecy analysis report?
The subject of the change does not involve the description of equipment or procedures important to safety. The parameters.
described are used in the design of radiation shielding and to i evaluate the consequences of normal plant operation. No accident l analyses are affected by the changes, i
- 2) Does the subject of this evaluation create the posnibility for an l accident or malfunction of a different type than any evaluated ;
previously in the safety analysis report?
l The parameters described in the change do not pertain to the safety '
functions of equipment or systems described in the FSAR. The changes do not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the marB i n of safety as defined in the basis for any technical specification?
1 Tbo parameters addressed in the change are not used as the bases for l
any technical specifications nor the ODCM. Therefore, the margin of safety with respect to plant operation as governed by the Technical Specification is not affected, l
L Based upon the above, there is no unreviewed safety question.
Approved: 6/13/89 l
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i Attcchment ST-HL AE 3260 Page 115 of 227 Unreviewed Safety Question Evaluation w89 066 i
Subject:
Monitoring of Wind Speed and Direction i
Description:
FSAR Section 2.3.3 is being revised to reflect the "as built" design of the onsite meteorological seasurements program.
, Unit 2 wind speed and direc*, ion analog meters were deleted i prior to plant licensing.
L Safety Evaluation: ,
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety .
analysis report? !
Deletion of the wind speed and direction meters from the Unit 2 Control Room does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report. The i indicators'were Class 9, nonsafety related, and were for indication ~
only. Wind speed and direction information froc the primary and backup meteorological towers is still available in the Unit 2 Control Room on the ERFDADS and RM 21A computers.
- 2) Does the subject of this evaluation create the possibility for an I accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
s The analog wind speed and direction meters were for indication purposes only. Wind speed direction indication is still available in the Unit 2 Control Room via the ERFDADS and RM-21A computers.
Therefore, this change does not create the possibility for an L accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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ST HL-AE 3260 Page 116 of 227 Unreviewed' Safety Question Evaluation #89 066 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Deleting the analog meters for wind speed and direction from the Unit 2 control room does not reduce the margin of safety as defined in the basis for any technical specification. Operability of the wind speed and direction instrumentation was not affected by deletion of the subject meters. The analog meters indicated wind speed and direction at the 10-meter level of the primary tower only.
Wind speed and direction at the 10-meter level and 60 meter level on the primary tower and at the 10 meter level of the backup tower is displayed on the ERFDADS and RM 21A computers in Unit 2.
Based upon the above. there is no unroviewed safety question.
Approved: 5/2/89
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Att:chment ST.HL AE 3260 Page 117 of 227 Unreviewed Safety Question Evaluation #89 067 Subj ect: Human Engineering Discrepancies Schedule Change !
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Description:
Corrective action Category C Human Engineering Discrepancies (HEDs) is being rescheduled from second refueling of Unit 1 to third refueling.
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Safety Evaluation:
L 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety 1 analysis report?
Category C items are defined as being " equipment / plant reliability i enhancement" with implementation at a " convenient" outage (not to I exceed 2 years). Under this definition, there are no safety consequences associated with these HEDs. Had there been any safety i I consequences, they would have been categorized at a higher level.
(Note: the NRC staff concurred with the STPECS program for categorization of HEDs in SSER 4.)
- 2) Does the subject of this evaluation create the possibility for an ,
accident or malfunction of a different type than any evaluated l previously in the safety analysis report? l Identification of the HED implies that there is a slight potential for a human error and that is why these are classified as Category C l HEDs. The schedule for implementing corrective action has no l bearing on the type of error.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? !
i None of the Category C HEDs affect any Tech. Specs. By definition, 'I they are reliability enhancement items.
Based upon the above, there is no unreviewed safety question.
Approved: 4/28/89 ,
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Att:chmInt ST HL AE 3260 Page 118 of 227 i '
Unreviewed Safety Question Evaluation #89 068
Subject:
1988 Geotechnical FSAR Update l
Description:
This change incorporates data from geotechnical monitoring through 1988 to update FSAR text, tables, and figures.
t Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of .
equipment important to safety previously evaluated in the safety analysia report?
The subject CN describes building settlement, subsidence, piezometric. levels and local hydrocarbon activity. The areas of i concern described in the FSAR are differential settlement between buildings, building tilt, piezometric decline and subsidence. There are no limiting values on the total settlement or arount of hydrocarbon extraction recorded. The FSAR presents precise limits on differential settlement between buildings and building tilt only L from_ day 3400. Differentia 1'settleuent between buildings have been ,
I updated in FSAR section 2.5.C.4.6.1. These limits are tabulated on i FSAR tables 2.5.C-4 and 2.5.C-6. The updated values for differential settlement, presented $n this CN, are for total differential settlement and all predate day 3400, figures 2.5.C-11, l 2.5.C-11A, 2.5.C-12, and 2.5.C 12A. A calculation for the new data )
l will reveal differential settlement since day 3400 that is within 1 the limits described above. No such calculation is presented in j this CN. Allowable building tile is tabulated on tables 2.5.C 5 and j 2.5 C-7, again only since day 3400. The CN building tilts only since day 3400 are presented in figures 2.5.C-13C and 2.5.C 14B. ,
~
The newly reported
- ilt is within the limits described in the referenced tables. Figures 2.5.C 13A, 2.5.C-13B, 2.5 C 14, nd 2.5.C-14A show total foundation tilt which are updated in this CN and predate day 3400. A calculation based on these figures indicates tilt below the allowable. An analysis of this data for tilt since day 3400 is not included in this CN. The data used to support this CN is the basis for a quarterly calculation, 7YO1HYC50006 fourth quarter 1988, in which tilt and differential settlement are checked since day 3400 for all safety related structures.
Total settlement is presented in the revised figures 2.5.C-9, 2.5.C- ;
9A, 2.5.C-10, AND 2.5.C-10A. There are no limits set for the amount of total settlement. There are no limits set for the amount of total settlement. There are predicted maximum and minimum limits which are indicated in the above figures. The updated movements are wit bin the estimated bounds.
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l Attachm:nt ST HL AE 3260 Page 119 of 227 Unreviewed Safety Question Evaluation #89 068 (Cont'd)
The updated piezometric levels in this CN, figures, 2.5.4 650, 2.5.4 660, 2.5.4-708, 2.5.0 20B, 2.5.C 21B, and 2.5.C 22B show that the piezometric levels are within the limits described in FSAR sections'2.5.C.5.6 and 2.5.1.2.9.6.2.5. The updated decline in the deep aquifer is 3 ft, in a 2.5 year period,'section 2.5.4.6. The referenced sections of the FSAR describe an average decline in the deep aquifer of about 1.9 ft. per year. The updated CN data in the above modified figures support the'FSAk description, section 2.5.c.5.6, that the shallow aquifer has stabilized, l
It is assumed that hydrocarbon activity will affect subsidence. For j this reason hydrocarbon activity within a 15 mile radius of_the plant is monitored. The FSAR presents no limits on the amount of l
oil and gas that will produce excessive subsidence. The amount of ;
oil and gas reported in this CN, FSAR section 2.2 and 2.5.1, shows a general decline in production in the area.
Subsidence reported in the revised figures 2.5.C 23E and 2.5.C 23F is less than the predicted 0.3 in, per year, FSAR section 2.5.C.5.5.2. Vertical subsidence is also updated on figure .
2.5.C 19A and vertical and horizontal subsidence is updated on l figures 2.5.C-23A, 2.5.C 23B, 2.5.C 24A, and 2.5.C-24B. There are !
no limits or assumptions for horizontal subsidence. Horizontal l movements are also updated on table 2.5.C-3B. This CN shows no progressive horizontal movement.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ]
i previously in the safety analysis report?
l The updated data fall within the limits already ev:!"sted in the ;
FSAR. A comparison of the new data presenner here and the FSAR l assumed values is presented in the response to question 1, above, j Since this new data is within evaluated limits, there is no i potential to introduce an unevaluated condition with this chango, i I
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Attachment I ST HL AE 3260 Page 120 of 227 Unreviewed Safety Question Evaluation #89-068 (Cont'd) I 1
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specification? );
The FSAR and the SER are the only documents that reference limits to I the data presented in this change. SER section 2.5.4.2.1 repeats 3 the expected reduction in deep aquifer level presented in the FSAR ;
but does not address the other points included in this change.
Settlement, subsidence, piezometric' level and hydrocarbon activity I are not treated in the plant technical specifications. Since the 1 changes presented in this change are within the expected limits (see item 1 above), these new conditions have already been evaluated for i safety concerns. This change does not reduce the margin of safety beyond acceptable limits described in the plant documents referenced ;
above, i
Based on the above, there is no unreviewed safety question. '
. Approved: 5/9/89 ,
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[, Page 121 of 227 p
Unreviewed Safety Question Evaluation #89 069 Subj ect: Temporary modification to remove time delay relay from RCB purge l isolation actuation circuit.
Description:
Currently, these time delay relays are not qualified. A i failure of these relays can be postulated that would result in a valid signal not being sent to SSPS, and containment ventilation not occurring when required. The temporary modifications result in deletion of the time delay relay so
[ that the Hi Radiation signal (or " Monitor Failure signal-Unit ,
1 only) is sent to SSPS until it clears. The modifications ensure that containment ventilation isolation occurs in
' response to these signals from the RCB Purge Isolation Monitors.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ,
- analysis report?
l-This change results in the radiation monitor inputs to containment ventilation isolation being present at SSPS until they clear, rather than being present only for 60 seconds. Thus, there is no increase in probability of occurrence or consequences of accidents previously evaluated in the FSAR.
l
- 2) Does the subject of this evs.luation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since the radiation monitor signals will be present until they clear, rather than remove 6 after 60 seconds, there is no possibility for an accident or malfunction different than those evaluated in the FSAR.
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Attachment ST HL AE 3260 Page 122 of 227 a-Unreviewed Safety Question Evaluation #89-069 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Since the radiation monitor signals to SSPS will be present until they clear, rather than removed after 60 seconds, this modification does not reduce the margin of safety as defined in the basis for the Tech Specs.
(Note: When a RCB purge isolation radiation monitor sends a "Hi Radiation" or " Monitor Failure" signal to SSPS and causes a containment ventilation isolation signal, and the rad monitor signal is determined to be spurious, then that rad monitor is declared inoperable. Action 18 of Technical Specification Table 3.3 3 then i, indicates that operation may continue provided that the containment l purge supply and exhaust valves are maintained closed.)
Based upon the above, there is no unreviewed safety question.
l Approved: 4/20/89 1'
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Att chment ST-HL AE 3260 Page 123 of 227 Unreviewed Safety Question Evaluation #89 070 Subj ect: Feedwater Isolation Valve Solenoid Dump Valves Alternate Operability Test
Description:
Procedure 2TEP07-FW 0001 is being revised to verify valve operability in the event that the solenoid dump valve position ,
switches are not functional.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety i analysis report?
The solenoid dump valves must be operable for the Feedwater Isolation Valve (FWIV) to perform its safety related function (close). The solenoid dump valve position switches perform no safety function and are only used in the test circuit to show operability of the solenoid valves. The position switches have no effect on feedwater isolation and the FWIV closure time is unaffected.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Visual indication of the solenoid dump valve position switch actuated test relays or independently stroking the FWIV with one solenoid dump valve at a time is a more reliable test. The position l switches are only used in the test circuit to prove valve operability and have no effect on FWIV operation or valve closure times.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The intent of testing both solenoids for venting the hydraulic fluid (which causes the FWIV to fail in the closed position) is satisfied ,
by these procedure revisions. The commitment to use the position switches to monitor solenoid valve operation (ST-HL-AE-1273) is being changed to a visual or independent solenoid valve stroke test.
There is no affect on the applicable technical specifications.
Based upon the above, there is no unreviewed safety question.
Approved: 4/28/89 A1/P3.NL7
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- Page 124 of 227 l
I Unreviewed Safety Question Evaluation #89 071 i- ' Subj ec t : - Feedwater System Valve Operability' Test
Description:
Procedure 2 PSP 03-FW-0001 is being revised to verify valve I operability in tha event that the solenoid dump valve position switches are not functional. I Safety-Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?>
The solenoid dump valves must be operable for the Feedwater I Isolation Valve (FWIV) to perform its safety related function l (close).. The solenoid dump valve position switches perform no l safety function and are only used in the test circuit to show l operability of the solenoid valves. The position switches have no i effect on feedwater isolation and the FWIV closure time is unaffected.
- 2) Does. the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
l Visual indication of the solenoid dump valve position switch _
i actuated test releys or independently stroking the FWIV with one i
! solenoid dump valve at a time is a more reliable test. The position I l- switches are only used in the test circuit to prove valve l operability and have no effect on FWIV operation or valve closure times.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The intent of testing both solenoids for venting the hydraulic fluid (which causes the FWIV to fail in the closed position) is satisfied l by these procedure revisions. The commitment to use the position i switches, to monitor solenoid valve operation (ST-HL-AE-1273) is l being changed to a visual or independent solenoid valve stroke test. l There is no affect on the applicable technical specifications. l l
Based upon the above, there is no unreviewed safety question.
Approved: 4/28/89 l l
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Attachment ST HL AE 3260
- Page 125 of 227 Unreviewed Safety Question Evaluation #89 073
Subject:
Acoustical Monitor Setpoints
Description:
This change to the acoustical monitor setpoints for PORV valve position indication raises the setpoint for "open" indication from 62 millivolts to 200 millivolts.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of ,
occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety
+
analysis report?.
- These instruments perform no safety function. They provide display and status change information to the ERP computer. This change is intended to prevent false indication due to noise from adjacent valves. Operation of these instruments is not required per any safety analysis discussed in the SAR. Therefore, this change does not increase the probability or consequences of an accident or malfunction of equipment evaluated in the SAR.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Inadvertent opening of a pressurizer safety valve (or relief) has already been analyzed in FSAR 15.6.1. The results and consequences .t of this analysis are unchanged as a result of this change.
- 3) Does the subject of this evaluatior. reduce the margin of safety as defined in the basis for any technical specification? .
These instruments are not in the Technical Specifications and do not affect any item discussed in any section. Tech Spec 3/4.4.2 is not affected as a result of this change since these monitors do not affect the operability of the pressurizer safety valves.
Based upon the above, there is no unreviewed safety question.
Approved: 5/3/89 A1/P3.NL7
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Attachment ST-HL-AE-3260 Page 126 of 227
-Unreviewed Safety Question Evaluation #89 074 j
Subject:
Anti Snag Grid
Description:
This review addresses the changes to the STP Unit 1 and Unit 2 licensing bases required to support the use of the I Westinghouse anti snag grid design. The inclusion of the anti-snag grid in the STP fuel design will significantly I reduce fuel handling damage without loss of performance of ;
reliability, i Safety Evaluation:
1
- 1) Does the subject of this evaluation increase the probability of ;
occurrence or the consequences of an accident or malfunction of
- l. equipment important to safety previously evaluated in the safety ,
analysis. report?
The changes to the grid only affect the design of the outer perimeter strip of the grid. The mechanical strength of the grid L has not been reduced. .The thermal-hydraulic properties are not affected and DNB margins remain unchanged. No fuel design '
specifications or rargins, as described in the safety analysis report, are impacted by this design change. Although the total I weight of the grids in the core increases, the change represents less than 0.1% of the total fuel weight. This effect is negligible.
Therefore, the probability of occurrence or consequences of an accident or malfunction of equipment important to safety has not been increased.
l 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The changes to the existing grid design affect neither the mechanical nor thermal-hydraulic specifications for the fuel assembly. The overall fuel assembly dimensions and design specifications remain unchanged. The changes do not create the possibility for an accident or malfunction of a different type than those evaluated in the safety analysis report.
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! ST HL AE-3260
( Page 127 of 227 C ,
Unreviewed Safety Question Evaluation #89-074.(Cont'd)
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- 3) Does the subject of this' evaluation reduce the margin of safety as defined in the basis for any technical specification?
The margin of safety,'as defined in the Bases Section of the
! Technical Specifications, is not impacted by this grid design change. Since the thermal-hydraulic response of the existing fuel e design remains unchanged with the incorporation of the anti snag - ,
grid design, the limits referenced in the Section also remain ,
unchanged. These include the margin to DNB, limiting fuel 'I temperatures, fission gas release, fuel rod cladding properties, and I local power densities. However, as described in the attachment, the !
changes have a slight impact on fretting wear for some selected rods i i
within the assembly. This slight impact, however, remains well ;
within acceptable limits. The fretting wear design limit remains a l
factor of two greater than predicted wear. No other design or .
operational limits are impacted.
Based'upon the above, there is no unreviewed safety question.
Approved: 7/6/89
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Attachment ST.HL.AE.3260 Page 128 of 227 Unreviewed Safety Question Evaluation #89 077
Subject:
Hydrogen Recombiner Instrumentation i
Description:
The FSAR is to be revised to clarify the description of the hydrogen recombiner instrumentation. The wording has been revised to give a clear and correct description which is also consistent with wording provided in the H instruction manual.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report? ,
l The FSAR change only clarifies and corrects the FSAR wording. The i FSAR change does r.ot perform any physical changes to the plant. '
- 2) Does the subject of this evaluation create the possibility for an ,
accident or malfunction of a different type than any evaluated I previously in the safety analysis report?
l The FSAR change only clarifies and corrects the FSAR wording. No physical changes are required. The change does not affect operation j of the recombiners as previously evaluated.
- 3) Does the subject of this evaluation reduce the margin of safety as
' defined in the basis for any technical specification?
L The FSAR change does not perform any physical changes to the plant.
No physical changes are required. The FSAR change only clarifies and corrects the FSAR wording, l
1 l Based upon the above, there is no unreviewed safety question, q l l Approved: 5/25/89 l
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[ Page 129 of 227 i I
Unreviewed Safety Question Evaluation #89 080 h , i
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Subject:
Limit Switches for Normal / Supplementary Purge Sample Valves L
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Description:
This modification pluo the as-built conditions increase the total calculated cable weight in Fire Zone 32 Z145. This L total weight exceeds the values documented in FHAR Section 3.2.
