ML20079G256

Changes,Test & Experiments,1980

ML20079G256
Person / Time
Site:	Indian Point
Issue date:	05/24/1982
From:	CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML20079G250	List: ML20079G247 ML20079G256
References
NUDOCS 8206080371
Download: ML20079G256 (15)

Text

s INDIAN POINT UNIT NO. 2 CHANGES, TEST AND EXPERIMENTS - 1980 1.

Relocation of Potentiometer "IP" at Battery Charger The original location of the potentiometer "IP" pre-vented the charger output voltage from being regulated under load conditions.

The door on the charging cabinet had an interlock that tripped the charger when access to the potentiometer was made.

This modification relocated the potentiometer from inside the charging cabinet to a lockable box outside the cabinet.

The relocation of the potentiometer does not affect the capacity or function of the batteries or their supply circuits.

This modification will not change any safety or non-safety functions that the batteries are required to perform.

The charging circuit was not changed.

The only change swas b1 the physical location of the potentiometer.'

Thus,,

the probability of occurence or.the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased.

There is no change in equipment or the method in which the existing equipment works.

The only change was in physical location.

Therefore, the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created.

The Technical Specifications require that the station batteries be tested periodically.

This modification will not change the ability of the batteries to be tested but will aid in the ease of doing the tests and of proving the operational readiness of the batteries.

Thus, the margin of safety as defined in the bases for any technical specification is not reduced.

Therefore, this modification was deemed not to involve an unreviewed safety question.

2.

Reactor Coolant System Level Monitoring System for Cold Shutdown Condition The purpose of this modification is to improve Reactor Coolant System cold shutdown level indication.

The pre-vico ; sys tem e:merienced a tirm lag during level changes dee to the weir action ot tne Reactor Coolant Pump casing adapter and diffuser.

8206080371 820524 PDR ADOCK 05000247 R

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The RCP casing adapter and diffuser acts as a weir to impede back flow through an idle pump. As a result, the reading on the local level indication tuce during transient conditions may not be a true reflection of system level.

To climinate this inherent time lag, a new level in-dication path was connected to an existing tap connection off the loop #21 hot leg.

Use of the level indication system is limited to the cold shutdown condition.

Since the new piping runs are isolated from the primary loop at all other times by at least two normally closed valves, no concerns involving plant opera-tion are raised.

Failure during cold shutdown could yield a maxiumum flow (assuming a guillotine break) of less than 50 gpm.

Such a loss can be handled by the normal makeup process and operator action to terminate the leak can be initiated prior to any significant loss of coolant.

The new system provides a truer indication of RCS water level during shutdown conditions.

The probability or consequences of any small break loss of coolant accident is not increased.

No other postulated accident is affected by this modification.

Si'nce the new installation is isolated from the primary system when it is at pressure and will have no effect at any time on the functioning of any other" system, no new type of accident is created by this modification.

The cold shutdown RCS level indication system is not addressed in the Technical' specifications.

It is concluded that this modification does not involve an unreviewed safety question.

3.

W-2 Switch Modification As outlined in a Westinghouse Technical Bulletin NSD-TB-80-9 and later in NRC Bulletin 80-20, the remote possibility exists that the W-2 type switches, when returned to their auto position, might not have all their safeguards contacts "madeup".

This modification provides visual means of en-suring the contacts have engaged.

This modification involved installing lights energized through the contacts of all safeguards W-2 switches.

The lights indicate if the contacts have "madeup" after the switches are returned to their " Auto Position."

There are approximately 47 lights installed for'38 switches behind the control panels SA & SK in the control room. - - _

The indicating-lights do not affect the operation of the existing switches.

The resistance across the new lights approximately 160 K onns which produces a current at 125 volts of 0.8 ma.

Thus, the current through the contacts due to the addition of the lights is negligible.

Failure of the lights would not affect the safety function of the switches.

If the light circuit failed "open", the light would go out alerting the operator to no indication.

If the light shorted to ground it would blow the existing circuit protection causing all the existing switches '

position indicating lights to go out, again alerting the operator to a malfunction.

