ML20059G333
| ML20059G333 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/30/1990 |
| From: | Leitch G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9009120260 | |
| Download: ML20059G333 (57) | |
Text
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10CFR50.59.(b) (2) i
.3902095580 l PHILADELPHI A ELECTRIC COM PANY ;
l LIMERICK GENER ATING ST ATION '
P. O. BOX A +
SAN ATOG A. PENNSYLV ANI A 19464 l
(216) 3271200. EXT.-3000
- onanau u.crives J.ugust 31, 1990 L 6... .E*.'. llllEl."'. ..... Docket Nos.50-352 i 50-353 License Nos. NPF-39 !
NPF-85~
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l- U.S. Nuclear Regulatory Commission' l Attn:- Document Control Desk i- Washington, DC 20555 l
l
Subject:
Limerick Generating Station, Units 1 and 2 -
f L Annual Plant Modifications Report July.1, 1989 through June.30, 1990. ,
L l'
Enclosed is a copy of the Limerick Generating Station,. Unit 1 Annual Plant Modifications Report for the period July 1, 1989-l through June 30, 1990 as required by 10CFR Section 50.59. >
The attached report consists of a- listing of modifications completed during this period. The following information is 7
included on each modification:
l l- O The Philadelphia. Electric Company Plant Modificettions (or document) " Tracking. Number".
O The " Title or Name" of the system, subsystem or i document which was changed.
O A " Description" of the change.
O The " Reason" for making the change.
O A " Summary" of the written safety evaluation.
Should you have any questions, or require further $Mormation, please contact us.
l Very truly yours,
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Enclosure gf -j cc: T.T. Martin, Administrator J egion I, USNRC T.J. Kenny, USNRC Seniod Ad ent Inspector 9009120260 900630 l PDR ADOCK 05000352 R PDC -[g f ,
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DOCKE - . b-35 UNIT.~'1)
' DOCKET NO.-50-353.(UNIT'2) i ANNUAL PLANT MODIFICATION REPORT '
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' JULY 1, 1989 THROUGH JUNE 30, 1990 l
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' SUBMITTED TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION.
O PURSUANT TO i l
I FACILITY OPERATING LICENSE.NPF-39-(UNIT-1)-'
AND NPF-85 (UNIT 2) t
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-LIMERICK GENERATING STATION s ANNUAL PLANT MODIFICATION REPORT
- [' JUNE 30, 1990
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This report for Limerick Generating Station Unit No. 1, License =
No. NPF-39 and Unit.No. 2, License No. NPF-85, is issued in .
fulfillment of the reporting requirements of 10CFR=50.59(b). The report covers modifications'that were physically completed during the one-year period ending June 30, 1990,- including changes made to the facility as described in the FSAR.
i For each of the modifications included in this report,-the safety evaluation has determined that there.are no unreviewed safety-
- questions as defined in 10CFR 50.59(a)(2) in that (1) the-probability of occurrence of the consequences of an accident or malfunction-of equipment important to safety previously evaluated in the FSAR was not increased, or (11) a possibility for an accident or malfunction of a different type than any_ evaluated previously in the FSAR was not created, or (iii) the margin of safety as defined in the basis for any Technical Specification was not reduced.
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Docket:No. 50-352 Docket No. 50-353
'I LIMERICK GENERATING STATION '
UNIT NO. l and 2 .
ANNUAL MODIFICATION REPORTT TABLE OP CONTENTS 'I Item Mod. No.
System ,
Page 0502-0 . Control Enclosure HVAC 'l' 0614-1 Standby Gas Treatment System (SGTS) 3-0974-1 Nuclear Boiler- 5 1 5180-1 Pcst LOCA Recombiner 7
-5329-1 Nuclear Boiler. Instrumentation 9 5475-1 Plant Process Radiation Monitoring 11 l 5742-1 Schuylkill PMP House and Makeup. fl3 1 5962-2 Reactor Core Isolation Cooling .15 l 5972-2 4KV System 17 l 5976-2 Plant Structures -
19 s 5986-1 Reactor Enclosure Recirculation System (RERS) -l Control Room Emergency. Fresh Air System (CREFAS)
Standby Gas Treatment System (SGTS)-
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-21 ;
5994-2 Reactor Core Isolation' Cooling (RCIC) 23 5995-2 High Pressure Coolant Injection ~-(HPCI) 25 ;
5998-2 Reactor Water Clean-Up 27 9 O, 6001-2 6006-2 Plant Structures Residual Heat Removal 29 1' 31 6025-2 Nuclear Boiler 33 6031-2 480V System 35 j 6038-2 Residual Heat Removal Service Water (RHRSW) 37 !
6039-2 Containment and Leak Testing 39 l 6108-1 250V DC System 41 l 9071-0 Emergency Service Water and- !
Residual Heat Removal 1 Service Water- 43 -l 9072-0 Recidual Heat Removal. Service Water 45 )
9075-0 Residual Heat' Removal Service Water 47 l-9076-0 Emergency Service Water 49 j 9083-J Residual Heat Removal Service Water 51 ]
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Licorick G3norctingl Station.
Unit 0-Annual Plant Modification Report 1989.Through~ June 30, 1990-1 O
4 EJuly 1,
'Jage 1 .
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Modifications No.: 0502-0 1
A. System: '. Control Enclosure HVAC '
i L B.
Description:
This. modification consicted of the replacement of the existing A & B Atmospheric Chlorine Detection Systems-.(ACDS) and changed the control room high= chlorine' condition isolation logic from a 1 out of 4 channel-(one detector per channel) isolation logic to a.T aut of'2' subsystem isolation (two detectors per subsystem) logic.
C.- Reason for Change: j To eliminate unnecessary isolation of the Main Control ~ Room Ventilation System and initiation of Control Room Emergency Fresh Air Supply-(CREFAS) System.
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D. Safety Evaluation Summary:
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- 1) Does this modification increase the probability'of occurrence or the consequences of.an-accident or malfunction of equipment:important to safety as previously evaluated in the FSAR?-
i Answer: No, because this modification replaced Channels A'& B detectors with Anacon type ~to-make all four channels alike. It also: revised' L existing 1 out of 4' channel logic to 2:out of 2 subsystem logic.to provide. redundancy in -
each subsystem so thatino_ single detector or probe failure could.cause an isolation.
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-11) Does this modification create the possibility for.an !
accident or malfunction of a different type than any L evaluated previously in the PSAR?
Answer: No,.because the monitoring cnd' protective functions of the chlorine monitors and/or-the HCRIS do not change. i
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, ,. -j Linarick Gansrating Gtotion-Unit 0 '!
l Annual Plant Modification: Report;
~N July'1, 1989 Through June 30, 1990 '
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, Page 2 'i
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t iii) Does this modification = reduce the margin of safety as defined in the bases for the Technical Specifications?- ,
j Answer No, because this modification reduced'the.
frequency of; spurious alarms and unnecessary-activation of CREFAS.--.The basesifor the i Technical-Specifications, Section 3/4.3.7.8 was reviewed in making 1this determinttfon.
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Lim 3 rick'Ganarcting Stction l Unit:1 '
1.:inual-Plant Modification Report'
/T ' July 1,~1989 Through-June 30,;1990
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'Page 3- ;
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Modifications No.: 0614 t A. System: Standby Gas Treatment System (SGTS) i B.
Description:
i The modification replaced the existing SGTS fans with higher capacity' fans and connected the SGTS to the refueling area and both reactor enclosures.
C. Reason for Change: '
The modification satisfied operating license condition 2.C(14).