( Safety Evaluation:
1
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously ovaluated in the safety analysis report? ,
1 The increased cable weight in zone 32 Z145 has no impact on the fire hazard analysis since there is no increase in the combustible loading value in the FHAR due to the conservative margin originally provided. This FHAR change does not create a change to the physical configuration of the plant nor any part of the plant, nor equipment important to safety previously evaluated in the SAR. This change has no impact on the safety function of the Fire Protection System i nor any system, subsystem, or component.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
l See response to (1). 1 I
l 3) Does the subject of this evaluation reduce the margin of safety as ]
defined in the basis for any technical specification?
This modification does not reduce the margin of safety for the reasons described in (1). Note that the Fire Protection System is not governed by any Technical Specification. l Based upon the above, there is no unreviewed safety question.
Approved: 5/9/89 A1/P3.NL7
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'd i l Attochment i ST.HL AE 3260 Page 130 of 227 !
Unreviewed Safety Question Evaluation #89 081
Subject:
Jumper Installation on Battery E2B11
Description:
This comporary modification calls for installation of a jumper from cell 45 to cell 47 on battery E2B11. This removes cell 46 from the battery.
Safety Evaluation:
I
- 1) Does the subject of this evaluation increase the probability of I occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The battery has been determined to be capable of adequately j
. performing its safety related function with 58 cells connected. The actual installation will use cable, lugs, etc. that c.re identical i to, or an approved equivalent substitute for the jumpers used to go from tier to tier. Therefore, this modification does not increase l the probability of occurrence or the consequences of an accident or l malfunction of equipment important to safety previously evaluated in I the SAR. '
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated l~ previously in the safety analysis report?
The modification deletes one cell from the battery through use of equipment identical to'or an approved equivalent substitute for that ]
already used on the battery. Load calculations for the class 1E battery have been examined, and electrical removal of one cell has L
been determined to not impair che ability of the battery to perform its safety-related function. Therefore, this modification does not l create the possibility for an accident or malfunction of a different ;
type than any previously evaluated in the SAR.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The margin of safety as defined in the bases for any technical specification is not reduced because the load profile that the
- i. battery is required to supply can be adequately supplied by 58 cells l
(vs.59). The current service test surveillance remains valid, because the load profile used in that surveillance uses currents 20%
higher than those in the battery calculation. Removing one cell is equivalent to adding approximately 2% more load to the remaining cell. This is within the 20% margin provided.
l Based upon the above, there is no unreviewed safety question.
Approved: 5/9/89 A1/P3.NL7
1 Attachment ST-HL AE 3260 Page 131 of 227 i
Unreviewed Safety Question Evaluation #89 085
Subject:
ECW Vent Fan
Description:
The temporary modification calls for installation of a metal cover plate over the building enclosure for ECW vent fan 3V151VFN006 to prevent air backflow through the ,pening from t the discharge of fan 3V151VTN005 back to its succion.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysin report?
Based on the analysis of both analytical and actual cooling load requirements, as presented in the Justification for Continued ;
Operation, single fan operation for ECW Train C pump room will maintain safety-related equipment within its environmental ?
.:emperature limits. Therefore, ECW pump operation will be j maintained during both normal and accident conditions.
- 2) Does the subjact of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ,
previously in the safety analysis report?
l Failure of one ECW vent fan does not create the possibility for an l
accident or malfunction of a different type than any previously l evaluated because the remaining fan (3V151VFN005) is adequate to provide heat removal from the room to maintain the required t l temperature limits.
- 3) Does the subject of this evaluation reduce the margin of safety as definnd in the basis for any technical specification?
l Based upon analysis of the actual heat 1 cad for the ECW pump room and inclusion of solar loads, the actual cooling requirements of the pump room are less than the calculated values used in the original system design. Single fan operation (3V151VFN005) is capable of maintaining the temperature units as specified in Tobic 3.7-3 of Technical Specification 3/4,7.13. Therefore, the margin of safety for ECW system operational and functional requirements is unchanged.
Based upon the above, there is no unreviewed safety question.
Approved: 5/15/89 ,
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ST.HL.AE.3260 Page 132 of 227 L
Unreviewed Safety Question Evaluation e89 086 Subj ect: Overvoltage Condi. ,n at Inverter Output Descriptinu: An overvoltage and fluctuating current condition was
- identtfied at output of inverter on Channel III.
Safety Evaluation:
i 1) Does the sut.iect of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
1he overvoltage incident occurred on only one channel. To date, the Maintenance Department has not experienced any abnormal equipment malfunction or failures which can be attributed to the overvoltage condition. We believe that the subject of this evaluation does not increase the probability of occurrence or the consequences of an accident because the design function has not been changed and the equipment is nov functioning per design. The design basis assumas
!- occurrence of the worst case failure of a single channel and, therefore, the subject of this evaluation does not increase the probability of occurrences or malfunction of equipment important to safety because there is no evidence of physical damage or palfunction. An overvoltage condition will shorten the life of electronic components connected to the bus. However, the effect of a smell overvoltage for a short period in a low temperature environasnt cannot be quantified since the lower temperature will help minimize the potential for damage. To date, no discernible nalfunctions have occurred. Sheuld a failure occur, it would be y readily detectable and the safety function would be ensured by redundant channels as presently analyzed.
l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The derign ic not being changed or any system being physically altered in the plant. The overvoltage only affected Channel III distributton panel DP1203, since it is independent of other channels and panels. Therefore, the overvoltage condition in this chtnnel l did not affect any other channels or panels and would not create the L possibility for an accident or malfunction of a different type n any evaluated previously in the FSAR. ,
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4 Att:chment c ST.HL AE 3260 l page 133 of 227 h
Unreviewed Safety Question Evaluation e89 086 (Cont'd) i 3) Does the subject of this evaluation reduce the margin of safety as f_ defined in the basis for any technical specification?
l The margin of safety is not compromised due to the evervoltage
! incident. The equipment t. hat experienced overvoltage is functioning per design. There is no evidence of any physical damago. The event
( subjected these instruments to a higher than usual voltare, but the Iow temperature environment helps to compensate'for any anticipated
- degradation.
I In addition, the fact that none of the equipment has failed or has shown any sign of degradation is considered sufficient to accept that this equipment is capable of performing its safety functions as designed.
In the future, the plant surveillance program, annunciation of any 4
malfunction in the equipment, and failure / deficiency trending program would assure that this equipment would stay operable and b9 replaced if degradation is detected, t-Based upon the above there is no unreviewed safety question.
Approved: 6/28/89 1
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Page 134 of 227 i i
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i Unreviewed Safety Question Evaluation w89 087
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Subject:
Mid Loop Level Instrumentation i l
Description:
This change adds instrumentation to measure the reactor vessel l l
water level in the hot legs during mid loop operation, t
! Safety Evaluation: j i
- 1) Does the subject of this eva*,uation increase the probability of ,
occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety !
analysis report? l l
The only safety related portion of the modification is addition of j the isolation valve in the 3/8" SS tubing which interconnects the i new level instrument to the existing primary sample tubing. (This j valve is normally closed in all modes of plant operation ercept mid- !
loop operation.) The valve and tubing up to the code break (including supports) is designed and purchased in accordance with the ASME code. Calculations and analysis have been performed to l ensure the code allowable stresses have been met. The connection to l the SI drain lines is after the code break. The complete level !
transmitter, gauge glass, and tubing installatica has been rupported ,
for seismic II over I criteria, and the Fire Hazards Analysis has ]
not been compromisea or exceeded. Therefore, this change does not i increase the probability of occurrence or the consequences of an l accident or malfuncticn of equipment important to safety previously evaluated in the safety analysis report. !
- 2) Does the subject of this evaluation create the possibility for an J accident or malfunction of a different type than any evaluated l
previously in the safety analysis report? >
l l Interconnections to the RCS are via 3/8" SS tubing. Failure of this equipment would not subject the RCS to a loss of inventory condition beyond the present analysis. During mid loop operation, the RCS is l basically at atmospheric pressure, while the design of this l installation is for 800 psig. Isolation of the installation during all other modes precludes accidents of any type.
l l
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This new installation of instrumentation is not discussed in the Technical Specification, and the Tech Specs do not describe or l discuss mid loop operations. 'Mid loop operations" is entered and l exited from Mode 5, and Mode 6 restraints are not applicable.
l Based upon the above, there is no unreviewed safety question.
Approves'.: 5/18/89 A1/P3.NL7
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[ Page 135 of 227 )
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Unreviewed Safety Question Evaluation #89 088 !
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Subject:
Steam Generator Blowdown Prefilters L
Description:
Use of any mesh size filter element is permitted in the SGBD l 3 prefilter assembly. Also, elimination of a filter element is i allowed if a " dummy" element is used in its place.
f
! Safaty Evaluation:
- 1) Does the subject of this evaluation increase the probability of I occurrence, or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety ;
analysis report? j j
There are no accidents evaluated in the FSAR which require the SG I Blowdown profilters to be operable. Therefore, this change does not increase the probability of occurrence of the consequences of an ,
accident or malfunction of equipment important to safety previously I evaluated in the FSAR.
- 2) Does the subject of this evaluation creats. the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? l l
The SGBD prefilter assembly does not impact the safe operability of l the reactor, nor does it provide a boundary to prevent an uncontrolled release of radioactivity to the environment. ;
Therefore, the change does not create the possibility for an j accident of a different type than any previously evaluated in the ;
FSAR. j
- 3) Dor,s the subject of this evaluation reduce the margin of safety as defined in the basis for any technical spocification?
The SGBD prefilter assembly does not impact the safe operability of '
the reactor, nor does it provide a boundary to prevent an i uncontrolled release of radioactivity to the environment.
Therefore, this change does not reduce the margin of safety as l defined in the basis for any technical specification. ,
i Based upon the above, there is no unreviewed safety questions.
- Approved: 6/20/89 A1/P3.NL7
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Attachment '
i ST HL AE 3260 Fage 136 of 227 !
l
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Unreviewed Safety Question Evaluation w89 089 ,
Subject:
Quality Assurance During the Operational Phase '
Description:
Proposed FSAR changes represent organizational realignments and provide clarifications and terminology changes. >
References to the Quality assurance Program Description and Startup Manager are being deleted due to completion of 1 Construction. Systems turnover is also being deleted due to g completion of this activity. The Startup Manager's !
responsibilities relative to the FSAR have ben assumed by the Plant Manager since S1 PEGS is in the operations phase. )
Safety Evaluation: )
- 1) Does the subject of this evaluation increase the probability of ,
occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety i analysis report? !
The proposed changes do not reduce or change any previous [
commitments relative to the types of activities performed in support of STPEGS during operations. The responsible organizations are bound by approved and implemented programs and procedures which !
assure the safe operation of the plant.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ;
previously in the safety analysis report?
The changes referenced do not create the possibility for an accident or malfunction of a different type. These changes are i organizational / administrative in nature. ,
t
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? q l
The basis for technical specifications would not be changed /affected by these changes to the FSAR.
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Based upon the above, there is no unreviewed safety question.
Approved: 5/25/89 l 1 I
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Attachment ST.HL AE 3260 Page 137 of 227 Unreviewed Safety Question Evaluation w89 090
Subject:
Description of Electrical System in FSAR
Description:
This FSAR change deletes reference to the High Voltage Direct Current (HVDC) facility and to a protective relay for the Main Generator.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The HVDC facility was to have provided a connection to a 400 Kv DC line from the STPEGS switchyard and as such would be a load only to the STPEGS switchyard. It was never considered to be able to qualify as an offsite power source. When proposed, the grid stability analysis was recalculated for the STPEGS to show that the HVDC facility connection would not have a detrimental effect on the previously accomplished analysis. When the HVDC facility was deleted, the load analysis was resubmitted. The load studies reverted back to those previously approved and included in the FSAR.
Relay 50/G1 served as a backup protective relay to protect the main generator prior to its synchronization with the 345 Kv grid. Once the main generator is synchronized, this relay serves no purpose and is not apart of the protective relay scheme used to protect the main !
generator while it is connected to the 345 Kv grid. During the startup phase of testing, the 50/G1 relay was found to be in a
" contact race" with other relaying, causing a main generator trip l l when synchronization was attempted. Review of the problem L determined that this relay was not necessary as long as the main I turbine generator speed was at 1800 RPM when synchronization was j attempted. Operating procedures were changed to ensure the correct i
rotational speed was present, and the relay was deleted.
These changes do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to l safety previously evaluated in the FSAR.
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[ ST ML AE 3260 Page 138 of 227 )
l Unreviewed Safety Question Evaluation w89 090 (Cont'd) j i
- 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated j previously in the safety analysis report? q The HVDC facility was to have been a load to the STPEGS switchyard, and it was never recognized as a qualified source of off site power. l Its deletion has no effect on either the CDC 17 or Station Blackout i analyses. In addition, the HVDC facility had no interface with any i Class 1E electrical systems. Removal of this system will not create an unanalyzed malfunction for the STPEGS switchyard. The 50/G1 i relay that was deleted did not interface with the turbine generator I reactor trip circuitry, nor did its deletion reduce the protection j required for the main generator under operating conditions. The )
relay did not interface with the STPEGS switchyard and did not )
affect the CDC 17 requirements.
l These changes do not create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR.
]
- 3) Does the subject of this evaluation reduce the margin of safety as I defined in the basis for any technical specification? !
1 The subject.s of this evaluation are not discussed in the Technical l Specifications, nor do they provide input to or comprise part of the ]
margin of safety analysis bases which are included in the Technical j Specifications. The margin of safety as defined in the basis for i any technical specification is not reduced, j Based upon the above, there is no unreviewed safety question.
Approved: 6/8/89 9
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Attachment ST.HL. AE- 3260 Page 130 of 227 Ur. reviewed safety Question Evaluation #89 091
Subject:
Plant Communications
Description:
This FSAR change addresses Table Q040.10-1 which lists available communications equipment for areas where it may be necessary to communicate with the Control and Auxiliary Shutdown rooms.
t Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Following these changes, adequate communications will still be available in each of the affected areas. Therefore, the changes do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
I The subject areas have adequate means of primary and backup
! communications systems to provide reliable communication during
' normal / emergency operations which would mitigate the consequences of an event and provide for a safe plant shutdown if required.
Therefore, these changes do not create the possibility for an accident or malfunction of a different type than previously evaluated in the FSAR.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
These changes to the communications system do not reduce the margin of safety as defined in the basis for technical specifications. The plant communicatiens system is not described in the technical specifications. As adequate levels of communication exist in the subject areas, there is no reduction in the margin of safety of the l
plant as defined in the technical specifications. ,
Based upon the above, there is no unreviewed safety question, j Approved: 6/8/89 A1/P3.NL7
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' Page 140 of 227 Unreviewed Safety Question Evaluation #89 092
Subject:
Addition of Common System Alarms to Unit 2 Annunciators and Plant Computer
Description:
System alarms are to be added to the Unit 2 annunotators and plant computer for certain systems common to both units.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
This change will result in an increase in the combustible loading in Fire Area 07, Fire Zone 071 (07Z071). However, the maximum postulated fire (MPF) from the revised combustible loading is 30 minutes. This duration MPF is significantly lower than the fire rating of the 072071 fire barriers (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />). The fire suppresrion and detection measures in 07Z071 are adequate to deal with a fire of this size. This change does not result in an increase in the probability or consequences of an accident.
- 2) Does the subject of this evaluation create tbo p ssibility for an ;
accident or malfunction of a different type ti m any evaluated l previously in the safety analysis report? j 1
The FHAR considers a fire in fire zone 07Z071. The assumption that ]
all power operated equipment (within a zone that contains a fire) is l lost is a bounding assumption for this evaluation. Because of the l FHAR analysis of the effects of a fire in 07Z071, this change does !
not create the possibility of a new accident or malfunction.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification 7 The basis of Technical Specification 3/4.3.3.5 was reviewed as I 07ZO71 includes the Auxiliary Shutdown Pans 1 Room. Redundant j shutdown capability is required in TS 3/4.3.3.5. If a fire occurs I in 072071 and all power operated equipment is lost, redundant shutdown capability exists from the control room. As the MPF due to i this change is mur.h less than the fire barrier rating, the fire will not spread to other zones. Therefore, the bases of TS 3/4.3.3.5 and af other technical specifications is not affected by this change.
Based upon the above, there is no unreviewed safety question.
Approved: 6/5/89 1
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[ ST.HL.AE.3260 !
Page 141 of 227
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Unreviewed Safety Question Evaluation r89 093 l l
Subject:
Addition of Cables and Conduits
Description:
This modification addresses addition of cables and conduits l for the second containment isolation valves to the chilled i water return lines in the component cooling water system from '
the reactor containment fan cooler system. The change results l in increased combustible loading in Fire Zones 012034 and ?
03ZO36. ;
i Safety Evaluation: !
- 1) Does the subject of this evaluation increase the probability of ,
occurrence or the consequences of an accident or malfunction of '
equipment important to safety previously evaluated in the safety !
analysis report?
The additional combustible loading from the subject change has been i determined to have no impact on the fire protection / Appendix R !
, program, nor on the safety of the plant. The change, although ;
l slightly decreasing the plant's safety reargin, is not considered to r I be a problem due to the three hour rating of the barriers, and the i fire detection and suppression capabilitics of the area. In l addition, completo loss of the area has been analyzed for safe i shutdown. Therefore, this change does not increase the probability i l
of occurrence or the consequences of an accident or malfunction of )
equipment important to safety previously evaluated in the safety !
analysis report. ,
1
- 2) Does the subject of this evaluation create the possibility for an i l
j accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The increase in combustible loading in FA12034 and FA3ZO36 is negligible. The fire loading in FA1 and FA3 remain below the three ;
hour rating of the firewalls. Therefore, addition of combustible l loading in FA1ZO34 and FA3ZO36 does not create the possibility for !
l an accident or malfunction of a different type than any evaluated l previously in the safety analysis report. l
- 3) Does the subject of this evaluation reduce the margin of safety as ,
defined in the basis for any technical specification?
Since the increase in combustible loading does not impact any other outside components, nor impact the fire protection systems or program, the change of total allowable combustible loading will not )
reduce the margin of safety as defined in the basis for any technical specification. I l
Based upon the above, there is no unreviewed safety question.