Both failures are highly un-likely due to the simplicity of the circuit, the reliability of the indication system and the Class A & Class IE install-ation.

These indicating lights assist in assuring that the require-ments of all technical specifications are met.

The new indicating system is an added measure to assure the CCR operators that all necessary safeguards equipment, as de-fined in the bases for any Technical Specification, is in its proper safeguards position.

Thus, the margin of safety as defined in the, bases for any technical ~ specification is not reduced by, the addition of this modification.

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Therefore, this change was deemed not to involve an un-reviewed safety question.

4.

RCC Change Fixture Modification The RCC Change Fixture'is mounted'on the reactor cavity wall and is used in removing rod control cluster and spider mounted secondary source assemblies from spent fuel assemblies and inserting them into the new or partially spent fuel assemblies.

The fixture consists of two main components: a guide tube mounted to the wall for containing and guiding the RCC element and a wheel mounted carriage for holding the fuel assemblies under the guide tube.

The guide tube is stationary and permanently fixed to the cavity wall.

The RCC Change Fixture gripper is raised and lowered in the guide tube by a cable hoist.

Since the LOPAR fuel assembly is 3" higher than the HIPAR fuel assembly, the rod cluster control spider will sit 3" higher in the fixture and the present guide tube would inter-fere.

Therefore, the guide tube was cut 5" to provide for clearance.

In addition, the Up-Travel Limit Stop for the gripper assembly has been adjusted to the new elevation.

Since the modification of the RCC Change Fixture does not change the function or the location of the equipment, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased.

Since the modification will prevent interference with any other equipment the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created.

It has been determined that the margin of safety as de-fined in the basis for any Technical Specification is not reduced by this modification.

Therefore, the modification was deemed not to involve an unreviewed safety question.

5.

Removal of the Old Gripper and Installation of a New Gripper for the Manipulator Crane to Accomodate Both HIPAR and LOPAR Fuel The gripper assembly is used to place fuel elements in a"r the core, remove them and transport them between the' reactor vessel and the fuel transfer system.

+The. gripper is air operated with air pressure needed to-S' 2 I" e disengage the fingers, which are moved from their engaged to disengaged position by a cam.

The HIPAR/LOPAR gripper cam position is determined by a piston that is moved pneumatically in the same way the HIPAR gripper was activated.

The modification involved removal of the HIPAR gripper and installation of a new gripper designed to handle both HIPAR and LOPAR Fuel.

The new gripper assembly has been tested with all HIPAR and LOPAR types of nozzles and load tested to 150% of I

the load the gripper will actually carry.

Since the new gripper performs the same function as the old equipment, the probability of occurrence or the con-sequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report will not be increased.

Since the new gripper does not interfere with any other W u 19.:.un t, the u sibi.lity for an accident or malfunction at a different type than any evaluated previously in the safety analysis report will not be created.

Since there are no Technical Specifications concerning the gripper assembly, the margin of safety as defined in the basis for any Technical Specification is not reduced.

Thus, this modification was deemed not to involve an unreviewed safety question.

6.

Installation of Limit Switches on Valves CT-6 & CT-64 This modification involved installing limit switches on the Condensate Storage Tank discharge valves CT-6 and CT-64.

Both valves are manually operated; CT-6 is a butterfly type and CT-64 a gate type. The switches will alarm in the CCR should a valve be closed to alert the operator that the primary suction path for the Auxiliary Feedwater Pumps has been interrupted.

The switches, position indicator lights and alarms have no control over Valves CT-6 and CT-64.

Before this modification, the valves were locked open and had no remote position indication.

This modification ensures that the CCR operator knows the position of valves CT-6 & 64 during all plant conditions.

This modification'does not change the pressure boundary or.

path for any fluids outside containment.

Previously the valves' were normally open and this ' modification does not

' - change that configuration.

To close either valve will require a deliberate act in the same manner as it would

-have previously.

Thus, the probability.of occurrence or the

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' consequences of an acci, dent or malfunction of equipment important to safety previously evaluated in the safety analysis report will not be increased.