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D. S&fety Evaluation Summary:
ID 1) Does this modification increase the probability of ,
\ss/ occurrence or the consequences ofian accident or-malfunction of equipment important to safety as previously evaluated in the PSAR?-
Answer: No, because the new SGTS fans, dampers, controls and ductwork were fabricated and installed under a.QA program which meets!or exceeds the original requirements.- This ensured'there would not be any increase in the probability of equipment _ failure. This modification did not increase _the-consequences ,
of an-accident since the reactor enclosure design drawdown time and in-leakage rate was-not exceeded. All primary containment isolation design requirements have been met.
Therefore, the new SGTS will maintain _the same high degree of reliability as the original ~ l system to mitigate a LOCA or fuel handl'ing '
accident. '
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Limarick-G2n3roting Stotion -
Unit 11 ,
Annual Plant Modification Report '
.(~' July l1,'1989 Through. June 30, 1990 ;
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' Page: 4 ,
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- 11) Does this modification create-the possibilityLfor_an '!
- accident or malfunction of'a'different' type than.any_ ,
I eva iP3ted previously- in the FSAR? ~
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s Answ<y- No, because-the new system operates in a similar' manner to the original SGTS.. The' l
' r e f u e l i n g a r e a'. n o w h a s t w o p n e u m a t i c normally-closed' fail-open HVAC isolation ~ .
valves installed in parallel to each other._ t These valves meet the single active failure criterion and connect-the refueling area-zone l -to the SGTS upon receipt of an isolation i signal. All primary' containment isolation- '
I design requirements _have-been met._ These: . l changes extend'SGTS-operation to the refueling area (and Unit 2' reactor enclosure) without ;
creating the possibility ofian accident.oir L malfunction different than'any previously '
It evaluated in the.FSAR when' connected only to' t l\ Unit-1 reactor enclosure. /
iii) Does this modification reduce the. margin of safety as i defined in'the bases for the_ Technical Specifications?L Answer: No, because the existing SGTS filter train can satisfy the efficiency requirements at z the
. higher flow rate and the reactor enclosure >
drawdown time is'not affected. . Therefore, these changes will not reduce the margin of !
-safety as defined in Technical _ Specification t Sections 3/4.3.2, 3/4.6.3, 3/4.6.5 and associated bases.
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l Lim 3 rick G3narcting Station
- - . Unit 1 Annual Plant Modification Report'
!T July 1, 1989:Through; June.30, 1990 lb / Page 5 't L 'I>
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7 Modifications No.: 0974-1 T
A. System: Nuclear Boiler B. Description ,
l J This_ modification replaced the pilot disc material in the ;
Main Steam Safety Relief Valves. ,
9 C. Reason foroChange:
This is part of a BWR Owner's' Group recommended program being-implemented by other utilitie:s for an inservice: performance. i evaluation to generically qualify the< substitute material as a fix for high setpoint drift.
t D. Safety Evaluation Summary:
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i) Does this modification increase the probability ofl t occurrence or the consequences of an accident or- i malfunction of equipment important to safety as i previously evaluated in the FSAR?
Answer: No, bect.use this modification-improved the r safety mode operation reliabilityiof;the-valve.
I 11) Does this modification create the possibility for an accident or malfunction'of a-different. type than-any L
evaluated previously in the FSAR?J Answer: No, because'the modification did not create i
the possibility'for an accident or malfunction o'i.a different type than any evaluated previously in the safety analysis' report. The l consequences of a postulated failure of the-safety-relief valve'are-completely enveloped by the current ASME Overpressure Protection Report. Therefore, the-proposed modification 1 did not create a new or different accident ~or malfunction than previously-evaluated. l 1
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.. :. e Lim 3 rick;G3n3rcting. Station-Unit 1
.. Annual Plant Modification' Report -i
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July 11, 1989'.Through June 30, 1990-
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l lii) Does this modification reduce the margin of safety as defined in the bases for the Technical, Specifications?. . ,
Answer: No, because this modification:did not reduce-thefmargin'of safety as defined in the basis -
for'any. Technical Specification. The ability.
to safely shutdown'the plant, as described in ;
the Technical Specification, is unaffected by ;
the change in safety-relief valve pilot disc l material.
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Unit 1 Annhal Plant' Modification Report- ,
f July _1, 1989 Through June.30,'1990 i, ,
Page.7- -
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Modifications No.: 5180-l' >
A. System: Post LOCA Recombiner ,
B.
Description:
This modification provides power feed bypass to the trickle-heaters in the hydrogen recombiner power cabinets LAC 224 and- '
1BC224.
i C. Reason for Change:
To maintain power to the trickle heaters even when H(12[s ,
Recombiner is shut down for~ maintenance.and.thus keep the H[12[s Recombiner dry and ready to operate.
D. Safety Evaluation Summary:
- 1) Does this modification. increase i.he probability of 'i occurrence or the consequences of an accident or malfunction of equipment-important to safety as previously evaluated in the FSAR?
Answer: No, because the transfer-switches inst'alled by this modification are only used to provide power to the trickle heaters when the, hydrogen-recombiners are shut down-for-maintenance.
They do not in any vay affect the; performance of the safety-related hydrogen recombiners. ,
This modification will not change _the original i function and logic'of_the' hydrogen'recombiner system. FSAR Section 6.2.5.2.1 was reviewed '
in making this determination.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any >
evaluated-previously in tne FSAR?
Answer: No, because the wiring in this-modification was installed in accordance with~Dwg.
8031-E-1412 and the addition of circuit breakers and transfer switches satisfy all Class IE installation requirements. FSAR j, Section 6.2.5.2.1-has been reviewed-in making !
l this determination.
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I Lim 2 rick-Gtnarating' Station. 1
' Unit 1 d
' Annual Plant Modification Reporti :)
July 1,-1989-Through June 30,11990. >
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111) Doeszthis modification reduce thel margin'of safety as, defined in the bases for theiTechnical Specifications?? ,
. Answer: No,1because this' modification' maintains the:
l hydrogen recombinersLin their-required-l non-operating _ temperature of 225[ho[sP and, ,
-thus keep them readily available for-proper .!
operation.. Technical Specification _Section I 3/4'.6.6 was reviewed in making this determination.-
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Unit lE
-Annual Plant Modification Report '
("'p July-1, 1989 Through June 30, 1990-l() ,
Page.9 >
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.l Modifications No.: 5329-1 A.- System: Nuclear Boiler Instrumentation +
B.
Description:
i This modification removed the jet pump developed head indicator PDI-42-lR005 from service.
i C. Reason for Change:
The instrument removal prevents a potential for SCRAMS.due to !
erroneous indication of reactor water level induced ~by ,
presure fluctuations.
D. Safety Evaluation Summary:
i) Doer, this modification increase the probability of O
occurrence or the consequences of an accident or malfunction of equipment importantoto safety as ,
previously evaluated in the FSAR?'
Answer: No, because the design-of this modification maintains the testability and seismic .
qualification.of the remaining instrumentation l on local rack 10C010. PDI-42-lR005 L was only -)
utilized as a diagnostic indicator'to maintain jet pump performance and did not-perform any ,
active safety function,
- 11) Does this modification create the possibility for an.
accident or malfunction of a different type than any evaluated previously in the FSAR?
Answer: No, because the design of this modification maintains ~the testability and seismic qualification of the remaining instrumentation on local rack 10C010. PDI-42-lR005'was only utilized as a diagnostic indicator.to maintain jet pump performance and did not perform any 3
active safety function. j
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'Unitil' Annual-Plant Modification: Report July.1, 1989-Through June 30,.r>90.