Appreved: 5/25/89 A1/P3.NL7
s Atta;hment
$T.HL.AE.3260 Page 142 of 227 Unreviewed Safety Question Evaluation e89 094
Subject:
Excess Cooldown Protection Components ,
I
Description:
This change addresses delay of removal of the remainder of the Excess Cooldown Prevention logic in Unit 1 from the Solid State Protection System. The delay is from tLe first to the second refueling. This change was fund to constitute an unreviewed safety question. The proposed change has been submitted to the NRC under correspondence dated June 15, 1989 (ST.HL-AE.3048).
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Page 143 of 227 l l
l Unreviewed Safety Questica Evaluation w89 095 )
Subject:
Deletion of Auto. closure Interlock on RHR Suction Valves l i
Description:
This temporary modification will improve RHR train reliability by preventing actuation of the suction valva closure interlock which isolates the RHR train from the RCS. Since this ;
modification will be implemented mid loop and Mode 6, no ;
pressure protection is required and RHR reliability is l required. ;
1 Safety Evaluation: !
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of ;
equipment important to safety previously evaluated in the safety i analysis report? l l
The purpose of the auto closure interlock is to isolate the !
associated RHR train to prevent overpressurization due to operator i error on plant heatup while increasing RCS pressure. Since the j relief. valve in each train has been confirmed to be capable of ;
preventing overpressurization under all credible events, deletion of ;
this interlock will not increase the probability of occurrence or i consequences of an accident.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? j l
Since the FSAR allows removal of the auto. closure interlock "when j the RCS pressure is below a present pressure," this temporary 3 deletion has already been evaluated; therefore, this change does not l create the possibility for an accident or malfunction of a different type than any evaluated previously in the SAR.
- 3) Does the subject of this evt.luation reduce the margin of safety as defined in the basis for any technical specification?
Since deletion of the interlock will ensure that a spurious i actuation does not cause a loss of RHR cooling, it will not reduce i the margin of safety in that respect. The procedural requirement for the operator to isolate the RHR trains per plant operating !
procedure 1 POP 03-ZG-0001 (Plant Heatup) will ensure that the train is isolated from the RCS prior to raising pressure. In addition, !
administrative review of temporary modifications prior to mode change will require this temporary modification to be removed prior to Mode 3 entry.
Based upon the above, there is no unreviewed safety question, j ipproved: 6/13/89 l
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Unreviewed Safety Question Evaluation e89 096 L
Subject:
load Swing Test at 306 Power Plateau Failure to M6at Acceptance ;
l Criteria ,
Description:
The Load Swing Test at 30% Power Pla* eau did not meet all ;
acceptance criteria. Manual intervention was required to !
stabilize turbine output, and to restore Tave to acceptable ;
values.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of j occurrence or the consequences of an accident or malfunction of ;
equipment important to safety previously evaluated in the safety analysis report? :
There is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to ;
safety in that the control and protective systems acted and
- responded as expected. The strict interpretation of the acceptance ,
criteria was not met; however, that was due to system grid frequency 1 variation rather than control system problems. The intervention to i maintain Tave by pulling rods was necessary in response to increased 1 turbine power output (20MW) as a result of the external demand ,
created by the frequency change on the system grid,
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? ;
i Failure to meet the acceptance criteria does not create the ,
possibility for an accident of a different type than any evaluated l previously in the safety analysis report. Control and protection systems reacted as expected for the conditions. There is no possibility for a malfunction of a different type than any evaluated in the safety analysis report because the purpose of the test was met in that the control systems operated correctly. >
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change does not affect the bases or margin of safety of any Technical Specification. Safety systems responded correctly; there was no challenge to the reactor protective system. The rod withdrawal interlock performed correctly at the power level expected, i
Based upon the above, there is no unreviewed safety question.
Approved: 5/26/89 :
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Page 145 of 227 l l
I Unreviewed Safety Question Evaluation w89 097 )
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Subject:
Incorporation of Unit 2 Cycle 1 Safety Analyses into the Unit 1 {
cycle 1 Licensing Bases !
15
Description:
This FSAR change incorporates the Unit 2 safety analysis into I the Unit I design basis. The change describes an increase in ,
the consequences of an accident previously evaluated in the !
safety analysis report. Correspondence addressing this change i was submitted to the NRC by letter dated June 1,1989 I (ST HL AE 3118). NRC acceptance was provided by )
correspondence dated August 22, 1989. ;
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f Unreviewed Safety Question Evaluation #89 098 l
Subject:
Use of Hafnium and Silver Indium Cadmium Design Rod Cluster Control (
Assemblies (RCCAs) ;
Description:
These proposed changes to the Technical Specifications would f allow use of both hafnium and silver indium cadmium design '
RCCAs within the core. A request for approval to include the changes in the Technical Specification was submitted to the :
NRC by letter dated June 1,1989 (ST.HL AE 3102). The Operating License was amended by the NRC by correspf dence v dated July 31, 1989. ,
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Unreviewed Safety Question Evaluation e89 099 i
Subject:
Delete Cycle Specific Parameters from Technical Specifications and l Reference a Core Operating Limits Raport l
Description:
The proposed changes consist of deleting cycle specific parameters from Technical Specifications and referencing a i Core Operating Limits Report. The proposed changes were subuitted to the NRC by correspondence dated June 1,1989 !
(ST.HL AE 3103). The Operating License was amended by the NRC ;
by correspondence t 4ted July 31, 1989, !
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,i AttO1hment ST HL AE 3260 i Page 148 of 227 ;
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Unreviewed Safety Question Evaluation #89 100
Subject:
System Operating Procedures j
Description:
This FSAR change is requested to change the following in FSAR l Section 13.5.5.2: l a) To correct procedure titles in the General, System, and ;
Off normal Procedure sections. l b) To delete the " Pressurizer Pressure and Spray Control System" procedure from the System Operating Procedure l list. l 1
c) To add the " Component Cooling Water System", " Essential i Chilled Water System", "RCB Chilled Water System", and l "F.mergency Diesel Generator" procedures to the System i Operating Procedure list.
I d) To delete the ' Loss of Open Loop Cooling System", " Loss l of Closed Loop Cooling System", " Plant Electrical System -l Off normal", *Cenerator Cooling of Seal Oil Trouble", l and "High Turbine Vibration procedures from the Off. 1 normal Procedure list. I e) To delete the listing of Emergency Operating Procedures (EOPs). ]
I f) To novo the " Loss of Instrument Air", " Loss of Essential q Cooling Water System", " Loss of Component Cooling Water j System", and " Dropped or Damaged Fuel Assembly" i procedures from the E0P to the Off normal Procedure j list. )
g) To change the word " supplementary" to " subsequent" in l the Annunciator Response Procedure section. ;
J Safety Evaluation:
i
- 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of l equipment important to safety previously ev&luated in the safety 1 analysis report? l a) Correcting procedure titles in the General, System, Off normal Operating Procedure sections does not change the operation of l the plant or change the content of approved procedures. '
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Attochment ST HL AE 3260 i Page 149 of 227 l
l a i Unreviewed Safety Question Evaluation w89 100 (Cont'd) !
b) The deletion of the " Pressurizer Pressure and Spray Control ;
System" procedure title does not change the operation of the I plant or the content of approved procedures. The operation of I the pressurizer pressure control system is specified in l approved General Operating and CVCS System Operating l Procedures. l 1
c) The " Component Cooling Water System *, " Essential Chilled Water ]
System", "RCB Chilled Water System", and " Emergency Diesel 4 Generator" System Operating Procedures are safety related and j should be included in this FSAR System Operating Procedure :
list, i d) The "less of Open Loop Cooling System", " Loss of Closed Loop j Cooling System", " Plant Electrien1 System Off normal", !
" Generator Cooling of Seal Oil Trouble", and "High Turbine Vibratioa" procedures are nonsafety related procedures. The operator actions required to respond to each of these plant !
conditions can be adequately covered in an Annunciator j Response Procedure or an Off normal procedure. Deletion of l these procedures from the Off normal procedure list does not remove the requirement to have procedures to cover these plant transients. Each of the above listed plant conditions has at )
leant one plant annunciator that provides a direct indication i of transient initiation. An Annunciator Responso Procedure l will ensure the appropriate operator actions are i proceduralized. I e) The current listing of emerrency operating procedures is j incomplete. STPEGS is a me; er of the Westinghouse Owner's '
Group (WOG) and has committed to implementing the WOG l Emergency Response Guidelines (ERGS). There are approximately 48 procedures in the WOG ERGS that are applicable to STPEGS.
A complete listing of E0Ps in the FSAR is not required because of the commitment to fully implement the WOG ERGS, ;
f) The " Loss of Instrument Air", " Loss of Essential Cooling Water l
System", " Loss of Component Cooling Water System", and
" Dropped or Damaged Fuel Assembly" procedures are not part of f the WOG ERG specified procedures. The above 1,isted plant conditions are considered off normal situations by the definition listed in the FSAR Off normal Procedure section. ,
Specifying that these procedures are off normal pro:edures does not change the currently approved procedures or change the operator actions performed during one of these transients.
g) Changing " supplementary" to " subsequent" provides consistent wording between Off normal and Annunciator Response Procedure actions that are not considered immediate operator actions.
A1/P3.NL7 c
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?
c Unreviewed Safety Question Evaluation #89 100 (Cont'd)
[ 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
(. For the reasons provided in (1), this FSAR change does not create f the possibility for an accident or malfunction of a different type L' than Any evaluated previously in the safety analysis report. ;
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specificatien? -
This FSAR change does not reduce the margin of safety as defined l i, in the basis for any Technical Specifications because changing ,
System, Ge.neral, Off normal, Emergency Operating, and Annunciator !
Response Procedure lists does not change any surveillance :
procedures or surveillance testing requirements, or degrade the operability of any Technical Specification required equipment. ;
5 Based upon the above, there is no unreviewed safety question.
Approved: 6/8/89 [.
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f Attachment l ST HL AE.3260 Page 151 of 227 Unreviewed Safety Question Evalaation w89101
Subject:
Addition of Door in Electrical Auxiliary Building
Description:
A door is to be added to the operations room of the Technical i Support Center.
Safety Evaluation:
1 1) Does the subject of this evaluation increase the probability of f occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
Addition of a non safety, non fire rated door to the operations room of the TSC does not impact any plant system. Addition of the door does not in:rease the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the SAR.
- 2) Does the subject of this evaluation create the poisibility for an accident or malfunction of a different type than any evaluated previously in the safety analyais report?
Addition of a non safety, non fire rated door to the operations room of the TSC does not impact any plant system. Addition of the door does not create the possibility for an accident or i malfunction of a different type than any evaluated previously in l the SAR.
- 3) Does the subject of this evaluation reduce the margin of safety as ;
defined in the basis for any cechnical specification?
The TSC is not described in any Technical Specification. Thus, '
addition of a door to the operations room of the TSC does not reduce the margiu of safety as defined in the basis for any -
Technical Specification. ,
Based upon the above, there is no unreviewed safety question.
Approved: 6/8/89 ,
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ST HL.AE 3260 l Page 152 of 227 l l' '
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j .Unreviewed Safety Question Evaluation e89 103 )
I
Subject:
Revised HVAC Failure Modes and Effects Analyses L !
- i.
Description:
. The FSAR is to be revised to incorporate the FHB and Control :
[ Room HVAC FMEA revised in response to an action item from ]
LER 88 066 addressed in correspondence ST HL AE 2542. This '
change was found to involve an unreviewed safety question, and was submitted to the NRC by correspendence dated July 14, 1989 !
(ST.HL AE 2940).
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ST HL AE 3260 i Page 153 of 227 l
Unreviewed Safety Question Evaluatioa #89 104 l
Subject:
Fire Area Boundary Designation l
Description:
This change to the PSAR clarifies acceptability of a vall [
betwean Fire Area 3, Zone 147, and Fire Area 30, Zone 144, as '
a fire atea boundary. The change addresses a gypsum board !
wall between FA3/2147 and FA30/Z144 which contains a non rated !
gypsum board soffit and a door installation that is not 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated, t Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of f occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety l analysis report? i
+
The total combustible fire loads for FA3/Z147 and FA30/Z144 have i the equivalent fire severities of 15 minutes and 59 minutes, respectively. The gypsum board wall is adequate as a 90 minute ;
fire area boundary capable of withstanding the hazards associated '
with the area. The gypsum board wall's 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> door, and the fire :
detection and suppressing systems installed in these areas are !
adequate t) limit the fire damage to a localized area, and thus !
will prevent propagation of the fire. Therefore, there is no increase in the probability of occurrence or the consequences of .
an accident or malfunction of equipment important to safety l previously evaluated in the safety analysis report, i
- 2) Does the subject of this evaluation create the possibility for an ;
accident or malfunction of a different type than any evaluated i previously in the safety analysis report? ,
The protection required for the fire area boundary is adequate to withstand the hazards associated with the area, and the protection required for circuits in the area from fire in the other area is adequate. The safe shutdown circuits in Fire Area 30 are essentially the same circuits as are routed through Fire Area 3. ,
The fire impact on a safe shutdown in both Fire areas 3 and 30 would be the same as previously analyzed in Appendix R analyses.
Therefore, this change does not create the possibility,for an accident or malfunction which has not been previously analyzed.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Fire Protection Program is not governed by any Technical Specifications.
Based on the above, t.here is no unreviewed safety question.
Approved: 6/13/89 A1/P3.NL7
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Attachment I ST !iL AE-3260 l' Page 154 of 227 i
Unreviewed Safety Question Evaluation w89 107 l l
Subject:
Radiation Monitoring System - Annunciators and Alarms j l
Description:
The description of the Radiation Monitoring Systeia is to be .j l revised to delete the reference to a permanent record. This i eliminates an implied requirement that alarm logs on the RMS I are subject to record retencion requirements and control. 1
)
Safety Evaluation
- i
)
I 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety l I analysis report? ;
Presence or absence of the alarm log has no impact on function of j
- j. the Radiation Monitoring System. The alarm log is an operational I t
convenience to review alarm history. Similar information is '
available in the RMS computer data files. Recording alarm history l does not change the probability of occurrence or the consequences 1 of an accident, nor does it contribute to malfunction of equipment important to safety, j l 2) Does the subject of this evaluation create the pos- Tility for an ,
I accident or malfunction of a different type than arc / evaluated '
previous.ly in the safety analysis report?
l Presence or absence of the alarm log has no effect on the function l of the Radiation Monitoring System, and will not create the -
possibility for an accident or malfunction of a different type '
than any previously evaluated.
Does the subject of this evaluation reduce the margin of safety as 3) defined in the basis for any tec.hnical specification?
The alarm log has no safety function and has no impact on the :
margin of safety afforded by any Technical Specification, nor does ,
it affect the dose rate or concentration of radioactive materials '
released.
~
l 1 i Based upon the above, there is no unreviewed safety question, l-i Approved:
8/1/89 l
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- 1 i
Unreviewed Safety Question Evaluation w89 108 ;
I Subj ect: Test Sequence at 904 Power j 2-
Description:
This change will eliminate the previously required evaluation f
!- and management approval of the 904 power tests prior to .
! increasing reactor power to 1004. Evaluation and management I approval of the 904 power tests will occur after performance i of the 1004 power tests. j Safety Evaluation: I I
- 1) Does the subject of this evaluation increase the probability of 1 occurrence or the consequences of an accident or malfunction of I equipment important to safety previously evaluated in the safety ;
analysis report? i i
The tests previously performed at 904 power will receive the same i evaluation and management approval after performance of the 100% !
power tests. This change complies with NRC Regulatory Guide 1.68 j which requires evaluation and approval of test conditions at a i minimum of plant output of approximately 25%, 50%, and 75% of I rated power. STPEGS initial startup test plateaus are et 30%, !
50%, 75%, and 100% of rated power. This change does not increase l the probability of occurrence of the consequences of an accident i or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an ;
accident or malfunction of a different type than any evaluated i previously in the safety analysis report? ;
i This change to the Initial Test Program does not affect plant equipment or plant operations, and thus does not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
t
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? !
This change to the Initial Test Program does not affect plant aquipment, plant operations, or assueptions'in accident analyses.
Thus, it does not reduce the margin of safety as defined in the l basis for any technical specification, r
Based upon the above, there is no unreviewed safety question.
Approved:
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l, Attachment ST HL AE 3260 Page 156 of 227 Unreviewed Safety Question Evaluation w89109
Subject:
Relocation of Loose Parts Monitoring System Accelerometers on the Reactor Vessel Head
Description:
This modification relocates loose patts monitoring system accelerometers onto the lifting lugs of the reactor vessel head due to lack of an acoustic connection in that region of the reactor vessel.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The vibration and loose perts monitoring system does not interface with any safety related systems, nor does it perform any safety related function. The loose parts monitoring system provides information only to the operators and provides no safety function, etc. Proper operation of this system improves safety in that it allows detection of loose parts in the upper head region.
The accelerometers are being moved from the shroud to the Rx vessel lifting lugs with its conduits attached to the shroud. The connection to the reactor vessel head has been evaluated by Westinghouse and approved. The reactor vessel stress calculations are not affected.
Two new hardline cables added by this modification package are installed in conduit and supported to the reactor vessel head shroud. This shroud is not safety related.
Relocation of the loose parts monitoring system accelerom2ters does not increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report. '
- 2) Doer the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated
- previously in the safety analysis report?
The loose parts monitoring system does noc perform any safety related functions. The system will still operate within the same parameters after this modification as before. There are no ;
changes to the operation or mounting method of this system.
Therefore, relocation of the accelerometers will not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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i Attachment l ST.HL.AE.3260 l Page 157 of 227 l Unreviewed Safety Question Evaluation e89 109 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specification? l l
Relocation of the loose parts monitoring system acceleropoters does !
not reduce the margin of safety as defined within the Technical i Specifications, j
> i Pased upon the above, there is no unreviewed safety question.
Approved: 6/18/89 <
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q Attcchment ST-HL AE.3260 ;
Page 158 of 227 ,
l Unreviewed Safety Question Evaluation #89 110
Subject:
Core Exit Temperature Alarm for Mid. Loop 0;eration I l
Description:
This change adds an alarm in the Main Control Room for a l representative high core exit temperature (CET) in mid loop ,
operation. An existing recorder for CET will be replaced with I one that has an alarm output. The alarm output will be wired ,
to a new alarm window. )
Safety Evaluation: ]
l
- 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety i analysis report? 1 The subject equipment will only be used during reduced reactor inventory conditions. The SAR does not address consequences of i accidents under shutdown conditions. Malfunction of this egoipment I will neither increase the probability of occurrence nor increase the consequences of an accident.