The addition of remote position indication allows for safer control of the system's valves.

With remote indication, the position of the valves can be easily checked during any plant or accident condition.

Therefore, the possibility for an accident or malfunction of a different type from any evaluated previously in the safety analysis report is not created.

The present Technical Specifications address the specific system in which these valves are located.

The addition of the valve position indicators to the above mentioned valves will not change any of the test or post-critical parameters as described in those sections.

These remote indicators will, in fact, make it easier to verify com-pliance with the requirements.

Thus, the margin of safety as defined in the bases for any Technical Specifications will not be reduced.

T h r., thic r.cdi fication was decre d not to involve an un-reviewed eatety question.

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7.

Auxiliary Feedwater Regulating Valve Power Supply Modification The coject at nis acdit:ication was to provide independent Class IE power sources to the auxiliary feedwater flow control valve controllers.

The following auxiliary feedwater valves controllers were disconnected from 120-volt A.C.

lighting bus 21 and moved to the vital 120 VAC Instrument Buses as outlined below:

Instrument Bus Flow Control Valve - Aux. Feed System No. 21 FCV-405A No. 22 FCV-405B No. 23 FCV-405C FCV-406A FCV-406B No. 24 FCV-405D FCV-406C FCV-406D

~ The flow control valves for the motor driven auxiliary' feed-'

water pumps are powered such that a single failure would not cause failure of both motor-driven trains of auxiliary a

feedwater.

.The feedwater flow control valves control power.is arranged

. " red such that if'one instrument bus were to fail, power for the secondary motor-driven pump and associated FCV controllers would be available.

The power supply for the FCV controllers is backed up from both the emergency diesels and the station batteries.

The turbine-driven auxiliary feed pump has its associated FCV controllers powered from four separate instrument buses such that a single failure would only affect one of four flow paths of turbine-driven auxiliary feedwater.

The instruraent buses themselves have been evaluated for the addition of the auxiliary feedwater valves load.

The evaluation has shown adequate capacity such that no over-load of the existing buses will occur.

The transfer of the auxiliary feedwater flow control valves controllers frotu one bus to several instrument buses results in an a marked increase in the reliability of the system.

The buses that the valves were transferred to have adequate reserve capacity such that no overload will be produced on a safetv o r.v : e.

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Thus, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased.

The modification does not change any of the functions or paths for fluids in tne Auxiliacy Feedwater System.

The changes are to the power supplies to the. controls for the valves.

The new power supply arrangement ensures that power to the valve controls is single failure proof.

Therefore, the possibility for an accident or malfunction of a different type from any evaluated previously in the safety analysis report is not created.

The operational requirements for the Auxiliary Feedwater System are discussed in the Technical Specifications.

This modification will aid in assuring that those requirements are met'; thus, the margin of safety as defined in the bases for any techncial specification will not be reduced.

This modification was deemed not to involve an unreviewed safety question.

8.

Separation of the Auxiliary Feedwater (A.F.W.) Pumps, Common Actuation Logic into Two Logics, Both Actuating Each Pump.

The purpose of this modification was to eliminate the possibil-ity.of a single failure defeating the A.F.W. pump actuation logic.

The common actuation logic for motor-driven A.F.W.. Pumps'.#21 A"t and #23 has been s'plit into two independent and redundant actuation logic systems'.

The new logic systems are the same as the present common logic system with the exception that instead of pump actuation on undervoltage of both buses 5 and 6, actuation occurs on undervoltage of either bus 5 or bus 6.

Each new system will be capable of starting both pumps with Safety Injection and Blackout delay logic re-maining the same in the two systems.

This modification consists of (1) changing the present common logic system into a single logic system by rewiring the undervoltage contacts for buses 5 and 6 from a series path to a paral-1el path and eliminating one of the actuation signals for loss of a Main Feed Pump (MFP) and (2) installing, as a redundant system, a new logic system identical to the modified logic and utilizing the loss of M.F.P. actuation signal previously eliminated from the common logic system.

The two logic systems are supplied from Instrument Buses #21 and #22 and are Class IE.