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i lii) Does this' modification-reduce the margin of safet'y-as- .4 e defined in the bases;for.the, Technical Specifications?' ,
r Answer: No, because PDI-42-lR005 wasinot utilized-to- i satisfy,the surveillance requirements for jet [
pump operability in the Technical l Specifications Section 3.4.l'.2, therefore, fits :
removal does not affect-compliance with that. !
section nor does it reduce-the' margin of. i safety as= defined in the bases for.that j section.- i
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Unit 1-Annual Plant Modification Report-July 1, 1989 Through June 30, 1990 i( '
. Page 11 Modifications No.: 5475 ,
A. System: Plant Process Radiation Monitoring l'
L B.
Description:
i This modification added flow totalizers to the north and- .
south stack normal range, north' stack' wide range ~and hot _
maintenance shop isokinetic sample monitoring systems. i
.C. Reason for Change:
To establish a means of obtaining total stack flow. l D. Safety Evaluation Summary:
- 1) Does this modification increase the. probability of O occurrence or the consequences,of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer: No, because the south and north stack normal range sample monitors in' addition to the~ hot maintenance shop monitor are non-safety
, related. While the: north stack wide; range l monitor is a post accident system and IE- ~ .
l powered, the flow element was installeduin a non-Q section of-pipe'away from:the. monitor, and the totalizer is' powered'fromfa'non-IE .
power source. As:a. result of locating the l flow element downstream of-the monitor, the skid dynamic qualification was' unaffected.. -
The additional flow' meters were. procured, installed and tested to the piping and system -t requirements in which they were placed. The l modification did.not'make a change to the-l stack flow operating system specifications therefore, it functions exactly as originally designed.
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Unit 1 .i Annual Plant Modification Report- l
(~N July 1,- 1989 Through June 30,s1990 >
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Page;12 -
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- 11) Does this modification create the possibility for an_ <
L accident:or malfunction of a different type.than any. '
l evaluated previously in the FSAR?.
' Answer: No, because the originalistack ' low-operating' specifications remain unchangid .and function:' ?!
exactly as originally designed. -The addition- !
al flow meters and totalizers were procured, 1 installed7 and tested:to the piping and system j requirements in' which' they are_ located.. - The - ,
tor *U ?ers are passive, non-alarm'and control
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J irstruments. l i
lii)- Does this modification', reduce.the margin of: safety as .
defined in the bases for.the Technical Specifications?
Answer: No,.because the design provides-an improved' mechanism in determing total stack flow 1 release to the environs. -The additional flow O' meters and totalizers were procured,' installed' and tested to the piping.and' system-require- !
ments-in which they are--located.. This '
modification is in accordance with.the
, original design requirements. 'The-subject-instruments do not-introduce any new alarm or l control functions, nor interfaceLwithz other-systems therefore, the. margin of safety:is not reduced. <
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Lim 3 rick G3nSrcting Station' )
-Unit 1 Annual-Plant Modification Report g
July 1,-1989.Through1 June 30, 1990 Page t L
k Modifications No.: 5742-1 ;
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A. System Schuylkill PMP House and' Makeup-B.
Description:
This modification-added an alarm-to warn plant operations prior to the cavitation point of the'Schuylkill River make-up l control valve. This modification also disarmed'the' automatic-level' interlock for the Schuylkill' River make-up control valve and the Schuylkill River and Perkiomen Creek make-up valve controllers.
C. Reason for Change:
To prevent misoperation of the Schuylkill River and Perkiomen Creek make-up systems. To notify operations prior to the cavitation point of the'Schuylkill River make-up valve.
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D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
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Answer: No, because this modification was designed to prevent the possibility lof control valve cavitation and misoperation of~the Schuylkill River pumps. Failure of the cooling _ tower basin will have no impact on safety-related components.- The make-up water system has no safety-related function. Failure of the system does_notfcompromise any safety-related-system or component or prevent a safe shutdown of the plant.
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Lim 3 rick G3nerating Station. .j '
~ Unit 1 Annual Plant Modification' Report j
("' July;1,-1989 Through June 30, 1990 Page - - 14 i
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- 11) Does this rodificationicreate the possibility,for ani ,
accident,or malfunction of a=different type than any: ,
evaluated previously in the FSAR?- ]
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, Answer No, because=the. modification-~was designedLto j '
L prevent'the possibility:of control valve l
cavitation and.the misoperation of the 3 Schuylkill 9tver' pumps. . The make-up water?
system has no safety-related; function. ..
Failure of the cooling tower basin will1have i no inpact on' safety-related components.
Failt re of .the rystem doesinot compromise 1any safety-related system or component or. prevent.
a safe shutdown'of the plant.
lii). Does this modification reducelthe margin of safety as-
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defined in the bases for the Technical Specifications?
( Answer: No,.because the make-up water system and its '
\ .instrumente. tion are not-covered by the, -
Technical Specifications. : Technical 4 Specifications Sections 3/4.3 Land 3/4.7 were reviewed in making this determination. i l
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Limerick Genorcting Stotion i Unit 2 i Annual Plant Modification Report ;
,s July 1, 1989 Through June 30, 1990 V'
l( Page 15 -
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Modifications No t: 5962-2 A. System: Reactor Core Isolation Cooling j i
B.
Description:
This modification provided isolation devices and other circuit changes. ,
C. Reason for Change To protect RCIC turbine speed control and indicating circuits t from faults that could result from a control complex fire before RCIC control is transferred to the RSP. i D. Safety Evaluation Summary:
() i) Does this modification increase the probability-of occurrence or the consequences of an accident or malfunction of equipment important to safety as i
, previously evaluated in the FSAR? :
Answer: No, because this modification provides the capability for the RCIC to be operated from the RSP during.a fire event in the control ,
l complex by protecting the turbine control circuit. This modification does not affect the capability of-RCIC to perform its intended function, which is to maintain adequate core cooling for certain events. This modification also does not affect the capability of the Remote Shutdown System (RSS) to perform its ,
intended function, which is to provide safe shutdown capability from outside the control room. FSAR Chapter-15 was reviewed in making l this determination.
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Unit 2 ,
i '
Annual Plant' Modification Report ;
l(^h July 1, 1989 Through June' 30, 1990 !
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Page 16 *i
- 11) Does this modifiestion create the possibility for an i accident or malfunction of a different type than any ,
evaluated previously in the FSAR?
Answer No, because the modification maintained the .
design functions, the separation criteria, .!
divisional power requirements, seismic f requirements and environmental qualification >
requirements of the RCIC and RSS. Malfunction '!
of the Class IE components associated with the modification will result in failure of RCIC, a l condition which has already been considered in the PSAR. i ill) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications? ,
. g- Answer No, because the modification did not affect i o any setpoints or instrument accuracy and. drift requirements defined in the-Technical ;
Specification. The design function and intent of the RCIC and RSS was not affected by this =>
modification. Technical Specifications t 3/4.3.5, 3.3.7.4 and 3/4.7.3 were reviewed in making this determination.
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. l Licorick Osnarcting Station i Unit 2 Annual Plant Modification Report !
July 1, 1989 Through June 30, 1990 ;
O - Page 17 *;
Modifications No.: 5972-2 ,
A. System 4KV System i B. Descriptions t This modification replaced the existing ITE-27D model relays .
in the . 16 KV switchgear- sections 10A11502, 10All509, 10All602, 10A11609, 10All702, 10All709, 10All802 and 10A118i9, with model ITE-27N relays.
C. Reason for Change:
To ensure protection of Class IE loads against the adverse '
effects of sustained undervoltage conditions when the Class IE buses are connected to the offsite power system.