- 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The existing CET recorder, although having no safety function, is seismically and environmentally qualified. The new replacement recorder with alarm output meets the same qualification requirements. This change does not alter the safety function af any i system or equipment. The recorder is for indication purposes only, ;
and cannot contribute directly to an accident or malfunction, i
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
i The new alarm is intended to increase the margin of safety in mid loop operation. Th.ls alarm is not addressed in the Technical Specification.
i Based upon the above, there is no unreviewed safety question.
Approved: 6/8/89 A1/P3.NL7
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- j. Att:chment l UT.HL AE 3260 i Page 159 of 227 l l
I Unreviewed Safety Question Evaluation #89 111 I
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Subject:
Containment Functional Design j Dest /iption: Tablew 6.2.1.2 17 and 2 19 present subcompartment net free volumes, peak pressure differentials, design pressures used j for ctructural designs of the subcompartments, and any !
! resulting margins in the structural design above the load case i containing the aforementioned design pressure condition, i These tables now incorporate the design pressures and margins I available as previously committed, j i
Safety Evaluation: !
I ;
- 1) Does the subject of this evaluation increase the probability of ;
occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety l analysis report? l For the Radioactive Pipe Chase Subcompartment (Table 6.2.1.2 17), '
the peak pressure differential for Node 1 is the same as the design '
pressure. The design of the subcompartment is within the ACI Code allowables described in FSAR Section 3.8.3.5, with no additional 5 margins required, or provided. Since the design is within the l' allowables, there is no increase in the probability of occurrenes or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis i report. ';
i For the RHR 1A Valve Room Subcompartment (Table 6.2.1.2 19), the peak pressure differential for Node 1 is the same as the design ;
pressure. In this case, the quantity of reinforcing steel provided ,
in the structural members is greater than required for the desi 6n pressure (as a result of reinforcing steel selected for other areas being continued through this subcompartment for construction ,
econonics). Consequently, there is a 1914 design margin on this !
particular load case. Since the design is within the allowables, there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to '
safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an :
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Since integrity of the structures, systems, an'd components remains intact, this change does not create the possibility for an accident or malfunction of a different type than previously evaluated in the safety analysis report. See discussion in (1).
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>- , Attachment ST-HL AE 3260' Page 160 of 227 5 kq .
Unreviewed, Safety :)uestion Evaluation #89111 (Cont'd)
- 3) Does tht subject of this evaluation reduce the margin of safety as 9
, defined in the basis for any technical specification? .,
The margin of safety for structural design subcompartments in all 3 Category I structures is not described in the basis of the Technical i Specifications. The integrity of subcompartments is maintained .
because-the. structural design is within the ACI Code.allowables described in FSAP,Section 3.8.3.5 and 3.8.4.5. 'See discussion in (1).
ST-HL AE 3260 ;
Page 161 of 227 L
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r Unreviewed Safety Question Evaluation #89 112 l tp
Subject:
Containment Penetration Conductor Protection
Description:
FSAR Table.8.3 14 lists all circuit breakers which are j required to be OPERABLE. This document change requires that l
'FSAR Table 8.3 14 be revised to be consistent with Technical 1 Specification 3/4.8.4.1, revised Calculations EC5025, Rev. 5 j and EC6025, Rev. 1 and revised Tabulations SE549EL5025, Rev. 5 j and SE542EL6025, Rev. 1. I l
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
a The document revision does not reduce the level of protection for the containment penetration conductors or the protection requirements but only impacts the list of circuit breakers that are providing tha~ protection. Physical changes to the plant, as required by this document change, have been addressed by design change documents. Circuit breakers required to be added to FSAR Table 8.3 14, by this document change, are presently documented by NCR's or are listed in HLP Calculation 87-PH 001 (Electrical ;
Penetration Test Points); therefore, the subject change does not result in any undocumented violation to the Technical Specification or NRC Reg Guide 1.63. Since the proposed change ensures that the containment penetration conductor protection meets the requirements of NRC Reg Guide 1,63, the subject of this evaluation does not increase the probability of occurrence or consequences of an accident or the malfunction of equipment important to safety.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
As stated in the response to Question 1, the document revision impacts the list of circuit breakers that are required to be OPERABLE but does not reduce the level of protection for the containment penetration conductors or impact the protection requirements. Therefore, the existing accident or malfunction evaluations are still valid and malfunctions of a different type have not been identified.
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Page 162 of 227 Unreviewed Safety Question Evaluation #89 112 (Cont'd) 3
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
^
The subject document change does not require a change to the plant
~
Technical Specification. The existing surveillance testing requirementa, described in Technical Specification 3/4.8.4.1, have not been altered and are still applicable to the containment I
penetration conductor circuit breakers. Therefore, the subject document change does not reduce the margin of safety as defined in ,
the Technical Specification.
Based on the above, there is no unreviewed safety question.
Approved: 6/20/89 l
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Attachment ,
ST-HL AE 3260 l Page 163 of 227 ;
i Unreviewed Safety Question Evaluation #89-113
Subject:
Delete Flowpath Through Valve CV 0215 (Emergency Boration Flush Line Isolation Valve)
Description:
'Flowpath through valve CV 0215 is being deleted by cutting and capping lined 2" CV1099UB3, 2" CV1103UB2, 4" CV1099UB3, and 4" ,
'CV1204UB2. Heat tracing on line 2" CV1103UB2 is to be !
abandoned in place.
. Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of .
equipment important to safety previously evaluated in the safety I analysis report?
'This change does not increase the probability or consequences of an
- accident or malfunction of equipment important to safety because:
- 1) the lines being abandoned in place (2" CV1099UB3 und 2" CV1103UB7) serve no safety function; 2) the safety function of the: lines being capped (4" CV1099UB3 and 4" CV1204UB2) at the intersection of the abandoned lines is unchanged; and 3) all lines remain properly supported for seismic considerations. Note that line 2" CV1103UB2 is abandoned in place and will contain no boric acid solution which could crystalize; therefore, heat tracing on this line may be abandoned with no adverse effect on the plant.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change does not create the possibility for'an accident of malfunction of a type different than those previously evaluated for the reasons detailed in (1).
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The margin of safety as defined in the basis for any technical specification is not reduced by this change. Abandonment in place of 2" CV1099UB3 and 2" CV1103UB2 fulfills STPEGS' commitment of eliminate the flowpath through CV-02:5. This was the basis for NRC acceptance of deletion of CV 0215 from the closure verification surveillance requirements of the technical specification.
Based on the above, there is no unreviewed safety question.
Approved: 6/19/89 A1/P3.NL7
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!- ST HL AE 3260 Page 164 of 227 if Unreviewed Safety Question Evaluation #89 114 h Subj ect: Tendon Surveillance
Description:
This proposed Technical Specification change introduces L additional flexibility in the schedules of the post-tensioning system surveillances of the reactor containment building (s).
This change will allow a tolerance cf i 1 year on the ;
F remaining surveillances. A proposed amendmenc to the STPEGS '
!: Technical Specifications was submitted to the NRC by letter dated June 28, 1989 (ST-HL-AE-3132),
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l L Attachment l L' ST.HL AE 3200 L Page 165 of 227 ;
)
, Unreviewed Safety Question Evaluation #89 115 i i
Subject:
Delay in Impleuentation of Common Alarms in the Unit 2 Control Room ;
i
Description:
The lack of annunciator windows in the Unit 2 CR, for ;
critical, shared equipment was classified as a Category B !
Human Engineering Discrepancy (HED). Following an '
implementation study by Bechtel, the CAR Board subsequently approved' installation of duplicate annunciator windows in the Unit 2 CR for critical systems. HED-1099 was included in our October 1988 CRDR submittal (ST HL AE-2793) as a Unit 2
, Commercial Operation commitment.
Safety Evaluation:
i
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of l
-equipment important to safety previously evaluated in the safety analysis report? t The. schedule for implementation of the annunciator windows in Unit 2 for critical, shared systems has no bearing on the probability of occurrence or consequences of an accident. These annunciator l- windows are used to monitor operation of nonsafety-related plant support systems. Neither their presence or absence, nor their operation or failure would initiate an accident. Since these systems and annunciators are nonsafety-related, they are assumed to fail during an accident. Therefore, the consequences of any accident which may occur are unaffected.
1
- 2) Does the subject of this evaluation create the possibility for aa accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Operation of Unit 2 has been evaluated as being safe with or without l annunciator windows for shared systems. The systems affected are nonsafety-related and have been assumed to fail during postulated accidents.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
None of the shared systems perform a safety function, and none of them are addressed in the Technical Specifications.
I Based upon the above,'there is no unreviewed safety question.
l Approved: 6/13/89 A1/P3.NL7
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Attachment ST HL AE 3260 Page 166 of 227 Unreviewed Safety Question Evaluation #89 116
Subject:
Combustible Load Attributable to Electrical Cables
Description:
The Fire Hazards Analysis Report is being revised to clarify
+'u commitments and basis for combustible load attributable to
.? atrical cables.
I;'
Safety Evaluation:
- . 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
A fire hazards analysis has been performed assuming a 40% Iann average cable tray fill value (rather than 40% maximum). There ara no Appendix R or fire protection requirements to keep the tray fill to less than 406. In addition, the FRAR is being made to clarify j that electrical cables in non combustible enclosures are not considered to be sources of fire. The non combustible enclosure design is equivalent to that of the cable conduit which has been previously determined to not contribute to the combustible load of an area. Therefore, these changes do not increase the probability of occurrence or the consequences of an accident or malfunction of i equipment important to safety. J l
l 2) Does the sub ject of this evcluation create the possibility for an l accident or malfunction of a different type than any evaluated )
previously in the safety analysis report? j As discussed above, these changes do not create the possibility for I an accident or malfunction of a different type than any evaluated previously in the safety analysis report. )
1
- 3) Does the subject of this evalua* ton reduce the margin of safety as defined in the basis for any technical specification?
The Fire Protection Program is not governed by any Technical l Specification.
Based upon the above, there is no unreviewed safety question. l Approved: 6/20/89 A1/P3.NL7 1
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!< ST HL AE-3260 t' Page 167 of 227 i Unreviewed Safety Question Evaluation #89-117
Subject:
Request for Approval of ASME Code Case N 460
Description:
ASME Code Case N 460 accepts a reduction in examination coverage of up to 10% on any Class 1 or Class 2 welds due to interference by another component or part geometry.
Safety Evaluation: ]
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunc: ion of a
j equipment important to safety previously evaluated in the safety '
analysis report? !
, 10CFR50.55(a)(g)(5)(iv) and (6)(1) require ASME Section XI i 1
examination limitations (where an examination requirement by the code is determined to be impractical) to be documented in a Relief l Request to be submitted to the NRC for approval. ASME Code Case 1 N-460 allows a reduction in coverage (limitation) of less than 10%
due to interference by anothey component, or part geometry. l Limitations of less than 10% would still be documented on the examination records, but would not be included in a Relief Request. I Use of Code Case N-460 does not revise the scope of welds subject to ISI nor revise the frequency and extent of examination.- Therefore, this Code case has no impact on the ISI weld examinations performed.
- 2) Does the subject of this evaluation create the possibility for an )
accident or malfunction of a different type than any evaluated ,
previously in the safety analysis report? l l
Use of Code Case N-460 will have no impact on the scope, frequency, or extent of ISI weld examinations performed. Therefore, use of Code Case N-460 will not create the possibility for an accident or malfunction of a different type than any evaluated previously in the ,
SAR. I
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Use of Code Case N-460 will have no impa'et on the scope, frequency or extent of ISI weld examinations performed. Therefore, there is no reduction in the margin of safety obtained by performance of the ISI weld examir<ation program in accordance with Technical Specification bases.
Based upon the above there is no unreviewed safety question.
Approved: 6/20/89 A1/P3.NL7
Attachment ST HL AE 3260 :
Page 168 of 227 Unreviewed Safety Question Evaluation #89 118
Subject:
Radiologically Restricted Area Entry
Description:
The entrance to the radiologically restricted area at the MAB
.El. 41' is being changed to expedite personnel ingress and -
egress to the RRA.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
This configuration change does not impact the design basis of the L plant, and does not impact the Appendix R program or the Appendix R/ Appendix A deviations of the RIAR. Based on this i evaluation, this change does not increase the probabilit.y of 1 occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety i analysis report. l
- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated q previously in the safety analysis report? l l
l This configuration change does not impact the design basis of the j l plant and does not impact the Appendix R program or the j Appendix R/ Appendix A deviation of the nlAR. Based on this i evaluation, this change does not create the possibility for an I accident or malfunction of a different type than any evaluated previously in the safety analysis report.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for sny technical specification? !
l This change does not reduce the margin of safety as defined in the basis for any technical specifications since the technical specifications do not address the subject of this ECNP. In addition, there is no impact on any safety related plant syatems or components addressed in the technical specifications since there is no equipment qualification impact or any impact to safety related o equipment due to flooding or Seismic II/I as discussed in the l
response to Questions 1 and 2.
l Based upon the above, there is no unreviewed safety question.
Approved: 6/13/89 l
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Page 169 of 227 Unreviewed' Safety Question Evaluation #89-119 Subj ect: -Access Control to RCB Personnel Air Lock
Description:
This modification adds an access control room and health physics count room and associated equipment to Room 326 of the MAB. It also adds, a new access to the Fuel llandling Building and security barriers to prevent bypassing the access control room.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?,
The changes have been evaluated for seismic qualification, fire hazards, structural loading, flooding, and equipment qualification.
This modification does not increase the probability of occurrence or the consequences of an accident of malfunction of equipment l important to safety previously evaluated in the safety analysis
! report.
NOTE: The. combustible load for the fire zone is increased j substantially, but it does not have an impact on the fire i
protection program or on the Appendix R fire hazard analysis.
l 2) Does the subject of this evaluation create the possibility for an I accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The changes have been evaluated for seismic qualification, fire hazards, structural loading, flooding, and equipment qualification.
This modification does not create the possibility for an accident or .
l malfunction of a different type than any evaluated previously in the I safety analysis report. (Note that the combustible load for the fire' zone is increased substantially, but it does not have an impact on the fire protection program or on the Appendix R fire hazard analysis.)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change does not reduce the margin of safety as defined in the basis for any technical specifications since this change is basically to the arrangement of MAB Room 326. The technical specifications do not address structural or architectural layouts of buildings. No systems are impacted since the revisions to existing items arn equivalent to the previous design.
Based upon the above, there is no unreviewed safety question.
Approved: 6/13/89 A1/P3.NL7
W, 1 Attachment ST HL AE-3260 Page 170 of 227- l l
l s Unreviewed Safety Question Evaluation #89 120 I
Subject:
Reduction of MAB HVAC Main Supply Air
Description:
- This plant modification provides :
- 1) Reduction of MAB main supply air and rebalancing the system;
'2) Deletion of 2" roughing filer in locker room AHV; and
- 3) Addition of blank off plates to MAB main supply air heaters. ;
Safety Evaluation: '
i 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ;
analysis report?.
Main supply air system is nonsafety-related and does not serve any I
safety function. The reductd MAB main supply air meets a11' cooling load, air change, and other design requirements, and therefere has i no effect on any safety or nonsefety systems / equipment. The safety 1 class equipment in the MAB are p ovided with their own safety class supplementary cooling units. All cooling requirements for nonsafety-related equipment are maintained. Therefore, nonsafety equipment utilized in Appendix R is not affected.
l
- 2) 'Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The basic design requirements identified in the system design criteria and FSAR have not changed, with the exception of airflow change [see (1)). This system is not required to operate during any transient or accidents postulated in FSAR Chapters 6 or 15. In addition, this system is not required to operate during a LOOP.
i Therefore, this modification does not create the possibility for an E accident or malfunction of a different type than any evaluated l previously in the safety analysis report.
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,,1 Attachment ST-HL AE 3260 Page 171 of 227 l
l Unreviewed Safety Question Evaluation s89-120 (Cont'd) 3)' Does the subject of this evaluation reduce the margin of safety as .
defined in the basis for any technical specification? l a
The Technical' Specifications have no' requirements for the MAB supply I air system.- This system is nonsafety related and does not provide any safety function, and is not governed by Technical Specification Section 3/4.7 which governs areas served by safety-related HVAC. l Therefore, the margin of safety is not affected by this I modification. ;
1 Based upon the above, there is no unreviewed safety question.. I 1
Approved: 6/20/89 I 1
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r Attachment ST HL AE-3260 t; Page 172 of 227 i
[ Unreviewed Safety Question Evaluation #89 121
Subject:
Plant Response to Load Changes Test
Description:
The acceptance criteria for Initial Startup Test #20, " Plant Response to Load Changes Test" have been revised. Acceptance !
criterion b.4 of the test description was changed to read, "No pressurizer safety valve operation (all test methods) and no pressurizer relief valve operation (test method d.1)". This criterion previously read, "No pressurizer safety or relief valve operation".
As stated in FSAR Section 7.7.1.5, "In the event of a large load reduction, not exceeding the design plant load rejection capability, the pressurizer power-operated relief valves might be actuated for the most adverse conditions, e.g.,-the most negative Doppler coefficient, and the minimum incromental red worth". The conditions of most negative Doppler coefficient 1 and minimum incremental rod worth occur early in cycle life during the startup test program. Since operation of a PORV ;
during a large load reduction test may occur, there should not ;
be an acceptance criterion that PORV operation does not occur.
1 An editorial change was also made, making the load reduction !
annroximatelv 50 percent. The Westinghouse NSSS Startup.
Manual (TGX/THX-3.4.8) states that the power level desired following the load reduction is approximately 50% of full l' power. In addition, there are inaccuracies in the turbine i control system such that an exact 50% load reduction may not '
occur. j b Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety l analysis report?
l The analyses for Loss of External Electrical Load bound this test.