() D. Safety Evaluation Summary:
Does this modificatiori increase the probability of 1) occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in ths FSAR?
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Answer No, because this modification only replaced the existing safety-related time delay
- undervoltage relay with a new model relay.
The replacement enhanced the system reliability as it significantly reduced the likelihood for spurious tripping and separating the Class IE distribution system from the offsite power system. The new relays !
ensure that adequate voltages are available to all Class IE equipment for all taodes of plant operation. Seismic and environmental qualification of the cubicles where the relays are installed was not adversely affected by the change.
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J Limerick GOnOrcting StGtiCn !
i Unit 2 ;
Annual Plant Modification Report l
( Ju)y 1, 1989 Through June 30, 1990 ,
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Page 18 * -
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i l 11) Does this modification create the possibility for an f accident or malfunction of a different type than any , j evaluated previously in the FSAR?
i - Answer No,'because replacement of these relays did ,
l not affect any other safety-related system. >
l This modification-does not affect the safe '
shutdown of the plant. This modification did not alter the design function design criteria or testing acceptance criteria for the affected systems.
111) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications? l t
Answer No, because this modification does not adversely affect the relay performance, but rather improved it by reducing the likelihood O,' of tripping and separating the Class.IE distribution system from the offsite power
, system. The new relay ensures compliance with ,
l BTP PSB-1 for equipment protection against degraded voltages. Technical Specifications :
Sections 3/4.3 and 3/4.8 were reviewed in making this determination.
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Linarick G;norcting Station Unit 2 Annual Plant Modificatir?n Report i
/~ July 1,.1989 Through June 30, 1990 l Page 19 {
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Modifications No.: 5976-2 A. System: Plant Structures r
B.
Description:
This' modification implemented changes to panels within the .
control enclosure to eliminate the possibility of inter-panel interference during a seismic event. Inter-panel .
Interference-of-the GE-NSSS panels was prevented by
- connecting panels together with externally mounted plates using existing connection points on top of the panels.
Inter-panel interference of the BOP panels was prevented by -
connecting panels together with interconnection bolts. ,
C. Reason for Change ,
O This modification changed the control panel installation within the control enclosure to eliminate the possibility of interpanel interference during a seismic event.
D. Safety Evaluation Sunnary:
- 1) Does this modification increase the probability of l occurrence or the consequences of an accident or ;
malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer: No, because this modification was performed prior to Unit 2 fuel load so that the actual ,
construction work in or around these panels did not jeopardize'the ability of the panels to perform any safety related function. This- 'l MDCP was issued to 1) implement the original design intent method of panel installation, ,
and 2) to enhance the existing plant ;
condition. These changes eliminated the possibility of inter-panel interference during .
a seismic event. This MDCP assured the dynamic qualification of the affected safety related panels. .The materials used to make s
the interconnection were Q-listed. The interconnection design is seismically
- qualified, and the interconnected panels retain their ability to remain operable during. -
and after a design basis earthquake or dynamic loading.
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i Licorick G;ncrcting Statien '
i Unit 2 Annual Plant Modification Report
,('_
July 1, 1989 Through June 30, 1990 l
\s,)/ -
. Page 20 -!
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h
- 11) Does this modification create the possibility for an
- accident or malfunction of a.different type than any ,
evaluated previously in the FSAR?
l
! Answer: No, because this modification eliminated the ;
possibility of inter-panel interference during
~
i a seismic event and' assured the dynamic qualification of the affected safety related-panels.
111) Does this modification' reduce the margin of safety as defined in the bases for the Technical Specifications?
Answer No, because the Technical Specifications do !
not address installation requirements of i panels. The operability of all systems with components in the panels being interconnected was not affected by this change.
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Limerick G;narcting Staticn i Unit 1 Annual Plant Modification Report !
July 1, 1989 Through June 30, 1990' i
\ Page 21
-l 4
I Modifications No.: 5986-1 i
A. System: Reactor Enclosure Recirculation System (RERS) ,
Control Room Emergency Presh Air System (CREFAS) .i Standby Gas Treatment System (SGTS) l l
B.
Description:
This modification consisted of removing _non-qualified interposing relays and rewiring annunciators for the charcoal adsorber fire detection panels in the Reactor Enclosure Recirculation System (RERS), the Control Room Emergency Presh Air System (CREFAS), and the Standby Gas Treatment System (SGTS).
C. Reason for Change.
( Relays manufactured by Schrack have been used in charcoal '
adsorber fire detection control panels OAC170, OBC 170, OAC177, OBC 177, LAC 186 and 1BC186. Two different models of i
Schrack relays, model CAD 14D10 and RM302024, have been used in those panels. A review of the F,quipment Qualification (EQ) package for the above-mentioned panels has revealed that no documentation exists to indicate that relay model CAD 14D10 is environmentally and seismically qualified. However, relay model RM302024 has been found to be qualified based on the documentation included in the EQ packages for'the above-mentioned panels.
D. Safety Evaluation Summary: ;
l i) Does this modification increase the probability of ,
occurrence or the consequences of an accident or m'1 function of equipment important to safety as l p*eviously evaluated in the FSAR?
AnEwer No, because this modification made no functional changes to the affected system; they will operate exactly as before and will function as presently designed. The removal of relays and rewiring of panels has been evaluated to assure conformance to the existing seisaic, environmental, and O electrical separation criteria for Limerick.
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i LiC3 rick G noroting StOtion !
Unit 1 i Annual Plant Modification Report July 1, 1989 Through June 30, 1990 L( .
Page 22 f i
- 11) Does this modification create the possibility.for an accident or malfunction of a different type than any evaluated previously in the FSAR? l t
Answer No, because this modification maintained the assurance of operation under postu3ated ,
I accidents. The seismic and environmental ;
qualification of the panels has been .
i maintained by this modification. This ,
modification did not impact the plant fire !
protection features. [
iii) Does this modification reduce the margin of. safety as defined in the bases for the Technical Specifications? ,
Answer: No, because this modification maintained the margin of safety of the. panels and maintained i assurance of operation under postulated O
accident conditions. Technical Specifications .
)
Section 3/4.3, 3/4.6.5 and 3/4.7.6 and their bases have been reviewed in making this determination.
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Limerick Generating Station Unit 2 Annual Plant Modification Report July 1, 1989 Through June 30, 1990
- Page 23 O- ,
Modificationu No.: 5994-2 A. Systemt Reactor Core Isolation Cooling B. Descriptiont This modification installed an emergency manual transfer switch which-enables the RCIC steam supply inboard containment isolation valve, HV49-2F007, to be powered and controlled from a Division 1 emergency source.
C. Reason f?r Changet To permit the valve to be opened in the event of a fire that requires the RCIC system for safe shutdown, but which has caused the valve to spuriously close with subsequent loss of Division 3 AC power.
O- D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR7 Answert No, because all components are Class IE, environmentally and seismically qualified, and installed in accordance with Class IE and seismic requirements. During normal operation, separation is maintained between Division 1 and Division 3 electrical equipment by two locked open breakers. The inboard and outboard isolation valves are normally open; thus, only the reactor vessel isolation
- function can be affected. Since the transfer switch is locked in the " normal" position the probability of failure of the valve to close when required is unaffected.. No accident evaluated.in the FSAR can be caused by'a failure of equipment added by this modification nor are the consequences of an accident evaluated in the FSAR increased.
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. . J Limerick COnorOting StOtiCn Unit 2 ;
Annual Plant Modification Report l i
i l July.1, 1989 Through June 30, 1990 Page 24 ;
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any ,
evaluated previously in the FSAR7 l Answert No, because this modification maintained the design functions, separation criteria, -
divisional power requirements, seismic requirements and environmental qualification requirements o.' the RCIC and RSP except for i
the brief time of the power transfer during a ,
fire event or testing of the transfer switch ,
when separation and divisional power requirements are not met. During this brief 2 time adegrtte protection has been provided to ensure that a fault in the Division 3 circuitry will not affect-the Division 1 power ,
supply.
iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications? !
Answer: No, because neither RCIC nor RSP are used to l ensure the compliance with the safety limits .
I defined in the Unit 2 Technical Specifications. Unit 2 Technical Specifications Sections 3/4.3.2, 3/4.3.5, 3/4.7.3 and 3/4.8.3 were reviewed in making this determination.
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Licarick Gan3 rating Station Unit 2 Annual Plant Modification Report July 1, 1989 Through June 30, 1990 O-.
Page 25 Modifications No.: 5995-2 A. System: High Pressure Coolant Injection (HPCI)
B.
Description:
This modification installs an emergency shutdown switch at the Remote Shutdown Panel (RSP), 20C201, to permit the HPCI system to be shut down quickly during spurious HPCI operation wnen normal HPCI shutdown circuits are disabled.
C. Reason for Changes Spurious HPCI operation could flood the main steam lines and prevent RCIC operation. The objer&lve of this modification is to assure HPCI shutdown capability er.d RCIC availability in case of a fire that requires the RCIC system for safe shutdown.
O-D. Safety Evaluation Summary:
i) Does this modi *ication increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer No, because this modification can only terminate or prevent HPCI operation.
Operation of the new HPCI emergency shutdown switch cannot cause HPCI to spuriously start and cannot initiate any of the accidents evaluated in the FSAR, Section 15.
- 11) Does this modification create the possibility for an accident or malfunction of a different type-than any evaluated previously in the FSAR?
Answer: No, because this modification maintained the design functions, the separation criteria, divisional power requirements, seismic requirements, and environment qualification requirements of the HPCI and RSP. Thus, the olant will operate within the envelope of analyzed conditions and the modification did not create the possibility of an accident or malfunction of a type other than that previously evalueted in the FSAR.
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e LiO3 rick G3noroting Statien Unit 2 Annual Plant Modification Report O '
July 1, 1989 Through June 30, 1990
, Page 26 4.11) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications? ,
Answer No, because this modification did not reduce the margin of safety as defined in the Technical Specification Sections 3/4.3.2, 3/4.3.3, 3/4.3.7.4, 3/4.5.1.
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Litorick Generating Station Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 27 Modifications No.: 5998-2 A. System: Reactor Weier Clean-Up B.
Description:
This modification installs a disconnect switch to prevent opening of valve HV44-2F031 during a design basis fire.
Spurious opening of valves HVC44-2F033, KV44-2F031 and either HV44-2F034 or HV44-2F035 would create a blowdown path from !
the Reactor Pressurc Vessel to either the main condenser or the equipment drain collection tank.
C. Reason for Change !
The objective of this modification is to limit the blowdown :
flow to an acceptable rate, and prevent valve HV44-2F031 from opening inadvertently when the RWCU system is in normal operation. Preventing valve HV44-2F031 from opening during a fire would limit the reactor blowdown rate to a maximum of 110 gpm by flow orifices F044-20001A and F044-2D001B, assuming that the upstream (F033) and downstream (F034, F035) valves would also spuriously open.
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or '
malfunction of equipment important'to safety as previously evaluated in the PSAR? ,
Answer No, because tnis modification provided the capability of disconnecting power to valve HV44-2F031 to prevent an excessive blowdown flow during a fire event in the control room or Unit 2 cable spreading room or~in fire area 70E by installing disconnect switch in fire ,
zone 71A. i
- 11) Does this modification create the possibility for_an accident or malfunction of a different type than any evaluated previously in the PSAR?
Answer No, because the original functional design of the system is unchanged and the system O. function is not included in any accidents evaluated in the PSAR.
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Limerick Ccn0roting Station ;
Unit 2 5 Annual Plant Modification Report !
July 1, 1989 Through June 30, 1990 i
']' _. -
Page 28 ';
iii) Does this modification reduce the margin of safety as.
defined in the bases for the Technical Specifications? .
3 Answer No, because RWCU is not used to ensure the l
~
compliance with the safety limits defined in the Technical Specifications. . The- i modification does not affect any setpoints or [
instrument accuracy and drift requirements defined in the Technical Specifications. The design function of the RWCU will not be
-affected by this modification; therefore, the modification will not cause the plant to . .
6 operate outside normal operating limits. The ,
basis for Technical Specification Sections i
3/4.3.2, 3/4.3.3 and 3/4.7.3 were reviewed in making this determination.
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Licorick Gan3roting Station.
Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 29 Modifications No.: 6001-2 A. System Plant Structures B. Description This modification repositioned an existing double angle brace and added a structural tubing member for Platform 28 inside the HPCI pump and turbine room.
C. Reason for Change:
Implementation of this modification provides proper transfer of lateral loads from the pipe support attachments-to the south wall of the room.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer No, because the platform was designed "Q" because it. supports safety-related equipment.
Existing plant fire protection systems were not adversely affected by this modification because the materials used in the modification meet the original design requirements. The modification to the platform did no' interfere with existing fire protection features,
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?
Answer: No, because the modified platform did not affect the existing plant fire protection systems, and would not support combustion.
This modification maintains the level of safeguard effectiveness required by the current security plan. This modification did not impact any safety-related equipment or O operator response to postulated events.
i7 Limerick 03n]rcting Staticn Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 30 -
iii) Does this modification reduce the margin of safety as defined in the bases'for the Technical Specifications?
Answer: No, because this modification did not reduce the margin of safety as defined in the basis for the Technical Specifications because-there are no Technical Specifications for the platforms and the modification did not affect any safety-related systems described in the Technical Specifications or their basis.
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Limerick Generating Station Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 31
- Modifications No.: 6006-2 A. System: Residual Heat Removal B.
Description:
This modification added a new pressure switch on local instrument rack 206027 which was wired in series with the outboard RHR shutdown cooling isolation valve opening relay.
C. Reason for Change:
The new pressure switch senses reactor pressure and prevents a postulated fire-induced " valve open" signal from causing valve HV51-2F008 to spuriously open while the reactor is at a pressure greater that the design capabilities of the low ll pressure RHR piping.
D. Safety Evaluation Summary:
- 1) Does this modification. increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer No, because the installation of a dynamic and environmentally qualified 1500 psi rated, Class IE, pressure switch in the' instruments header has an insignificant effect on the probability of instrument header failure. The addition of the new pressure switch in the opening circuit of valve HV51-2F008 did not increase the probability of the loss of the RHR shutdown suction line because manual action can be used to open the valve as allowed in FSAR Section 15.2.9 should the pressure switch fall. Since the modification only provided a permissive in the opening circuit for the valve it has not increased the probability of malfunction of the signals used to close the valve in the event high reactor pressure or low reactor level.
Licorick G3norating Station Unit 2 '
Annual Plant Modification Report -
O July 1, 1989 Through June 30, 1990 Page 32 -
~
- 11) Does this modification create the possibility for an accident or malfunction of.a different_ type than any evaluated previously in the FSAR?
Answert No, because no failure mode of this switch creates an accident different from that in FSAR Chapter 15. Since the automatic close signals are not affected, valve HV51-2F008. -
will continue to perform-its safety related functions _as currently designed.
iii) Does this modification reduce the margin of safety as defined in the bases for the Technical-Specificatioits?