The change to the acceptance criteria reflects the function of the PORV's to relieve RCS pressure during load reductions. This change does not increase the probability of occurrenca or consequences of an accident or malfunction of equipment important to safety.
- 2) Does the subject of this evaluation create the possibility for an accident or inalfunction of a different type than any evaluated previously in the safety analysis report?
The Large Load Reduction Test is a design transient which is bounded by the Loss of External Electrical Load analysis. A loss of external load event results in a NSSS transient that is less severe than a turbine trip event. The Turbine Trip analysis includes scenarios for the pressurizer PORV's being either open or closed.
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Attachment-at .e ST HL AE 3260
, Page 173 of 227 Unreviewed Safety Question Evaluation #89 121 (Cont'd) ;
Deleting the acceptance criterion that the PORV's do not open does '
not create the possibility for an accident or malfunction of a
- j. different type than previously evaluated.
l
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
{
The Bases for Technical Specification 3/4.4.4 state the PORV's and- ,
L steam bubble function to relieve RCS pressure during all design '
l transients up to and including the design step load decrease with ,
L steam dump. Since the PORV's purpose is to relieve pressure during D
a 50% load reduction, deleting "PORV's not opening" from the ,
acceptance criteria for this test does not reduce the margin of L safety in the basis for this Technical Specifi:ation.
l Based upon the above, there is no unreviewed safery question.
Approved: 6/16/89 1
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Attachment ST HL-AE-3260 e
Page 174 of 227 l
)
Unreviewed Safety Question Evaluation #89-122 Subj ect: Evaluation of Pipe Support bescription: On June 16, 1989 following completion of the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />
) warrantee run in Unit 2, a Full Load Rejection (FLR) test was performed. One of the primary functions of this test was to
^ '
satisfy the requirements of the Cteady State Vibration / Transient Load Test, Procedure No. 2 PEP 04 ZG-0010.
To obtain the various data needed to analyze the loads that resulted from the FLR transient, the Main Steam system piping was instrumented, and the data recorded at the Westinghouse Test Analysis Mobil Unit (TAMU) trailer.
The recorded. loads were acceptable for all supports fer all four Main Steam lines, with one exception. One hanger'(No, MS-2001 HL5002) experienced a transient load which exceeded the allowable stress limits (per ASME Section III, Subsection NF) . The hanger is a strut located in the Containment Building at Elev. 68'-0" on the vertical riser of che main j steam line coming off of Steam Generator 2A (See attached ]
sketch). The stress allowable that is applicable is based on l the FLR being considered an Upset Condition. It was also l determined that if the stress allowable for a Faulted j Condition could be used, which equates to twice the allowable 1 limit for an Upset Condition, that the strut would be acceptable, per Code allowable limits, and not subjected to deformation. Per the Design Bese requirements, however, the i FLR is considered as an Upset Condition and was therefore j determined to be a nonconforming condition.
1 Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment ir.portant to safety previously evaluated in the safety ,
analysis report?
When the recorded data from the TAMU was reviewed, it was determined that the stress levels imparted on the piping component nozzles, and
.the pipe supports were within the allowable limits of design, with the exception of hanger HL5002. There were no new stress risers or intI$sification that resulted in a change to the already determined locations that v.sre used in High Energy Line Break Analysis (HELEA).
Parigue limits previously analyzed for the piping and noczles was unaffected due to the type of load that occurred, which,is not a cyclic load--only a high transient load associated with a compression wave generated by rapid c) ,sure of a valve, lasting a fraction of a second. Tne loads evaluated did not exceed the ASME stress limits, with the exesption of hanger HL5002.
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Attachment ST !!L AE 3260 l Page 175 ot 227 i 1
j Unreviewed Safety Question Evaluation #89-122 (Cont'd)
To address the. excessive support load, a calculation was performed I. 'to determine what the consequences would be if the hanger did not l perform as intended. The resulting loada did not exceed the stress limits-in the piping nor in the remainder of the associated suppore.s . Consequently, failure of hanger HL5002 would not create a !
. cascading effect on the balance of the support system. However, the '
hanger is not expected to lose its functionality since the Faulted j
. Condition criteria result in the strut being acceptable as is. Also i note that no damage was identified during visual inspection of the l support (MS 2001-HL5002).
2)' Does the subject of this evaluation create the possibility for an I accident or malfunction of a different type than any evaluated i 2 previously in the safety analysis report? l 1
Although the loads that were identified as a result of the FLR test b j are higher than anticipated, they have not resulted in any new failure modes or break locations. Consequently, it is concluded 1 that the existing analysis of accidents boimd the possible scenarios
)
associated with the current configuration. No functionality or )
operability of the Main Steam system is expected to be lost. ;
l l' 3) Does the subject of this evaluation reduce the margin of safety as ')
. defined in the basis for any technical specification? i J
l' The margin of safety used as a basis for Technical Specifications is j l not affected due to the nature of this deficiency, which does not i L directly affect any of the existing Technical Specifications. While ,
L the stress in the support is more than the originally calculated !
stress values for Upset conditions, the stresses for faulted ,
conditions have remained below code allowables. Thus, no failure or 1 loss of functionality is expected. Therefore, no margin of safety I ss defined in Technical Specifications is compromised.
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Based upon the above, there is no unreviewed safetv question.
Approved: 6/18/89 l
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l,L Attachment ST.HL AE-3260 Page 176 of 227 (1 Unreviewed Gafety Question Evaluation #89-123 4.
Subject:
RCB Electrical Penetration Temporery Modification
Description:
This temporary modification involves replacement of electrical 6 penetration blind flanges with modified blind flanges on the EAB side of the penetration. The modified flange will allow control cables to pass through the penetration with an adequate Hydrosil Seal provided to maintain containment integrity.
Safety Evaluation:
- 1) Does the subjec: of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
She proposed seal design provides adequate sealing capability in ,
modes 5 and 6 for the given plant conditions. Therefore, this does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the PSAR.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The electrical penetration blind flange does not impact safe operability of the reactor and the designed seal will provide an adequate boundary to prevent en uncontrolled release of radioactivity to the environment. Therefore, this item does not create the possibility for an accident of a different type than any previously evaluated in the FSAR.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The electrical penetration blind flenge does not impact the safe l
j operability of the reactor and the designed seal will provide an I adequate boundary to prevent an uncontrolled release of radioactivity to the environment. Therefore, this change does not L reduce the margin of safety as defined in the basis for any i Technical Specification.
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t-Based upon the above, there is no unreviewed safety question.
Approved: 7/17/89 l
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L Page 177 of 227 !
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Unreviewed Safety Question Evaluation #89-124 -
Subject:
Narrow Range Level Instruments for Diesel Generator Puel Oil Storage Tank
Description:
This change adds narrow range level indication and high level ,
alarm functions to Diesel Generator Fuel Oil Storage tanks for i the operator at the fuel oil filtration skid, e
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety i analysis report?
1 The instruments being added in this change are to connect to existing instrument sensing lines. These instruments, as well as l exiscing instruments, serve no safety function. This instruments, I along with their associated hardware, cables, conduits, etc., will .,
be seismically supported per II/I requirements. Therefore, thie .
j L
change will not adversely affect the safety of the plant because the j function of existing equipment and structures, system design, and i operation, are not affected by the change. 1
- 2) Does the subject of this evaluation create the possibility for an !
l accident or malfunction of a different type than any evaluated 1 previously in the safety analysis report?
l l This change does not affect any existing instrumentation functions, l system design, or system operation. Addition of these indicating
- 1. and alarm functions will aid in filling the fuel oil tanks without overflowing them. Therefore, this change does not create any adverse effect on plant safety because the change is not involved in i any plant safety function. l l
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This change adds more accurate indication and alarm functions for diesel generator fuel oil storage tank level. These Instruments will provide a higher confidence level that the fuel oil storage tanks contain a minimum of 60,500 gallons per Section 3.8.1.1 of the plant Technical Specifications. Therefore, this change will not reduce the margin of safety.
Based upon the above, there is no unreviewed safety question.
Approved: 6/27/89 Al/P3.NL7 {
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Page 178 of 227 Unreviewed Safety Question Evaluation #89-125 ,
Subject:
Quality Assurance During the Operations Phase
Description:
The FSAR-is being revised to incorporate the position of Vice President, Nuclear Assurance, and update the FSAR Section 17.2.
-Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The proposed changes do not reduce or change any previous commitments relative to che types of activities performed in support of STPEGS cluring operations. The responsible organizations are bound by approved and implemented programs and procedures which ,
assure the safe operation of the plant.
l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
i These changes are organizational in nature and do not create the 1 j possibility for an accident or malfunction of a different type.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification? )
The basis for Technical Specifications would not changed /affected by I these FSAR changes.
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Based upon the above, there is no unreviewed safety question. !
1 Approved: 6/20/89 l A1/P3.NL7 1'
e Attachment ST HL AE 3260 Page 179 of 27.7 Unreviewed Safety-Question Evaluar. ion #89 126
Subject:
Deletion of Valve from Demineralized Water System Diagram
Description:
Valve XDW 1277 is being deleted from P&lD 6Q210F00066 (Demineralized Water System). The valve is a 1/2" test.
connection that was never installed.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety analysis report?
Absence of the valve will not affect the Demineralized Water System, or any safety related system or component dependent on the DW System for makeup. Sufficient mechanical connections exist to test PC 6456/PV-6456. This valve was to be used for testing; it had no accident / operational function. Therefore, the change does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
]
- 2) Does the subject of this evaluation create the possibility-for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The Demineralized Water System is not safety-related. Lack of this valve in the system does not affect the system function, operation, ,
or maintenance, or create the possibility of a malfunction or l accident not discussed in the FSAR. l l
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Demineralized Water System is not the subject of any Technical !
Specification.
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Based upon the above, there is no unreviewed safety question.
Approved:
8/9/89 l-A1/P3.NL7
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[ Unreviewed Safety Question Evaluation #89-127 k#
Subject:
Containment Penetration Conductor Protection
Description:
This change adds two electrical circuits through the i
containment penetrations for powering new welding receptacles.
This requires that FSAR Table 8.3-14 be revised to include the primary and backup circuit breakers required by NRC Regulatory Guide 1.63.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of
, occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety
' analysis report?
The change to FSAR Table 8.3-14 does not reduce the level of protection for the containment penetration conductors or the protection requirements. Only the list of circuit breakers providing the protection is impacted. Also, only the protection of the containment penetration conductors is affected. The only penetration failure associated with this change'is compromising'of the penetration seals due to a circuit overcurrent condition. Since the proposed change ensures that the containment penetration I, conductors are protected per the requirements of RG 1.63, the l conductors will not be affected by a circuit overcurrent condition.
Therefore, containment integrity has not been compromised by the j added circuits. The change does not increase the probability of ;
occurrence or consequences of an accident or malfunction or j equipment important to safety. l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated l previously in the. safety analysis report?
i L
This change does not reduce the level of protection for the j l containment penetration conductors or impact the protection l requirements. Failure of the containment penetration seals due to 1 an overcurrent condition by the added circuits has been precluded by ensuring that the requirements of RG 1.63 have been met. Since this change has no other impact on the containment penetration conductors, this change does not create any new possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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- b. ST HL AE-3260 ;
l Page 181 of 22.7 j
Unreviewed Safety Question Evaluation #89 127 (Cont'd) .
- 3) Does the' subject of .his evaluation reduce the margin of safety as ,
defined in the basis for any technical specification?
i The change does not require a change to the plant Technical Specifications. The existing surveillance testing requirements (Technical Specification 3/4.8.4.1) have not been altered and are still applicable to the containment penetration conductor circuit breakers. Therefore, this change'does not reduce the margin of
. safety as defined in the Technical Specifications.
Based upon the above, there is no unreviewed safety question.
- i. Approved: 6/27/89 )
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ST HL AE-3260 Page 182 of 227 v l l
Unreviewed Safety Question Evaluation #89 129 i
Subj ect: Relocation of Loose Parts Monitoring System Sensors on the Steam l Generators !
Description:
Relocatien of the Loose Parts Monitoring System (LPMS) .
accelerometers and plug connection boxes, and raceway to l alleviate physical interferences and to reduce ALARA concerns when the main aanway covers are removed from the steam 1 I generators. l I
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of l occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety ,
analysis report?
Relocation of the accelerometers does not increase the probability of occurrence or the consequences of an accident or malfunction of L equipment'important to safety previously evaluated in the Safety l
Analysis Report.
l l The vibration and loose parts conitor is an integrated system for the. detection of loose parts and abnormal vibration in the primary cooling system. Presently, the sensors are mounted to the main access hatches and must be removed to gain access to the internals of the steam generator vessel.
l The acoustical coupling will be increased because the accelerometer will be attached directly to the wall of the vessel, as opposed to the removable hatch cover. The sensitivity of the accelerometer will not be diminished as the proposed mounting location of the relocated sensor is along the same axial line as the existing mounting locations, where loose parts released within the primary loop migrate to an impact with the wall of the vessel.
The Loose Parts Monitoring System provides information only to the operators, and provides no safety function (i.e., trip, etc.).
Proper operation of this part of this system allows only for the detection of loose parts in the lower region of the steam generator.
l
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The relocation of the accelerometers will not create the possibility for an accident or malfunction of a different type than any evaluated previously in the SAR. The LPMS does not perform any safety-related function. The system will operate within the same parameters after the modification as it did prior to the modification. No modifications or changes to the system operation, installation method, or monitoring facilities have been proposed.
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ST.HL AE-3260 L Page 183 of 227 Unreviewed Safety Question Evaluation #89-129 (Cont'd)
- 3) .Does the subject of this evaluation reduce the margin of safety _as defined'in the basic for any technical specification?
The relocation of the LPMS sensors does not reduce the margin of safety as defined in any technical specification.
Each time the steam generator main manway access covers are removed, it is necessary to remove the accelerometers from the covers, as well as the cables and associated raceway between the sensor and the coupling box, subjecting the sensors, cable / raceway to possible damage. Recalibration of the system is required when the' sensor is 1: reinstalled. In addition, the location of the coupling boxes presents an interference to personnel entering the manway of the steem generator vessel after the hatches are removed.
The relocation of the vibration sensors will alleviate the need for I reworking the LPMS at the vessel hatch when access is required,
! resulting in increased reliability of the system, unobstructed access to personnel entering / exiting the vessel, and the savings of manhours which will reduce the person-rem dose and augment the ALARA program. 1 i
1 l Based upon the above, there is no unreviewed safety question.
l l Approved: 6/28/89 l
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.c Attcchment ST-HL AE 3260 Page 184 of 227 Unreviewed Safety Question Evaluation #89-130
Subject:
Change of ECW Train Valve i
Description:
Due to material availability, Modification 86-161 will be revised to show valve EW0133 to be 2" rather than 1 1/2" as shown originally. This change affects FSAR Figure 9.2.1 3.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of
' equipment important to safety previously evaluated in the safety analysis report?
This change does not increase the probability or consequences of an accident. This change increases the size of valve E20133 on tha bearing water supply to the B train ECW pump. This valve is a ball valve not used for throttling. The actual valve body is the same size as the existing body, except that the reducers are added by the valve vendor on the 1 1/2" valve. This change will have no effect on the reliability of the ECW pump or the ECW system.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
This change will have no effect on the supply of water to the ECW pump bearings. The function of the valve and operation of the system are unchanged. The stress margins have been reviewed and ;
found to be acceptable. All analyses are unchanged. l
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The Tech Spec requires all three trains of the ECW system to be operable. Since this change does not impair operation of the system in general, or specifically hinder operation of the pumps, the margin of safety is not reduced. -
1 Based upon the above, there is no unreviewed safety question.
Approved: 6/28/89 l
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I Attachment f ST.HL AE 3260 i Page 185 of 227 i Unreviewed Safety Questiupon Evaluatiupon #89-131 l
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Subj ect: Onsite Power Systems
Description:
Figure 8.3 3 is being revised to incorporate additional drawings,'as well as editorial corrections, t
t Safety.Evaluatiupon; ,
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- 1) -Does the subject of this evaluation increase the probability of occurrence or the consequences.of an accident or malfunction of i i equipment important to safety previously evaluated in the safety analysis report?
1 The editorial changes being made and inclusion of the additional ;
drawings do not reflect any physical change to the facility and do not have any impact on the safety of the plant, the accident 1 analyses, or dose consequences previously documented or submitted to the NRC. 1 1
- 2) Does the subject of this evaluation create the possibility for an i accident or malfunction of a different type than any evaluated i previously in the safety analysis report? !
l The changes to the FSAR are editorial in nature and reflect the as built condition: no physical or procedural changes are required. Previous safety analysis evaluations are not affected; l therefore, this change does not create the possibility for an j accident or malfunction of a different type than any evaluated 1 previously in the safety analysis report.
]
- 3) Does the subject of this evaluation reduce the margin of safety as j defined in the basis for any technical specification? i The drawings used to expand Figure 8.3 3 represent both Class 1E and non-Class 1E and DC control power schemes. (These drawings j are not being revised, and do not represent a change to the STPEGS electrical systems.) There is no reduction in the margin of safety as defined in the basis for any technical specification. ,
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l Based upon the above, there is no unreviewed safety question.
i Approved: 7/11/89 l
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I i Attachment ST.HL AE 3260 )
Page 186 of 227 Unroviewed Safetj Question Evaluation #89 133
Subject:
RHR Pumps' Status Monitoring Revision
Description:
This change deletes the pull-to lock to bypass /inop '
indication for the RHR pumps. ;
i Safety Evaluation: 1 i
'1) Does the subject of this evaluation increase the probability of I occurrence or the consequences of an accident or malfunction of e equipment important to safety previously evaluated in the safety
- l. analysis report?
i The probability of occurrence or consequences of accidents are not I affected by this change because this change does not affect the l operability of the pumps in question. Only the bypass /inop '
! indication is affected by the change to avoid the nuisance alarm when a pump is put into " pull-to lock" procedure. (The RHR pumps do not receive automatic ESFAS start signals and thus are not !
impaired from performing any safety function by being put into I
" pull-to-lock".)