Answer: No, because the addition of the pressute' switch does not affect the capability of the RHR system to remove decay heat from the reactor pressure vessel and does not affect-O the overpressurization interlock required for the valve to perform its e,afety functions.
Unit 2 Technical Specifications Sections 3/4.3.2, 3/4.3.3, 3/4.3.4, 3/4.3.7, 3/4.4.9, 3/4.6.3 and 3/4.9.11 were reviewed in making this determination.
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LiCorick G3n3roting StatiCn Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 33 Modifications No.: 6025-2 A. System: Nuclear Boiler ,
B. Descriptions Replace the NUPRO plug valves in the GE Nuclear. Energy supplied H23 instrument racks with the Worcester Control ball valves.
C. Reason for Change:
To increase the integrity of the instrument line pressure boundary, and ensure that the associated instruments will operate 1" accordance with their original design r3quirem? s. These valves provide a means of testing the exces: a check valves (EPCV), and a means to back-fill the
() D.
assock: in instrument sensing line(s).
Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or i malfunction of equipment important to safety as previously evaluated in the PSAR?
Answer No, because this modification did not make any functional changes to the operation of the EFCVs or to the instruments on the lines to:
which the test valves are connected. The new test valves are.Q and rated for the design temperature and pressure conditions. They are environmentally qualified. The pressure boundary function of tha test valves will be .
maintained, and the operability of the l instruments will not be affected-under any 1 circumstances by installation of these test i valves. FSAR Section 6.2.4 was reviewed in making this determination.
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Limerick G3n3 rating Station Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990
, Page 34 -
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?
Answer No, because no functional changes were made to-the primary containment. Replacing the existing test valves with the new test valves increased the integrity of the instrument line pressure boundary. This ensures that the associated inst.ruments will operate- in accordance with their original design requirements.
iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?
Answert No, because-providing a Q test valve will maintain the margin of safety as defined in O the basis for Technical Specification Sections 3/4.3 and 3/4.6.3 since it will ensure the integrity of the pressure.
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Linorick Gonorating Station Unit.2 Annual Plant Modification Report O July 1, 1989 Through June 30', 1990 Page 35 -
Modifications No.: 6031-2 A. Systemt 480V System B.
Description:
This modification replaced the time delay undervoltage. relays in the load center circuit breakers 52-20124, 52-20134, 52-20224 and 52-20234 with instantaneous undervoltage relays.
C. Reason for Change:
The time delay undervoltage relays did not operate satisfactorily and were-inconsistent in providing the desired time delay.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer: No, because this modification prevented the undesirable tripping of the load center breakers due to. inconsistencies in the timing of the time delay undervoltage relays.
Replacement of the time delay undervoltage relays with instantaneous relays did not affect any Plant safety function. It restored the load center circuit breakers to their original design which did not affect the tripping function of the circuit breakers.
Isolation of the non-class IE from Class IE power sources has been maintained. This modification did not affect the functior or performance of any equipment or system in the plant.
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Liocrick con 3rcting Station Unit 2 Annual Plant Modification Report July 1, 1989 Through June 30, 1990 O.
Page 36 -
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the PSAR?
Answert No, because the trip function and isolation requirements for the circuit breakers has.not been affected. The modification has not altered the design function or design criteria for any systems. Therefore, no new failure affects have been introduced into those systems and the plant transient analysis identified in Chapter 15 of the FSAR has not been impacted.
111) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?
Answer No, because this modification did not alter or change the operations of any safety related O- systems. The margin of safety has, therefore, 1
{
not been reduced. Unit 2 Technical Specifications Sections 3/4.6.5 and 3/4.8.3 were reviewed in making this determination.
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Lim 3 rick Gon3 rating Station Unit 2 Annual Plant Modification Report O .
July 1, 1989 Through June 30, 1990 Page 37 -
Msdifications No.: 6038-2 A. System Residual Heat Removal Service Water (RHRSW)
B.
Description:
This modification installed and connected a new instrument cable between Remote Shutdown Panels (RSP) 10C201 and RSP 20C201 to transmit the Residual Heat Removal Service Water (RHRSW) system Loop A pump common discharge header pressure signal from Pressure Indicator (PI) PIl2-001A-2 to PIl2-001A-3. Also, the existing wiring associated with PIl2-001A-3 in RSP 20C201 has been modified to enable operation of PIl2-001A-3.
C. Reason for Change:
O To transmit the RHRSW system Loop A common discharge header pressure signal from P112-001A-2 to PIl2-001A-3.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident.or
- malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer: No, because the addition of the instrument cable provided the RHRSW pump discharge pressure signal to PI12-001A-3 located on RSP as required by the original design intent.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?
Answer No, because implementation of this modification introduced no new failure modes.
The existing func~lonal logic and control of the RHRSW system c mponents continues to meet the applicable design criteria of the RHRSW system.
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Licorick G3nerating Station Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 38
- iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?
Answer No, because the function of the RHRSW system was unaffected by.this modification.
Technical Specification Section 3.7.1 was reviewed in making this determination.
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Licorick Conoroting.stotien Unit 2 Annual Plant Modification Report July 1, 1989 Through June 30, 1990 O' .
Page 39 Medifications No.: 6039-2
/
A. Systems Containment and Leak Testing B.
Description:
This modification extends the test connection piping for the containment personnel air lock beyond the shield doors.
C. Reason for Change:
The relocation reduces personnel radiation levels incurred on a six month schedule during the Local Leak Rate Test (LLRT);
thus keeping exposure ALARA. Prior to the relocation, the test connection was accessible only by opening the radiation shield doors. This modification made the test connection accessible to PECo's LLRT Group which is responsible for O testing it on a six month schedule while the plant is operating, in accordance with Plant Technical Specification 3/4.6.1.3.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer No, because this modification improved the ALARA features of the plant by reducing the potential for worker's radiation exposure during LLRT testing. The relocation of the LLRT test valve did not change the results of the pressure testing of the containment personnel air lock. No change was required to the design bases and system description of any systems discussed in the PSAR except for Figure 6.2-47. Section 6.2.6.2 has been reviewed to make this determination. The relocation of the containment personnel air lock LLRT valve therefore will not become a source of an accident or malfunction nor will it become a source of an accident or O- malfunctions of safety equipment, the new components have been manufactured and installed in accordance with existing design criteria for the subject system.
Limerick G3norating Statien Unit 2 Annual Plant Modification Report O July 1, 1989 Through June 30, 1990 Page 40 -
e t
- 11) Does this modification create the possibility for an
' accident or malfunction of a different type than any evaluated previously in the PSAR?
Answer No, because the new design of the containment personnel air lock LLRT. connection enables the manuall'1 operated valve to be accessible without the need to open the radiation shield-doors. This reduces the potential for worker radiation exposure,'thus improving.the ALARA features of the plant.. The plant fire protection features have not been affected by-this change.
In addition, the plant hazards analysis and ,
safe shutdown analysis have been reviewed'and are not affected by the relocation of the subject LLRT valve. This modification has O
been implemented in accordance with existing design criteria for the subject system.
Finally, Modification 6039-2 does not require a change to any design basis or system description of any system described in the PSAR except for Figure 6.2-47. Section 6.2.6.2 has been reviewed in making this determination.
iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?
Answer No, because the LLRT is required by. Technical Sp9cification Section 3/4,6.1.3. This modification did not affect compliance with this requirement. This change improves the ALARA features of the plant. In addition, the relocation of the subject LLRT test valve did not adversely affectLany plant safety system, structure or component as described in the Unit 2 Technical Specifications. Section 3/4.6.1.3 of the Technical Specifications and its bases have been reviewed to make these determinations.
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0 Licorick G3norating Station Unit 1 Annual Plant Modification Report July 1, 1989 Through June 30, 1990 O. Page 41 '
Modifications No.: 6108-1
- a. System: 250 V DC System B.
Description:
This modification replaced underrated fuses in 125/250V DC- "
MCC and panels with properly rated fuses. This modification also added a second set of fuses / fuse blocks for the HPCI/RCIC nonsafety-related pump motors.
C. Reason for Cha,nge:
This modification brought the modified equipment into :
compliance with the original design intent.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?
Answer: No, because this modification did not increase the possibility of operational transients, abnormal operational transients or any other design basis accidents. This change will have no impact on the accident analysis described in the FSAR Chapter 15.
This modification did not alter any assumption previously made in evaluating or mitigating the radiological consequences of an accident as described in the SAR.
This modification did not result ir any configuration where an accident iritiator not considered in the SAR is created.
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Litorick 00nerating Station Unit 1 Annual Plant Modification Report July 1, 1989 Through June 30, 1990 O.
Page 42 -
- 11) Does this modification create the possibility for an .
accident or malfunction of a different type than any' evaluated previously in the FSAR?
Answer No because'the use of properly rated fuses restored equipment and cable protection to within the design requirements. Use of redundant fuses on the non-Class lE HPCI and RCIC Condens r and Vacuum Pumps assures Class 1E/non-Class 1E independence. This modification did not increase the frequency or operation of any equipment or systems important to safety nc* did'it degrade.the system performance necessary for reliable operation of the equipment. FSAR Sections 8.1.3 and 8.3.2 were. reviewed 11n making this determination.
O- lii) Does thic modification reduce the margin of safety as !
defined in the bases of the Technical Specifications?
Answer No, because this modification did not ,
adversely affect any considerations covered in I the Technical Specifications nor did it affect any of the limiting conditions for operation or surveillance requirements related to the 125/250V DC Power Distribution' System as described in the Technical Specifications.
The changes as described in the modification do not alter the intended function of the systems involved, nor do they affect the' safe shutdown of the plant as described in the SAR.
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Lim 2 rick'G2nsrcting Station Unit 0 Annual Plant Modification Report- i
/^ July 1,-1989 Through June 30, 1990
( .
Page 43- 0
, Modifications No.: 9071-0 A. System > Mmergency Service Water and 4 esidual Heat Removal Service Water B.
Description:
This modification rerouted safety-related cables and added fire barriers on certain electrical raceways.
C. Reason for Change:
To ensure the capability to monitor system 1 pressure'and/or .I system flow rate for ESW and RHRSW systems is retained in the
- event of a fire.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of-an accident or malfunction of equipment important to safety as- 1 previously evaluated'in the FSAR? '
Answer: No, because.this modification involvedi the i addition of fire barriers on existing-electrical raceways. The only potentially- ,
detrimental'effect of adding such fire
! barriers is-the increased weight on the
! raceways. The design of the supports.for each raceway affected by the fire-barrier addition .
has-been checked to verify.that the existing. i supports are adequate to accommodate the l increased weight. The only physical changes t
involved in this' modification other than'the '
addition of fire barriers on existing raceways were-(1) rerouting of three safety-related ,
cables, (2) installation of' conduit <lAI220, (3) addition of a 3-hour rated fire. barrier on t conduit 1AI220, and (4) provision of a penetration seal in the new-penetration througn the wall between the auxiliary equipment room and the remote shutdown room.
l((7)
These changes did not increase the probability of-occurrence orithe severity of the consequences of any postulated accident or ;
malfunction.
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L .l Liesrick G3norating Stction Unit 1 i
Annual PlantlModification Report ]
('T . July,1,J1989 Through' June 30, 1990- ;
as _/ '
Page 44' i 1
11)- Does this modification create the possibility for an accident or= malfunction of_a different type than any ,
i evaluated previously in the FSAR? i Answeri No, because this modification involved the j addition of fire barriers on existing electrical _ raceways. Thelonly potentially l
detrimental effect of adding such-fire barriers is the increased weight on the- ;
raceways. The. design of theLsupports for each raceway affected'by the fire: barrier addition has been checked ~to verify that the existings supports are adequate-to-accommodate the increased weight'. ~The only. physical changes involved in this modification other than;the addition of fire barriers on existing raceways ;
-were (l~)Lrerouting of'three safety-related cables, (2): installation of conduit'lAI220,
[h
%2 (3) addition of a 3-hour rated. fire barrier on conduit 1AI2120, and (4) provision'of a penetration seal in-the new penetration i
through the wall between the auxiliary equipiaent room and the. remote- shutdown ~ room. 1 These changes do.not introduce the potential t for failure modes that-have notLbeen evaluatedi oreviously. 1 111- ~$9 .... _adification reduce the margin of safety as i
- v. the bases for the= Technical' Specifications?
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Jo, because none of-the Technical I
Specifications contain': requirements lrelated to (1) the identification of systems andi components that are essential for safe
, shutdown,_or (2)lthe degree of fire _ protection ,
that is-to be provided'for_ cables associated !
with such systems and components.-
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Lim 3 rick G3norcting~ Station- ;
Unit 0 i Annual Plant Modification Report f#T : July:11, 1989 Through' June 30, 1990
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. Page 45 -
i Modificatings_3ogy '9072-0 i A. Sj;pj.jgst Residual Heat Removal Service Water :
B. Descriptions ,
This modification involved-the following changes:
- 1. Transfers the Class-IE 480V AC power oupplies for common MCCs 00B5212C and 00B522ZD from Unit I load- J l
centers to Unit 2 load centers.
- 2. Transferred the Class IE'125 V'DC control power . i supplies from Unit 1.DC panels to Unit 2 DC panels-for' !
'the following motor operated valvest. HV12-003C, HV12-031C, HV12-032C,:HV12-ll3 and HV12-ll4.
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- 3. . Transferred annunciation and 1ndication from panels
\ s# 10C601,.1CC861, IDC861 to panels.20C601, 2CC861 and
-2DC861. .,
The above changes configured the'ESW and RHRSW-systems essentially the same in each unit.
C. Reason for Change:
1 To split the common loads'for ESW and RHRSW systems between Unit 1 and Unit 2 power supplies, as intended:in.the original design.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability-of occurrence or the consequences of an accident or malfunction of equipment important to safety as ,
previously evaluated in the FSAR?.
Answer: No, because this modification only transferred-
~
from Unit l to Unit 2 the source of the Class ;
IE 480V AC power supplies for MCC 00b521ZC and' '
L 00B522ZD and the Class IE 125V.DC control t power for the motor operated valves listed in
/~N B.2 above.
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Litorick!Ghn3rotingLStation Unit ..
. Annual-Plant Modification Report !
jy July 1, 1989'Through-June 30, 1990 .
(_)- . ,
Page 46 'l
-11) Does this modification create the-possibi'lity for an h accident or malfunction of a different type:than any~ .
i evaluated previously-in'the FSAR?_
t
' Answer: No, because this modification'onlyEtransferred f from Unit 1 to Unit 2 the source.of the' Class l IE'480V AC power supplies 1for MCC.00B521ZCland' ,
00B522ZD and thelClass IE 125V DC control ,
power for the motor operated valves' listed in-B.2 above.
lii) Does this modification reduce-the margin of safety;as- 3 defined in the bases'for the Technical Specifications? y i
Answer: No, because the RHRSW, ESW, and Unit.lfand 2 ,
Class IE 480V AC and-125V>DC electrical' . l systems still meet.all-their original' design.
requirements and che capacity to perform their.
safety-related functions. Technical O'.