, 2) Does the subject of this evaluation create the possibility for an I
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
This change does not create the possibility for an accident or malfunction of a different type than those previously evaluated since only the bypass /inop indication is affected. The change i
removes nuisance alarms when one of each set of pumps is put into I " pull to lock" per procedure. J L
- 3) Does the subject of this evaluation reduce the margin of safety as l
defined in the basis for any technical specification? ,
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The margin of safety as defined in Technical Specification bases I is not affected by this change because operation / operability of the RHR pumps is not affected by this change.
l Based upon the above, there is no unreviewed safety question. 1 Approved: 7/28/89 i
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5 h 'l Attachment- ,
, ST-HL-AE 3260 Page 187 of 227 Unreviewed Safety Question Evaluation #89 134
Subject:
ECW Corrosion Monitoring System
Description:
This modification adds a side stream corrosion monitoring system to the Essential Cooling Water System t
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of -
- occurrence or the consequences of an accident or malfunction of i
, equipment important to safety previously evaluated in the safety L
analysis report?
This addition of a corrosion monitoring system which includes low pressure, seismically-supported small bore lines to the ECW System '
is bounded.by existing flooding and hazards analyses and combustible loading evaluations. Based on the above, the subject l .of this evaluation does not increase the probability of occurrence i or the consequences of an accident or malfunction of equipment .
important to safety.
l~ The cross tie through the ECW corrosion monitor does not. impact !
I operability of either train. The corrosion monitor is located L downstream of all safety-related heat exchangers served by the ECW L system. Train separation of the ECW system ensures that'a failure
, of one train will not impact operation of the other trains, and ;
adequate cooling will be provided for safety related components.
The cross tie between trains will not impact the capability of the ECW to provide cdequate cooling, as the safety function of the ECW ,
- j. system ic already performed upstream of the corrosion monitor.
Therefore, the criteria defined in 10CFR50, Appendix A, General Design Criteria 44 are met.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated l
previously in the safety analysis report?
As in (1), this change does not modify the system in such a manner as to create the possibility of a malfunction of a different type than any evaluated previously.
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4.:tachmer.t i ST HL.AE 3260 I f Page 188 of 227 Unreviewed Safety Question Evaluation e89 134 (Cont'd) !
)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Presence or absence of a corrosion monitoring system was not i considered as a basis in establishing the ECW Technical Specification requ!rerents. Ad.11 tion of a corrosion monitoring i syst4m to the ECWS dees not change any design or operability basis l used in establishing the ECWS Tech Specs and consequently does not I reduce the margin of safety as defined in the basis of the ECW Technical Specifications.
Based upon the above, there is no unreviewed safety question, j l
Approved: 7/25/89 !
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Attcchment ST HL AE 3260 Page 189 of 227
- Unreviewe d Safety Question Evaluation sL9 135 1
Subj ect: Changes to Program for Control of Heavy Loads i
Description:
These changes affect the response to NRC Ceneric letter 81 07, ' Control of Heavy Loads. ' The changes address:
i t
a) Additional cases of bypassing the polar crane ;
interlock. I i
b) Modification of inspection requirements of the Reactor !
Vessel Head and Internals Lift Rigs, c) Heavy loads requirements do not apply in the Reactor l Containment Building when there is no fuel present in l that building, j d) New load path for the Reactor Vessel Internals Lift Rig, e) New load path for the Reactor Vessel Irradiation i Surveillance Capsule Shipping Cask j l
l f) Adding and changirg weights of RCB Polar Crane and THB j Overhead Crane Loads, and claried safe load paths.
g) Adding new load paths for the RHR Heat Exchanger ;
hatches.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of :
occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety i analysis report? !
None of the thanges identified increase the probability of ;
occurrence or consequcnces of an accident or malfunction of ;
equipment. l l
Does the subject of this evaluation create the possibility for an 2)
I accident or malfunction of a different type than any evaluated :
previously in the safety analysis report?
l l The types of accidents or malfunctions are unchanged. None of the j changes described affect anything other than a postulated load drop accident. {
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i Attachment l ST.HL.AE.3260 Page 190 of 227 Unreviewed Safety Question Evaluation e89 135 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basin for any technical specification?
' Tech Spec 3/4.9.7 requires that loads in excess of 2500 pounds be excluded f;oa travel over fuel assemblies in the Spent Puel Pool g, except when being carried by the single. failure proof 15 ton hoist of the FHB Overhead crane. These conditions are not changed. No ocher technical specifications ara affected. The margin of safety is not affected.
- Based on the above, there is no unreviewed safety question.
Approved: 8/11/89 t
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i Attcchment i ST.HL.AE.3260 >
Pagt 191 of 227 1
Unreviewed Safety Question Evaluation w89 138- i i
Subject:
Temporary Modification: MAB Centrifugal Charging Pump ;
Supplementary Cooler Air Supply ,
l
Description:
This temporary modification covers removal of the fan and motor for MAB Centrifugal Charging Pump Supplementary Cooler i Supply Fan, and installation of a cover plate of sheet metal ,
at the fan discharge screen to restrict back flow of air to l the remaining fan. :
1 Safety Evaluation:
1
- 1) Does the subject of this evaluation increase the probability of !
occurrence or the consequences of an accident or malfunction of j equipment important to safety previously evaluated in the safety '
analysis report?
The CCP remains completely operational under the single fan ;
operation of the Roota 041 supplemental cooler. Normal and accident environments within the qualified envelope are .
maintr.ined. Thero is no increase in probability of damage due to !'
a seismic event. Possibility for inadvertent energizing or shorting oc existing cables that would normally supply the fan has been precluded. Thus, the probability of occurrence or :
consequences of an accident or malfunction are not increased by [
removal of the failed fan. !
I
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
i Design temperature is maintained in the Charging Pump Cubicle j (Room 041) and, per the JCO, previously analyzed HE!aA and FHAR ,
l analyses are unaffected. Removal of the failed fan and addition >
l of the cover plate do not create the possibility for accidents or malfunctions not previously analyzed, as the equipment in the room :
will continue to function within its design temperature !
environment, ,
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ST.HL.AE 3260 .
Page 192 of 227 )
i Unreviewed Safety Question Evaluation e89 138 (Coat'd)
- 3) Does the subject of this evaluation reduce the matgin of safety as -
defined in the basis for any technical specification? l 1
> The total cooling load requirements have been found to be very ;
I conse rvative. The temperature of the charging pump cubicle will ;
be below the maximum allowable temperature.
! Therefore, there is no reduction in margin of safety as defined in the basis for any Technical Specification. !
1 I I i
Based upon the al ove, there is no unreviewed safety question. I l
Approved: 7/16/89 ]
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W Attachment ST.HL.AE.3260 Page 193 of 227
- p Unreviewed Safety Question Evaluation w89 139 l
l
Subject:
Damage to Main Step.Up Transformer 2A
Description:
Unit operation with only one of two main step.up transformers has been evaluated. This evaluation applies to both Units 1 and 2.
Safety Evaluation:
I
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
This mode of operation does not increase the probability of occurrence of an accident or malfunction of equipment important to safety for the following reasons:
- a. The affected equipment is nonsafety related and hence not required for safe shutdown of the plant.
i
- b. Protective relaying utilized for full power operation with both main transformer windings will be utilized for 50%
power operation with one main transformer winding. With the revised relaying setpoints for temporary operation with the one main transformer winding, the full complement of generator protection will stil). be provided without L compromise.
- c. Administrative controls for calibration of protective relaying setpoints are not affected, as the same approved I plant procedures will be used for calibration in either l operational condition.
- d. The two main transformer windings operate in parallel.
Hence, any postula.ad accideac involving both windings will also be applicable for a single winding. It is not possible to have any accident affecting one winding without affecting the other winding; e.g., a fault on winding will be seen by the other winding, with the same resultant generator / turbine / reactor trip.
1 I
- e. Operation of safety related equipment will continue as presently described in the safety analysis report,
- f. Long tarm operation at reduced power due to the loss of one main transformer has been reviewed from a fluid systems standpoint. Components and systems are designed for continuous operation at any power level.
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i l Attachment l- ST HL AE 3260 l l page 194 of 227 j 1
Unreviewed Safety Question Evaluation e89 139 (Cont'd) ,
l
- 2) Does the subject of this evaluation create the possibility for an l' accident or malfunction of a diffeient type than any evaluated :
previously in the safety analysis report?
t The mode of operation with one main transformer winding does not I create the possibility of an accident or malfunction of a l
different type than previously analyzed for the following reasons:
- a. As described in (1) above, items d, & e., the two main )
transformer windings operate in parallel. Accident e.nalyses l were performed considering both windings, including i synergistic ef fects between the two windings. Therefore, j operation 90 h a single winding will be bounded by present !
accident evc'tuations and hence those evaluations are still l valid,
- b. Disconnection of one main transformer winding will result in !
a change in the impedance seen by the generator. This !
change will have no impact on voltage regulation and voltage drop on the plant electrical power systems, since come of these systems are fed by the unit auxiliary transformer !
which has an automatic on load tap changer and the remainder ;
are fed by the standby transformers, which are directly )
connected to the switchyard busses, which are not affected j by the main transformer windings. i
, c. All damaged winding electrical connections (Unit 2 only) i
! (isophase bus, 480 VAC control, etc.) will be determinated I and/or dcenergired and physically protected in accordance with approved plant specifications and procedures. The :
operation of existing protective electrical devices for the {
l- determinated connections will not be affected by the subject ;
determinstions, j l
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1 Attachment l ST HL AE 3260 Page 195 of 227 i I
Unreviewed Safety Question Evaluation e89139 (Cont'd) ,
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- 3) Does the subject of this evaluatior reducs the margin of safety as l definod in the basis for any technical specification? l Electrical equipment and loads addressed by the plant Technical ,
specifications are normally powered by transformers. Operation of j the pain transformer winding is not described in the Technical i specifications, an the proposed operational mode does not impact ;
the operation of any other systems as described in the Technical l Specifications. Therefore, operation with one main transformer l winding at a reduced power level does not reduce any acrgin of l safety as described in the Technical Specifications, i i
Based upon the above, there is no unreviewed safety question.
Approved: 7/16/89 l !
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f ST.HL. AE. 3260 l Page 196 of 227 !
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[ 11nreviewed Safety Question Evaluation w89144 j L
Subj ect: RCFC Fan Motor Qualification
Description:
TSAR CN #1298 contadns revisions to the IEEE Standard dates used in the qualification of RCFC fan motors. Specifically, l
! IEEE 334 19;1 was revised to IEEE 334 1974, and IEEE l 344 1971 as supplemented by NRC Branch Technical Position !
ICSB.10 was revised to IEFI 344 1975.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability ol' l occurrence or the consequences of an accident or ra.ifunction of equipment important to safety previously evaluated in the safety !
analysis report? )
i The equipment qualification of the RCFC fan motor was performed in i accordance with the later editions of these IEEE Standard as l presented in the equipment specification 2V211VS0001. The subject revisions to the FSAR reflect the design and qualification ;
i_ requirements for the RCFC fan motors which were performed in l l accordance with the environmental and seismic qualification i programs on STP. l Note that prior to issue of IEEE 344 1975, the equivalent requirements of this standard were dictated by IEEE 344 1971 as
, supplemented by NRC Branch Technical Position ICSB 10. Therefore, this revision to the FSAR does not indicate the use of more recent l , ', criteria, but rather presents the requirements with the single '
l- updated reference.
/> Reference to the more recent IEEE Standards indicated above
(- reflects the overall requirements of the equipment qualification This revision to the FSAR does not in prograra employed on STP.
any way impact the performance of the RCFC fan motors, but rather correctly states how this equipment was qualified (environmentally and seismically) to perform its safety related function. i Therefore, the corrected IEEE Standards in the FSAR would not I increase the probabiljty of equipment malfunction previously evaluated in the safety analyais report. ,
- 2) Does the subject of this evaluation create the possibility for an l accident or malfunction of a different type than any evaluated ,
previously in the safety analysis report?
As described in (1), this change does not create the possibility ,
for an accident of malfunctior, of a different type than any evaluated previously in the safety analysis report.
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- Page 197 of 227 ;
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L Unreviewed Safety Question Evaluation W89 144 (Cont'd) i
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- 3) Does the subject of this evaluation reduce the margin of safety as i defined in the basis for any technical specification? i Tho margin of safety for the associated RCFC Technical -
Specification 3/4,6.2.3, containment Cooling Systems, is not i reduced by this proper reflection of the qualification '
requirements of the RCFCs, ,
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Based upon tho above, there is no unreviewed safety question.
Approved: 8/1/89 l A
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Attothment ST l!L.AE.3260 Page 198 of 227 Unreviewed Safety Question Evaluation e89-145
Subject:
Shielding Source Terms
Description:
This FSAR change is to establish consistency between FSAR Section 12.2 and other references. The subject cf this change is primarily shielding source tera information.
' Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The source terms described in Section 12.2 are not used for accident evaluations, only shielding to support power generation.
The changes represent reductions (based on normal operation,
+- including anticipated operational occurrences), corrections and for consistency with the Westinghouse Project Information Package (PIP). The changes do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated :
previously in the safety analysis report?
l The subject of this evaluation is not concerned with safety design bases or plant procedures, nor is it concerned with any accidents or malfunctions that would inpact the health and safety of the ,
public. l
- 3) Does the subject of this es aluation reduce the margir. of safety as :
defined in the basis for any technical specification?
The subject of the evaluation is not involved in the bases of any Techniccl Specifications. The mergin of cafety is not affected.
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' Based upon the above, there is no unreviewed safety question.
Approved: 8/1/89
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l Attachment i ST HL.AE 3260 i Page 199 of 227 1 Unreviewed Safety Question Evaluation #89 146 l
Subject:
Occupational Doses from Airborne Activity l
Description:
The calculation was revised to incorporate a changed plant I operating organization (manning levels). The number of people, the job assignments, and titles changed for some eperating pinnt departments. This calculation addresses !
radiation dose accumulated by operators and workers as a l result of normal operation and usintenance. The calculation j considers radiation dose from normal expected airborne I radioactivity levels. !
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of -
equipment important to safety previously evaluated in the safety analysis report?
The subject of the calculation does not impinge upon the functioning of equipment important to safety nor increase the probability of occurrence or consequences of an accident. Ic is not associated with nor does it impact accident dose analyses.
Dose estimates are based on subjective estimates of time spent in ;
the course of carrying out the duties of the operators in their .
various assignments. The guidelines for performing these
- estimates are unspecific, allowing for a wide range in the ortcome i for any specific job assignment. As indicated in Reg. Guide 8.19, ,
the dose assessments performed in accordance with the guide ,
"are. . .not for NRC regulatory enforcement purposes". The purpose of the dose estimate is to ensure that adequate attention is given j during the pSAR design stage as well as construction (FSAR stage) l to tnaintain personnel exposures ALARA. ;
In addition, per NSAC 125, Section 3.6, the consequences referred i to in 10CFR50.59 do not apply to occupational exposure resulting
( from other than accidents and equipment malfunctions, e.g., from routine operations, maintenance and testing.
m
- 2) Does the subject of this evaluation create the possibility for an '
accident or malfunction of a dif ferent type than any evaluated previously in the safety analysis report?
The subject of this evaluation is not concerned with equipment important to safety or plant proceduros, and is not concerned with any accidents or malfunctions which could impact the health and safety of the public.
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Attachoent !
ST HL AE.3260 i Page 200 o; 227 i Unrevicwed Safety Question Evaluation eP9140 (Cont'd)
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- 3) Does the subject of this evaluation reduce the margin of safety as !
defined in the basis for any technical specification? !
The aubject of the evaluation is not involved in the bases of any Technical Specifications. Specification 3/4.11.2 limits gaseous i effluents and 3/4.11.4 limits total dose to the public as a result j of plant operation. Neither of these are affected by the change. '
Section 6, Administrative Controls, is also not affected.
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Based upon the above, there is no unreviewed safety question, j 1
Approved: 8/6/89 ]
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[- Attachment ST HL.AE 3260 Page 201 of 227 Unreviewed Sofety Question Evaluai: ion w89147
Subject:
Main Cooling Reservoir - FSAR Update
Description:
The FSAR is being revised to include:
- 1) 1985 Liquification Potential of Embankment Foundation;
- 2) Reference to MCR monitoring program and deletion of construction phase detailed locations; and
.) Status update of MCR.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated ir,the safety analysis report?
l The liquification potential analysis performed in 1985 (Ref.
' S.6 20) and included in the proposed Section 2.3.6.5.1.6.3 ,
combines two analyses which were performed and previously presented '
to the NRC. The first analysis was presented to the NRC at a meeting between the NRC and H1AP at Bethesda, Maryland on April 2, 1985. A supplementary analysis was recommended at that nieeting and the results of this analysis were presented to the NRC by letter ST.HL AE 1293, dated July 1,1985. The final report (Ref. 2.5.6 20) ;
combines theso two analyses and the prcposed Table 2.5.6 10 l l summarized the pertinent factors of safety which are the same or
' higher than those presented in the first two analyses. For these [
reasons, there is no increase in the probability of occurrence or in i the consequences of an accident or as1 function of equipment '
L important to the safety analysis as a result of +.he proposed ;
changes. ;
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l Deletion of Figure Nos. 2.5.6 16, 2.5.6 17A, 2.5.6-17B, 2.5.6 18 and ;
l 2.5.6 19 rerove from the FSAR details of the geotechnical !
I instrumentation which had been installed around the MCR during the '
early period of construction. Inserts "G" (Section 2.5.6.6.1.3) and i l "I" (Section 2.5.6.8.1.1) to the FSAR chango refer to Specificatian i 9Y510YS1004, " Specification for Geotechnical Monitoring and !'
l Inspection of Main Cooling P.eservoir" (Ref. 2.5.6 21) which l incorporates updated details and locatians of the original and supplementary instrumentation. In Appendix J of tha SER, the NRC acknowledges that an inspection and monitoring program is being l' implemented daring and after staged filling of the MCR and that L remedial measures or maintenance of the facility will be implemented l l where required. The NP.C also refers to Ref.2.5.6-21 as the document l which describes and locates instrumentation installed around the '
MCR.
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Attechment i ST.HL AE 3260 i Page 202 of 227' ;
Unreviewed Safety Qeestion Evaluaticin w89147 (Cont'd) j Insert "J" (Section 2.5.6.11) to the FSAR change so refers to the i supplementary instrumentation and briefly describes modifications ,
which have been made to the various c.hannels, ditches and sloughs i around the NCR as a result of the monitoring and observations mado ,
during the staged fillit.g. For these reasons, there is no increase {
in tha probabilicy of occurrence or in the consequences of an !
accident or malfunction of equipment important to safety previously i evaluated in the safety analysis report as a result of the proposed changes. ;
- 2) Does the subject of this evaluation create the potsibility for an ,
accident or malfunction of s different type than any evaluated previously Jn the safety analysis report? ,
As described in the bases for the response to question 1), the fina' report on the liquification potential analysis performed in 1985 ,
(Ref. 2.5.6 20) suncarized the previous two analyssa which nad been presented to the NRC. The results from the final analysis, i presented in proposed Table 2.5.6 10, indicate factors of safety equal to, or higher than, thosc presented in the previous two :
analyses. For this reason, this change does not create the possibility for an accident or malfunction of a different type than ;
any evaluated previously in the safety analysis report. l Deletion of Figure Nos. 2.5.6 16, 2.5.6 17A, 2.5.6 17B, 2.5.6 18 and 2.5.619 which removo from the FSAR details of instrumentation previously installed around the MCR, and the addition of Inserts "G" (Section 2.5.6.6.1.3) and "I" (Section 2.5.6.8.1.1) tc the FSAR ,
change which refer to the Specification 9Y510YS1004 as the new !
source of details of the instrumentation previously and presently installed around the MCR, provide more complete and up to date ,
information on the instrumentation installed around the reservoir.
The addition of Insert "J" (Section 2.5.6.11) to the FSAR chan , [
also refers to the supplementary instrumentation and briefly describes the modifica;1ons to di hes, 91oughs and channels around the NCR as a result of observations made during staged filling of the NCR. The NRC acknowled,ed 2 in Appendix J of the SER that such l
inspections and monitoring are performed during staged filling of
, the MCR and that remedial measures and maintenance will be l implemented when required; therefore, this does not create the >
possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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Page 203 of 2.17 Unreviewed Safety Question Evaluation #99 147 (Cont'd)
- 3) Does the subject of this evaluation reducw the margin of safety as i defined in the basis for any technical specifir.ation? j As described in bases for the responses to questions 1) and 2), the results presented in the final report on the liquification analysis ;
performed in 1:B5 indicate factors of safety equal to, or higher than, those presented in the first two analyses. For this reason, this evaluation does not rsduce the margin of safety as defined in :
the basis for eny Technical Specification, j Relocation of the source of information on MCR instrumentation from ;
the FSAR (deletion of Figures 2.5.6 16, 2.5.6 17A, 2.5.6 17B, 2.5.6- !
18 and 2.5.6 19) to the Specification 9Y510YS1004 (inserts "G". !
Section 2.5.6.6.1.3 and "I", Section 2.5.6.8.1.1) does not reduce j the margin of safety as defined in the basis for any Ttchnical ,
Tvecification. This also applies to the brief descriptinn of the
-amedial measures installed in channels, ditches and sloughs as a result of observations made during stages reservoir filling (Insert l "J ", Section 2. 5.6.11) .
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1 Based upon the above, there is no unreviewed safety question.
Approved: 0/1/89
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i Attachment j ST HL AE-3260 1 Page 204 of 227 Unreviewed Safety Question Evaluation #89 148 l
Subject:
Category I Backfill Program
Description:
The Category I backfill program as described in FSAR Section 2.5.4.5.63 has been completed, and the updated tonnage of structural backf!.11 delivered to STPEGS is provided. The !
revised tonnage is provided for information only and does not l affect the safety related activity of placing and compacting this material. l i
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of i occurrance or the consequences of an accident or malfunction of l equipment important to safety previously evaluated in the safety j analysis report? l l
Evaluation, verification, end documentatica of the Category I l structural backfill program have been completed in accordance with ;
previously identified procedures dercribed in FSAR Sections J 2.5.4.5.6.2.2 through 2.5.4.5.6.2.5. Although these changes involve i a change to the facility as described in the SAR, they do not ;
increase the probability of occurrence or the consequences of an i accident or malfunction of equipment important to safety previously i evalusted in the safety analysis report.
- 2) Does the subject of this evaluation create the possibility for an ,
J accident or malfunction of a different type than any evaluated prevb usly in the safety analysis report? i These changes provide updated information which does not change the i l safety aspect of the backfill progran and therefore, does not create i the possibility for in accident or malfunction of a different type than any evaluated previously in the safety analysis report.
1 i
- 3) Does the subject of this evaluation reduce the margin of safety as I
defined in the baats for any technical speciff. cation?
Pasults of the Category I structural backfill program have been verified, evaluated, and documented, and have been found to meet the requirements of the appropriate specifications. The updated tonnage l
of Category I backfill delivered to the STPEUS site is for
! .cfarmation only, and does not affect the results of the l si sty relsted program. Therefore, this chrnge does not reduce the l- margin of safety as defined '.n the basis for any Technical Specification.
Based upon the above, there is no unreviewed safety question.
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Attachment ST HL AE 3260 7
Page 205 of 227 nistuved: 8/1/89 Unreviewed Safety Question Evaluation w89 149
Subject:
Reactor Makeup Water System Diaphragm
Description:
Use of a polyvinyl chloride diaphragm in the Unit 2 Reactor Makeup Water System (RNWS) (e.g. Reactor Makeup Water Storage Tank (RNWST)) will eliminate the current concern of leaking fluorides being experienced with the Unit I rubber diaphragm.
Gafety Evaluation:
- ) Does the subject of this evaluation increase the probability of occurrence or the ccnsequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The RNWS/RKWST are not used in the evaluation of any design basis accidents or transients. A single faU,ure of the RNWS or the RMVST is not considered in any failure modes and effects analyses.
The function of the diaphragm, to prevent absorption of air which would reise the dissolved oxygen content above the alloweble for use as reactor makeup water, will be maintained by the polyvinyl diaphragm. In addition, the water chemistry specifications will not bo digraded (i.e., no presence cf a high fluoride content). ;
Finally, the design of the polyvinyl chloride diaphragm is compatible with the required chemistry specifications and will not introduce any adverse ccrrosion products to violate the design chemistry specifications. ,
i The polyvinyl diaphragm function and design objectives are '
equivalent to that of the rubber diaphragm (with the exception of :
adverse effects on the water chemistry requirements). There is no increase in the probability of occurrence or the consequences of an accident or equipment malfunction as a result of this waterial change. *
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report? t As deficribed in (1), use of a new material for the diaphragm will not introduce the possibility for a new accident or equipment malfunction.
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! ST HL.AE-3260 Page 206 of 227 Unreviewed Safety Question Evaluation *89149 (Cont'd) n
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
Technical Spe:ifications 3/4.1.2, Reactivity Control Systems Boration Systems; 3/4.4, Reactor Coolant System; and 3/4,7, Plant Systems were reviewed for potential impact as a result of the diaphragm material change. The RNWS, RNWST and any os choir componenes are not addressed in the Technical Specifications or in the basis for any Technical Specification. Therefore, this material change will have no impact on the margin of safety.
t Based upon the above, there is no unreviewed safety question. !
Approved: 8/1/80 l
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tr-Attachment ST HL AE-3260 Page 207 of 227 Unrevtewed Safety Question tvaluation w89 150
Subject:
Domineralizer Building Lab Area Air Conditioning Capacity
Description:
The FSAR Table 9.4 2.7 is being revised to be consistent with the as built condition of demineralizer building lab area air conditioning unit. 1his is a consistency change, and no physical change is involved. The equipment is nonsafety related.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
The FSAR change will not change the probability of any accident or malfunction, since the component failura does not result in any initiating events with respect to a safety related system er structure. The demineralizer building lab area air conditioning (A/C) unit does not interface with a safety related system or struerure.
- 2) Does the subject or' this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
As discussed in (1) above, this component does not provide any initiating events. The demineralizer building A/C t. nit is not listed in the FMEA of FSAR Table 9.4-5.7. The change in cooling rate will not affact any safety function. There is no change in heat load to any safety related HVAC cystem. Therefore, this change does not create the possil'.lity for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
l 3' Does the subject of this evaluation redu:e the margin of safety as defined in the basis for any technical specification?
This item is not discussed in the basis o*l any Technical Specification in Tet t.nical Specification Section 3/4.7. This change does not reduce the margin of safety as defined in the basis of any L
Technical Specification.
l Based upon the above, there is no unreviewed safety question.
Approved: 8/1/89 A1/P4.NL7
Attachment ST.HL AE 3260 Page 208 of 227 Unreviewed Safety Question Evaluation W891$1
Subject:
Control Room Toilet Exhaust Fan
Description:
The FSAR Table 9.4 2.1 and FSAR Section 9.4.1.2.1 are being revised to be consistent with the as built condition of the e,ontrol room roilet exhaust fan. This is a consistency change, no physical change is involved. The control room toilet exhaust fan is nonsafety related equipment.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evalusted in the safety analysis report?
The FSAR change will not change the probability of any accident or malfunction, since the failure of the component does not result in any initiating events. The control room toilet exhaust fan operates only during normal operation and is automatically isolated during plant emergency operations. The fan does not perform any safety-related function with regard to control room habitability.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated !
previously in the safety analysis report?
As discussed in (1) above, this fan does not provide an initiating i event. The EAB FMEA evaluated the fan and found that failure of the fan had no effect on system safety function capability because safety related dampars isolate the fans under accident conditions. I Therefore, this change does not create the possibility for an ;
accident or malfunction r,f a different type than any evaluated previously in the safety analysis report, t
- 3) Does the subject of this evaluation reduce the margin of safety as ;
defined in the basis for any technical specification?
As discussed in (1) above, this fan does not provide any i safety-ralated functions with regard to control room habitability.
This item is not discussed in any Technical Specification in Technical Specification Section 3/4.7; therefore, this change does not reduce the margin of safety as defined in the basis of any Technical Specification.
Based upon the above, there is no unraviewed safety question.
Approved: 8/1/89 Al/P4.NL7
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i Attachment l ST HL AE.3260 Page 209 of 227 l t
Unreviewed Safety Question Evaluation #39 154 ]
Subject:
Reactor Coolant System Description
Description:
FSAR Table 5.1 1 is to be revised to reflect:
- 1) a decrease in RCS volume;
- 2) an increase in thermal design flow; and l
- 3) elimination of three loop power operations, i These changes are being made as part of the design ,
finalization at the plant. The changes have already been ;
incorporated i$.co Technical Specification Section 3.2.5, :
3.4.1.1, and 5.4.2. In addition, the changes are addressed in 1 FSAR Chapter 15 safety analyses. ,
i Safety Evaluation: l
! 1) Does the subject of this evaluation increase the probability of i occurrence or the consequences of an accident or malfunction of j equipment important to safety previously evaluated in the safety analysis report? :
1 The proposed change reflects the design finalization of the plant. ;
The change does not change any plant equipment or procedures. !
Existing safety analyses are not affected by these changes. ;
Therefore, these changes do not increase the probability of an accident or malfunction of equipment important to safety. Since the ,
l Chapter 15 analyses are not impacted, the consequences of an ,
accident (dose release) are not increased. '
l l 2) Does the subject of this evaluation create the possibility for an !
accident or malfunction of a different type than any evaluated previously in the safety analysis report?
1 Since the change is bounded by existing analyses in the safety ,
analysis report, it does not create the possibility of an accident t or malfunction of a different type than any evaluated previously in
- the safety analysis,
- l. 3) Does the subject of this evaluation reduce the margin of safety as i defined in the basis for any technical specification? l l
l Since the Chapter 15 analyses are not impacted by the change, tho ,
l' margin of safety is . r reduced.
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Based upon the above, there is no unreviewed safety question.
l l Approved: 8/1/89 l
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Page 210 of 227 l l
Unreviewed Safety Question Evaluation #89 155 l
Subject:
Auxiliary Feedwater System I
Description:
This change corrects a denfting error to show steam trap drain valve as 'normally closed" on FSAR Fig. 10.4.9 1., ;
Safety Evaluation: 1 1
- 1) Does the subject of this evaluation increase the probability of i o:currence or the consequences of an accident or malfunction of !
equipment thiportant to safety previourly evaluated in the safety !
analysis report? l Chapter 15 does not analyze accidents or malfunctions of steam trap i drains. The valve in question is nonsafety-related, and is not required for safe shutdown of the plant. Physical changes are not ;
involved. Therefore, the change does not increase the probability of occurrence or consequences of an accident previously analyzed.
- 2) Does the subject of this evaluation e.reate the possibility for an accident or malfunction of a different type than any evaluated ,
previously in the safety analysis report? 1 The steam trap drain valve does not serve a safety function nor any l equipment with a function important to safety. Therefore, it does ;
not create the possibility for an accident or malfunction of a different type than any previously analyzed. ;
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The subject of this evaluation is not considered in any technical !
specification nor does it involve the 'aases for any technical i specification. Therefore, the n.argin of safety is not reduced.
Based upon the above, there is no unreviewed safety question.
Approved: 8/18/89 r
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Attachment ST HL AE-3260 page 211 of 227 ,
t Unreviewed Safety Question Evaluation w89 156
Subject:
Evaluation of the STPECS Unit 1 Cycle Extended Operation
Description:
This evaluation supports extending the operation of Unit 1 Cycle 1 from 10,800 MVD/MTU to 11,900 MWD /MTU. l Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report?
6 The proposed change extends the design cycle burnup for Unit 1 Cycle
- 1. The changea does not change any plant equipnent or procedures.
The existing analyses are not affected by these changes. Therefore, these changes do not increase the probability of an accident or malfunction of equipment important to safety. Since the Chapter 15 analysis is not impactad, the consequences of an accident (dose release) is not increased.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated ;
previously in the safety analysis report?
Since the change is bounded by existing analyses in the safety analysis report, it does not crecte the possibility of an accident l ot nalfunction of a different type than any evaluated previously in the safety analysis.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
1 Since the Chapter 15 analysis is not impacted by the change, there is not a reduction in the margin of safety.
1 Based upon the above, there is no unreviewed safety question.
l Approved: 7/28/89 A1/P4.NL7
s Attachment ST HL AE 3260 l Page 212 of 227 Unreviewed Safety Question Evaluation a89 157
Subject:
High Energy Line Break Analysis / Designation of i Essential i)iesel Generator Support Systems I l
Description:
In accordance with a commitment in the response to NRC l Question 210.020N (Amendment 57), this FSAR Change Notice (CN) J provides the updated / final high energy line break and stress summary results which replace the initial stress su mary ,
results previously provided in Table 3.5.2 1 and Figure 3.6.1-1.
J In addition Tabin 3.6.1 1 is revised to indicate that the DG .
Closed Cooling Water System and the DG Lubricating Oil System l are essential systems. Though classification of these systems is changed in this table, other FSAR sections (e.g., Section 8.3.1.1.4, 9.5.5, and 9.5.7) currently reflect that these DG subsystems are required to mitigate the consequences of an accident and shutdown the reactor, thus implying by definition that they are essential systems.
Safety Evaluation: ;
- 1) Does the subject of this evaluation increase the probability ot!
occurrence or the consequences of an accident or malfunction of equipment important to nafety previously evaluated in the safety analysis re} ort?
The final stress summary results were based on the HELBA criteria currently outlined in Section 3.6 of the FSAR. The SER (NUREG 0781) and Supplements document the completed review and acceptance of the HELBA criteria as presented in the FSAR associated H1AP correspondence to the NRC as referenced in the SER and Supplements.
Any physical changes resulting from the finalization of postulated break locations were completed prior to the licensing of Unit 1 (8/21/87) and Unit 2 (12/16/88). The incorporation of the final stress summary results into the FSAR reflect the as built, design, and analyzed condition of the plant at the time of licensing.
The generic event of a high energy line break is not associated with ,
a specific probability of occurrence. The final stress summaries indicate increases and decreases for currently identified breaks located at terminal ends. Although the total stress at specific nodos has changed, the new value remains below the code allowable.
In accordance with the HELBA criteria, breaks are postulated at all terminal ends regardless of the total stress present at that postulated break location. Therefore, the subject of this PSAR CN does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
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Unreviewed Safety Question Evaluation #89 157 (Cont'd) i
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated !
previously in the safety analysis report? l l
The initial stress svamaries presented in the FSAR were incomplete. '
Not all high energy line systems had been addressed. The final stress summary results address all the required high energy line ,
systems. The inclusion of these additional break locations for !
these various systems does not reflect new accident analyses. The j additional break locations presented in both Table 3.6.2 1 and '
Figure 3.6.1 1 vere determined in accordance with HEL11A criteria presented in Section 3.6 of the FSAR, and subwequently reviewed and accepted by the NRC in the SER and Supplements. New break locations were identified at both terminal ends and intermsdiate ends in !
accordance with the criteria. As required, barriers, shields, or :
pipe whip restraints were installed to provide appropriate i protection measures to ensure integrity of essential system ;
( functions. The addition of these break locations does not reduce J L the margin of safety previously established for the generic HELBA l program. New break locations were evaluated in the same manner as all other break locations. I
- 3) Does the subject of this evaluation reduce the margin of rafety as defined in the basis for any technica1' specification?
l No Technical Specification associated with a high energy line system I
(e.g. , ECCS, RHR, RCS) is impacted by the finalization of the stress summary results. Neither the LCOs (i.e., equipment of train
- availability) nor required surveillances are altered by the subject i FSAR CN. The margin of safety as defined in the bases for any of these related Technical Specifications is therefore not reduced.
l The pipe break analysis pertaining to the DG Closed Cooling Water l System and the DG Lubricating 011 System is based on the criteria l that these systems are essential, and was thus more conservative I than previously indicated in Table 3.6.1 1. Correction of this I table has no impact on the HELBA program or consequences of such postulated breaks.
l Based upon the above, there is no unreviewed safety question.