Specification Sections =3/4.7'.1.1,1 3/4.7.1.2, 3/4.8.1,-3/4.8.2, 3/4.8.3 and.3/4.8.4.were :'
reviewed in making this determination.
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Lim 3 rick G;norcting Station-Unit 0-Annual Plant Modification Report
, -July 11,;1989' Through June 30, 1990 Page 47l '
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Modifications No.:~ -9075-0 A. System: Residual Heat Removal Service Water B..
Description:
1 This modification' transferred the.125VDC control power,ofs j RHRSW/ESW-Loop B to Unit 2 cooling-tower shutoff valve;HV12-- !
211 from Unit 2 12$VDCfdistribution systemJpanel 2BD102 to Unit 1 125VDC distribution: system panel 18D162.
C. Reason for Change j To be in accordance with the' design basis of having both the motive-and control power'fromlthe-same unit (Unit 1).
D. Safety Evaluation Summary:-
- 1) Does this modification increase 1the probability of occurrence or the consequences of:an accident or 4 malfunction of equipment important to safetyias; previously evaluated in the FSAR?-
Answer: No, because this_modifibationLprovidedLUnit-1 125VDC power for thescontrol circuitry of (
RHRSW/ESW. Loop'B to Unit.2 cooling; tower shutoff =MOV valve HV12-211.which is-in accordance with the design basis of having both the 440V motive power and the control power from the same. unit (Unit 1).
1-1) Does this modification create the possibi'lity for:an f accident or malfunction of a different type:than any evaluated previously in the FSAR?
Answer: No, because the existing design'had the 440V /
motive power _from Unit:1 MCC 00B52ZB and'the j 125VDC power for control circuitry from Unit 2 ~
L 125VDC distribution panel 2BD102 which was not 4 in accordance with the design basis.
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l LicSrick G3nsroting Station J Unit:0-Annual Plant 1 Modification Report ')
July.1, 1989 Through June'30,t1990
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, ) , Page 48
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t 111) Does this modification reduce the. margin!of safety as -!
defined-in the bases for the Technical Specifications? ;
Answer:- No, because this modification'provided 125VDC power, panel 1BD162 for the' control circuitry
~
of MOV-valve RV12-211'so that both the motive and theLeontrol-power'for-the valve'are fed from the same unit 1(Unit 1). Technical:
Specifications 3/4.7.1 andc3/4.8 were reviewed in making.this determination.
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Licarick Ganarcting Station !
Unit 0 ,
Annual Plant Modification Report--
July 1, 1989 Through June ~30, 1990
(_ .
Page 49=
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l Modifications No.: 9076-0' ~
L A. System: Emergency Service Water.
B. Description
.This modification provides a redundant' remote shutdown capability by installing a local control for Emergency Service Water (ESW) pump motor OCP548. '
C. Reason for Change: ,
This modification increased the.overall capability of the ESW l to satidfy the needs of-both Units 1 and 2 by making 3 ESW-pumps available for supplying cooling: water totthe emergency i diesel generators and the residual heat removal (RHR) systems -i lube oil and seal coolers 1n the event that evacuation of-the
~
control room is necessary.
(
D. Safety Evaluation Summary:
- 1) .Does this modification increase the probability of occurrence or the consequences of ansaccident'or.
malfunction of equipment important to safety:as -
previously evaluated in the FSAR?
-Answer: No, because previous evaluations. assumed;only .t 2 ESW pumps could be. operated from remote locations.. Since this modification added a-third remotely operable-ESW pump ~, a decrease should occur in the consequences of accidents or malfunctions of equipment related to safety as previously evaluated in the FSAR.
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h 1 Lim 3 rick G3nsroting Station.
. Unit 0-Annual Plant Modification Report 1
('\ ; -
July 1,f1989 Through June _.30,-1990--
- (,) - Page 50-A i
11)l 'Does this modificationLcreate--the possibi11ty for-an' accident or malfunction of aLdifferent type than any , ,
l- evaluated previously in the FSAR?
Answer: No, because a failure of the'added transfer-andicontrol switch for ESW pump OCP548 would i not prevent ESW pump OAP548 from being-
. remotely controlled to provide cooling for- ,
. Unit-1 and Unit.2:RHR; pumps, LAP 202 and: . '
2AP202, which is the presently-evaluated' condition in the FSAR., Thesadded cabling.did.
not create theLpossibility for.an accident:or.
malfunction'of'a different type than that previously: evaluated'inithe FSAR'since a failure of the added' cabling would not affect- 1 adjacent cables and_would cause~ annunciation I in the main ~ control room'as'a fail-safe'
. indication. .
( i
\ Does this modification reduce!the margin of. safety.as lii) defined in the bases for the Technical Specifications?
Answer: No, because the only transfer and control switch for: ESW pumps described. in the'
' Technical Specifications is OAP548,-the-modifications put:forth previously in:this j safety' evaluation will'not result in a change to the Technical Specifications, i.e. the ;
Technical Specifications:for remote' shutdown ':
system instrumentation and controls'do.not 4 mention OBP548 and should not mention OCP548 -
since they are:both local controls and not on (
the remote shutdown system (RSS) panel.' ;
Technical Specification 3/4.3.7.4, 3/4.7.1.2 I and bases 3/4.3.7.4 and 3/4.7.1.2_were
, reviewed in making this determination.
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-Lim 3 rick G9narcting Station.
Unit.0 Annual Plant Modification Report
( July 1,11989 Through June 30, 1990-(V 5
Page 1 l
Modifications No.: 9083-0 f
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I A.- System Residual-Hoat Removal Service Water l B.
Description:
This modification changed the RHR heat 3 exchanger discharge valves HV51-lF068A&B limit switch CAM positions from 20%.and '
i 25%, respectively, to full open position. In addition, the Loop A valve HV51-1F068A' time delay will be_ reset from 80 ,
seconds to 85 seconds.
C. Reason for Change:
To allow valves HV51-lF068A&B-to'be opened fully to. achieve:
the required flow-during two unit operation.
b)\~
D. Safety Evaluation Summary:
- 1) Does this modification increase-the probability of l t
occurrence or the consequences-of an accident.or malfunction of equipment importantito safety 1as previously. evaluated'in the FSAR? ;
Answer: No, because this-modification made no functional change to Unit 11 Land common ESW and RHRSW systems. The.UnitJ2" portions'of=the ESW and RHRSW'were designed, installed and: tested to the same specifications as Unit 1 and common portions of'the systems.
- 11) Does this modification create thefpossibility for-an acciden; or malfunction of a different type.than'any evaluated previously.in the FSAR?
Answer: No, because changing:the time allowed to close the discharge valve does not affect-other systems.- The RHRSW system-is,still protected from overpressurization from the'RHR system since the-discharge valve still closes after the inlet valve.
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k- 4 ** n Lim 3 rick Gan3 rating . Station- ]
Unit 0- ,
- Annual Plant Modification' Report-
. July:1, 1989 Through Junes30s 1990-Page 521-
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l: .lii) Does this. modification reduce the, margin of' safety-as .
defined in the bases for the Technical Specifications?:
- Answer:
No, because the units can still.be safely shut l down by> adjusting the RHRSW' discharge' valve ;
1 position to achieve required flow to:the RHR heat exchanger. , Technical. Specification-Sections 3/4.3.7(3.3.7.4),'3/4.3.7.11,-
3/4.4.9, 3/4.5, 3/4.7.1.1, 3/4.9.11 and. .
3/4.11.1'were' reviewed in making this determination.
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