Approved: 8/1/89
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Attachment l ST HL AE 3260 l l Page 214 of 227 l l
Unreviewed Safety Question Evaluation w89 158A j
Subject:
hid Loop Operation and Use of SG Dans During Refueling l l
Description:
Installation and use of SG nozzle dans in the RCS includes '
operation under conditions not explicitly stated in the FSAR, l although reducing RCS inventory operations are discussed. l I
Safety Evaluation: l
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction of i equipment important to safety previously evaluated in the safety !
analysis report? j l The SG dans perform two functions: Block flow into a SG and therein l prevent its use in core cooling a ,:nndition allowed by Technical l Specifications. The dam also acts as a primary boundary for the RCS '
in place of the removed SG manway covers. It is designed, with
! margin, to withstand the highest pressure which it will see in this service and as such is considered to be as effective as the manway covers. Procedural controls are in place to ensure adequate air vent paths are available to prevent RCS system pressurization or I vacuum formation during makeup or draining of RCS level. RCP & HHSI pumps are power locked out by procedure and accumulator discharge valves are power locked out. These measures ensure that the design pressure of the nozzle dams is not exceeded by plannea or inadvertent actionc while the nozzle dans are in use. Gerofore, operation with SG dams does not increase the probability m occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report. -
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in tht> safety analysis report?
l The dans replace the SG manway covers as the pressure retention
! boundary. Loss of the dans therefore results in a large break IDCA, j an analyzed accident. Analyses have been performed to establish acceptable containment cooling and flooding effects. These calculations show acceptable conditions for equipment necessary to respond to this event. No other type of accident would result from I the loss of leakage from the dam; therefore, use of SG dams does not l' create the possibility for an accident or malfunction of a different I type than any evaluated previously in the safety analysis ieport.
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ST HL.AE 3260 Page 215 of 227 ,
t i Unreviewed Safety Question Evaluation e89 154A (Cont'd)
- 3) Does the subject of this evaluatson reduce the margin of safety as j defined in the basis for any technical specification? '
The ,"SAR accidents are not considered with the unit shut down and I cooled down. A direct comparison of margins is therefore difficult. ,
Hostvar, the accident can be handled using safety grade equipment :
available by Technical Specification and by administrative l procedures, with results that are bounded by the FSAR analyses. ;
Therefore, the margin of safety is not reduced by the SG nozzle i dams. i I
Based upon the above, there is no unreviewed safety question. !
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Approved: 7/31/89 l i
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Attachment ST HL-AE-3260 Page 216 of 227 Unreviewed Safety Question Evaluation #89-158B
Subject:
Mid Loop Operation and Use of SG Dans During Refueling 1
. Description? This evaluatien covers operation of the unit while draining to mid loop conditions to install dams, upcration in Modes 5 and 6 with the dams installed and while drained dowr 4 s remove the ,
dams.
Saraty Evaluation:
- 1) Does the subject of this ev'Tuation increase the probability of 3 occurrence or the consequences of an accident or r.alfunction of equipment important to safety previously evaluated in the safety analysia report?
1 No increases in the probability of occurrence or consequences are created by mid loop operation as the FSAR analysis of a large break LOCA envelops this condition.
Detailed evaluations of loss ei offsite povar and boron dilution in regard to mid-loop operation are provided in the safety evaluation. ,
RHR and LHSI unthrottled flow evaluation and the locking of RHR heat exchant.er makeup valtas ensure that the probability of occurrence or consequances of an accident as described in the FSAR due to mid-loop i operations are not increased.
- 2) Docs the subject of thir evaluation crea:e the possibility for an ,
accident or malfunction of a different type than any evaluated l previously in the safety analysis report?
j The FSAR large break LOCA analys.is bounds the potential loss of RHP.
i- during mid-loop or a breach in the RCS pressure boundary (i.e., !
! nozzle dam failure). WCAP 11916 (loss of RHR cooling while the RCS is partially filled) evalustes potential RCS pressurization, boiling in the core, or core uncovery. These scenarios are boanded by the FSAR large break LOCA. The effects of disp 1r.cing core decay heat to ;
L the containment as a result of the initial phases of a ;
feed-and-bleed type mode of LHSI injection and pressurizer relief j
have been evaluated and RCFC cooling capacity identified is sufficient to maintain containment closure. The containment response for this mode of cooling is bounded by the FSAR large break LOCA evaluation.
l Detailed evaluations of losa of offsite power and boron dilucien in F regard to mid-loop operations demonstrate that the possibility o! an accident or malfunction of a different type than evaluated it. the FSAR is n,t created.
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y; Attachment ST-HL-AE 3260 Page 217 of 227 Unreviewed' Safety Question Evaluation #89-1588 (cont'd) !
- 3) Does the subject' of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The basis for. Technical Specification 3/4 5,2 and 5.3 ECCS Subsystems, 3/4.6 Containment Integrity, 3/4.0.2.3 containment Cooling were found to be applicable for consideration of mid-loop operation and are addressed below:
ECCS Subsvetem )
The basis for ECCS subsystem operation is tre maintain sufficient core cooling to limit the peak cladding temperature within acceptable limits. For RCS temperatures below 350'F, single failure assumptions of the operable low head injection pump are not required and two LHSI pumps are operable should one be discharging into a broken loop.
For the loss of RHR during mid loop, peak cladding temperatures are bounded by the FSAR analysis and no decrease in margin results for mid loop operation. The Technical Specification for RCS temperature 3
< 200*F does not require operability of a LHSI pump. Administrative procedures for mid-loop do require a LHSI pump for RCS makeup. .
WCAP-11916 has shown that a single LHSI p0mp discharging through the i hot leg is sufficient to handle a loss of RHR with a large cold leg opening (the worst case for core voiding). Thus, the single LHSI pump during mid-loop maintains core conditions such that a decrease ,
in margin does not exist.
Containment Intecrity and Containment E'2ildine Penetration I The basis for Tech. Spec. 3/4.6.6 is f'ounded upon ensuring that the i containment will withstand the maximum pressure following a LOCA or l steam line break. The basis for Tech. Spec. 3/4.9.4 is to ensure l that release of radioactivity is restricted to containment leakage. l Analysis of the containment response to a loss of RHR from mid-loop j and the subsequent heat-up and pressurization of 'ae containment was J performed. The containment temperature whore RCFC heat removal marched core decay heat was established. This analysis demonstrates that the containment integrity is maintained to prevent release of radioactive material and no reduction in margin of a Technical Specification basis occurs.
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ST-HL.AE-3260 1 Page 218 of 227 l 1
Unreviewed Safety Question Evaluation #89 1588 (cont'd) l 1
- 3) Does the subject of this evaluation reduce the margin of safety as i defined in the basis for any technical specification? (Cont'd) j Containment Cooling The basis for Technical Specification 3/4.6.2.3 is to ensure i adequate heat removal capacity during past LOCA conditions. 1 Calculations (ref. NE TH 03-00) which evaluated the containment temperature and pressure established that this function has been met 1 without a reduction in Tech. Spec. basis margin.
Detailed evaluations of loss of offsite power and boron dilution in i regards to mid-loop operations are addressed in the safety i evalustion. These evaluations and the above evaluation demonstrate that mid loop operation does not reduce the margin of safety with respect to any technical specification bases. ,
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Based upon the above, there is no unreviewed safety quustion.
Approved: 7/3/80 l 1
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- l Attachment l dT HL AE-3260 l Page 219 of 227 j Unreviewed Safety Question Evaluation w89 159 l
Subject:
RHR Pump Motor Current Remote Indication
Description:
This temporary modification provides an indication of RHR pump running current to the control room operators. Thio ;
information will be used to monitor for air entrainment in the 1 pump suction. ,
Safety Evaluation: )
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- 1) Does the subject of this evaluation increase the probability of J occurrence or the consequences of an accident or malfunction of i equipment important to safety ,reviously evaluated in the safety l analysis report?
The only connection to permanent plant systems is via the ,
transformer clamped around the RHR 1E power cable. Tnis is a l nonpenetrating, low energy sensing device which will have no impact on RHR cable performance or oper& tion during transformer operation.
If the transformers were to fail, no heat input or degradation of ,
the RHR cable would occur. All other cable is presently installed ,
to permanent plant design specifications, and is not currently in use for any o;her application. Thus, a failure of the circuiting or components in this temporary modification will have no impact on any permanent plant equipment and all existing analyses are valid and l bounding. Therefore, this temporary modification does not increase the probability of occurrence or consequencer df an accident or malfunction of equipment important to safety.
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
The 1E indication cables are isolated from the non-1E components by two fuses, such that no different type of accident or malfunctic will occur beyond those evaluated previously.
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
This modification does not modify or increase RCS temperature or decay head load and it does not reduce the number of available RHR trains. Therefore, it does not reduce the margin of safety as defined in the basis for RHR requirements in the Technical Specifications.
Based upon the above, there is no unreviewed safety question.
Approved: 8/2/89
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j Attachment ST i!L-AE 3260 Page 220 of 227 l Unreviewed Safety Question Zvaluation #89-160 l
Subject:
Update to FSAP. Table 7.5-1 ;
Description:
This FSAR change deletes the Reactor Containment Fan Cooler (RCFC) differential pressure (DP) setpoint from FSAR Table j 7.5-1. I Safety Evaluation: l
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accidert or malfunction of equipment important to safety previously evalsated in the safety I analysis report?
Post-accident monitoring instrumentation is provided to monitor an ,
event which has already occurred; its operation has no impact on the l probability of the event's occurrence or the malfunction of tia ,
-equipment monitored. Deletion of the specific setpoint has no 1 effect on the DP switches' function, as described above; the setpoint is still controlled through che setpoint list.
- 2) ' Does the subject of this evaluation create the possibility for an accident or malfunction of a different typo than any evaluated previously in the safety analysis report?
Post-accin nt monitoring instrumentation in provided to monitor an event whiQ has already occurred; its operation hss no impact on the probability of the event's occurrence or the malfunction of the equipment monitored. Deletion of the specific setpoint has no effect on the DP switches' function.
3)- Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
The RCFC DP switchec are not addressed by the Technical '
Specifications; for Post Accident monitoring, only the Category 1 instrumentation is considered. In addition, the specific setpoint does not affect the switches' function of determiring whether or not the RCFCs are operating.
Barad upon the above, there is no unreviewed safety question.
Approved: 8/8/89 A1/P4.NL7
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Attachment 1 ST HL AE-3260 Page 221 of 227 Unreviewed Safety Question Evaluation #89 162 I Subject; Proposed Revision to Technical Specification Table 4.3-1 -;
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Description:
This proposed amendment was reviewed pursuant to 10CFR50.92 i and determined to not involve a significant hazards i consideration. The proposed amendment to the Technical !
Specifications has not yet been submitted to the NRC for approval.
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Attachment ST-HL AE 3260 Page 222 of 227 l- Unreviewed Safety Question Evaluation #89 164
Subject:
Steam Generator Blowdown System Component Design Parameters
Description:
FSAR Table 10.4 1 is being revised to be consistent.with the l equipment design specification and vendor design documents.
1 Safety Evaluation:
- l. 1) Does the subject of this evaluation incr(ase the probability of
- occurrence or t.he consequencas of an accident or malfunction of. !
l equipment important to safety previously evaluaced in the safety l l analysis teport? !
1 This change.is a consistency check between FSAR Table 10.4-1 and thn ;
other design documents. The design specification MS102/, and vende: 1 design data sheet 4322 00001 AKG for SCBD regenerative heat l exchanger show that the design pressure for tubeside of the heat I exchanger am 250 psig and for the she11 side as 800 psig. :This also ,
agrees with line list on the basis that the she11 side receives flow from condensate systen,which is designed for 800 psig whereas the tubeside receives flow from SGBD flash tank which is designed for l 250 psig. Similarly for the SG recirculation pump, the design specification MS1033 and vendor design data 4317-00G39 BIE/8317-
.00036 BIE and pump curve were revieved. These documents show's flow of 150 gpm at 210 feet of head. The 235 ft of head-is a shutoff head. This change does not increase the probability of occurrence or the consequences of an accident or malfunction previously evaluated based on the following:
- a. This system is noasafety class (except for the part through the containment penetration) and thus performs no function related to the safe shutdown of the reactor plant as the containment penetration area is not changed by this FSAR change notice,
- b. This system is not addressed in FSAR Chapter 15 accident events. The changes addressed in this change have no impact on the probability of occurrence or the consequences of an accident or malfunction of equipment important to' safety previously evaluated in the SAR.
- c. This system is not addressed in the Tech. Spec.
Doer the subject of this evaluation create the possibility for an ccident or malfunction of a different type than any evaluated ereviously in the safety analysis report?
As stated in A.1, this system is ncasafety class and is not needed for the safe shutdown of the plant. Therefore, this change does n>t create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
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Attachment ST-HL-AE-3260 Page 223 of 227 Unreviewed Safety Question Evaluation #89-164 (Cont'd)
- 3) Does the subject of this evaluation reduce the sargin of safety as defined in the basis for any technical specification?
There are no technical specification requirements placed on the steam generator blowdown system. Therefore, the proposed change does not reduce the margin of safety, b Based upon the above, there is no unreviewed safety question.
Approved:' 8/18/89 k
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Attachment ST-HL-AE-3260 Page 224 of 227 Unrevies.'ed Safety Question Evaluation #89-165
' Subj ect: Process and Effluent Radiation Monitors
Description:
The accuracies of the process and effluent radiation monitors (PERMS) are specified by the vendor of the radiation monitoring system in vendor documents which are controlled at the site. These documents are used in instrument loop uncertainty evaluations. To determine the trip setpoints, ;
sensor error and allowable values for radiation monitors that I cause ESF actuations. .These values are specified in Tech Spec. Table 3.3-4. The accuracies of the FERMs vary due to j different type of detectors and detector environments. To )
! make a blanket statement of PERMS accuracy is misleading and I
is not representative of the different PERMS monitors. Also, i since the standard review plan does not require the PERMS ;
system accuracies bc stated in the FSAR, the accuracy l statement for the radiation monitors is being deleted from the 1 FSAR. I 1
Safety Evaluation: 1 1
- 1) Does the subject of this evaluation increase the probability of occurrence or the consequences of an accident or malfunction.of s u
equipment important to safety previously evaluated in the safety ll analysis report?
l This change deletes a statement in the FSAR that discusses the '
accuracy of the PERMS. This change does not increase the i probability of occurrence of an accident since the radiation I monitoring system does not cause accident initiations (it is foi monitoring and control only). Deleting the accuracy statement dces t g
not physically change tFw radiation monitoring system. Radiation monitoring system operalility is unaffected so the probability of equipment malfunction la not affected. The accuracies of the radiation monitors are stated in vendor documents that are i controlled at the site. These documents are used to deterwine trip setpoints, sensor error and allowable values for PERMS monitors that l cause ESF actuation. Deleting the accuracy statement from the FSAR I I
does not affect design documents; hence, the consequences of an accident are unchanged by deletion of this statement. ;
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Attachment i ST-ilL- AE.3260 !
Pago 225 of 227 Unreviewed Safety Question Evaluation #89-165 (Cont'd) l l- 1
- 2) Does the subject of this evaluation create the possibility for an l 1.
accident or malfunction of a different ty g than any evaluated
)
previously in the safety analysis report?
Deletion of the accuracy statement from the FSAR does not create the !
possibility for an accident or malfunction of a different type than i i any evaluated previously in the SAR. The PERMS accuracies given by I li the vendor were used to determine ;-rotective system setpoints so this change does not affect the installed PERMS system. This change does not affect the operability of the PERMS or the physical !
l condition so the possibility for different malfunctions is not L created.
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- 3) Does the subject of this evaluation reduce, the margin of safety as defined in the basis for any technical specification?
L The setpoints for the radiation monitors that cause ESF actuations l
are determined by using vendor document information and'are not based on the accuracy inforaation in the FSAR. Deletion of the j D accuracy statement from the FSAR does not reduce the margin cf I
. safety.as defined in the Tech. Specs. The trip setpoints, sensor I L' error, total allowance and allowable values in Tech. Spec. j Table 3.3-4 remain valid and bounding.
l: Based upon the above, there is no unreviewed safety question.
lf l Approved: 8/18/89 l
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Attachment ST-HL-Ar-3260 Page 226 of 227 Unreviewed Safety Question Evaluation #89- 169
Subject:
Deletion of Test Thermowells
Description:
A thermowell in the FW/CD system is to be replaced with a threaded plug.
Safety Evaluation:
- 1) Does the subject of this evaluation increase the probability of occurrence or the conseqt.ences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis' report?
I This chan;e is to nonnuclear-related equipment that is not necessary for the safe shutdown of the plant. The change involves deletion of thernowell TW 7100 and subsequent replacement of the thermowell with !
a threaded plug. The thermowell was originally used to verify the output of temperature element TE-7102. TE-7102-is used to monitor the temperature of line 36" CD-1035. Deletion of this thermowell
.i will not. decrease the ability of the operators to monitor the temperature in this line, since a hand held pyrometer can be used to verify the output of temperature element TE 7102 instead. The pressure in the line.where the change is being made is 291 psig, g Since a threaded plug will bs used in place of the thermowell, the i failure mode changes from a case of the thermouell breaking off and being sucked into-the SGFP to one of the plug unthreading itself and becoming a missile. Since the location of the thermowell is on top '
of the turbine building and away from all safety-related equipment, i the missile effect will not damage anything related to safe shutdown. In addition, subsequent flooding of the turbine building is not a concern to the safe shutdown of the plant. The change is ,
I being made to equipment which is not in a radiologically controlled area; therefore, the consequences of an accident are not increased. .
- 2) Does the subject of this evaluation create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis raport?
Failure of the plug which will replact TW-7100 will not affect the safe shutdown of the plant since the plug line #36" CD-1035 and the SCFP's are not required for safe shutdown. As discussed in 1), the failure mode for this change is the plug becoming a missile; the SGFP's are not affected. ,
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, Attachment ST-HL AE-3260 Page 227 of 227 Unreviewed Safety Question Evaluation #89-169 (Cont'd)
- 3) Does the subject of this evaluation reduce the margin of safety as defined in the basis for any technical specification?
None of the eq'.dpment affected by this change reduces the margin of -,
safety for any Tech. Spec. Neither the thermowell, line 36" CD 1035 or t'.a SGFP's are mentioned in the technical specifications, nor do they reduce the integrity (by failure) of any equipment that is in the technical specifications.
Based upon the above,-there is no unreviewed safety question.
Approved:' 8/11/89 l: .
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