The two independent logic systems will also provide redundancy for the required actuation signals for steam driven AFW pump #22..

Changing the actuation signal on undervoltage of Buses 5 and 6 frcm a.serica mode to a parallel mode and sep-arating the common actuation logic system into two redundant systems protect the A.F.W.

system from single failure and improve system reliability.

The basic function of this system, (which is to provide an automatic actuation signal on (1) loss of off-site power without S.I.,

(2) loss of either main boiler feed pump, (3) low-low level in any one of the four steam generators, or (4)

S.I.

signals) will remain the same. Since the new actuation logic systems remain Class IE, the seismic I capability of the system will not be degraded.

Inasmuch as this modification protects the A.F.W.

System from single failure and improves its reliability, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report are decreased.

The basic function of the actuation system remains un-changed so that the possibility of an accident or mal-

., function of a.different type from any evaluated pre-viously in,the safety analysis. report is not created.

The margin of safety as defined in the basis-for any Technical Specification is not affected by this mod-ification.

Therefore, the separation of the common actuation logic of the motor-driven A.F.W.

pumps into two logics, both actuating each pump, is deemed not to involve an unreviewed safety question.

9.

Installation of New Motor Control Center No. 28A in Containment The purpose of the new Motor Control Center (MCC) is to provide redundant or back-up power for equipment in the containment building.

The new MCC is to be connected to an existing breaker position via cable, on the 480V switchgear located on 15' elevation of the control building.

Previously l

MCC 28 was the sole source of power for the fans that cool the control red drive system inside containment. MCC 28A provides a second source of power for these fans.

The MCC's are independent of each other and interlocked so as to prevent parallel operation.

This redundant source, l

MCC 28A, represents an inherent improvement.

The installation of an additional MCC has been analyzed

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ter=:nc that it does not:

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(1)

Increase the probability of an occurrence or the con-sequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report.

(2)

Create a possibility for an accident or malfunction of a different type from those previously evaluated in the safety analysis report or reduce the margin of safety as defined in the bases for any Technical Specifications.

Therefore, the modification does not constitute an unreviewed safety question.

10.

MS-68A Valve on Steam Generator #21 This modification eliminates the Steam Generator (S. G. )

shell side drain line to the blowdown line to prevent leaks.

The MS-68A valve and a portion of S.G.

1. 21 drain line to the blowdown line has been removed and the blowdown connection capped.

The only function of this drain line was for maintenance

@ si work and it was kept closed during S.G.

operation.

s.

The Steam Generator can be drained utilizing the blowdown 2,

lines.

The closures are capable of withstanding' secondary D

side pressure so that the integrity of the S.G.

pressure boundary is maintained.

Removal of the MS-68A valve and ~

' Ja portion of.the line does not~de' grade the seismic I'

.' capabilities of the blowdown. lines.

Since the functional capability and the integrity of

' Steam Generator #21 was not affected by this modification, the probability of occurrence or the consequences of an accident or nalfunction of equipment important to safety previously evaluated ix the safety analysis report is not increased.

This' modification has no adverse effect on the seismic I capability,of the-blowdown line so that the possibility for an accident or malfunction of a different type from any evaluation pr'eviously in the safety analysis report will not be created.

iThis' modification is not involved with any Technical

,Specificati6a.

Therefore, the margin of safety as de-findd in the basis tar any Technical Specification is not reduced.

It is concluded that this modification was deemed not to

' involve an unrevitwed sgfety question.

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11.

Installation of Electric Auxiliary Feedwater Flow Indicating System Replacing Previous Pneumatic System This modification replaced the pneumatic auxiliary feed-water flow indication with new electric transmitters, power supplies and indicators.

As with the previous system the new transmitter rack is located in the auxiliary feedwater pump rocm.

The indicators and the new power supplies are located in the CCR.

The qualification tests consisted of radiation, seismic, and steam / chemical tests.

This modification has been analyzed to determine that it does not:

1-Increase the probability of an occurrence or the consequences of an accident or mal-function of equipment important to safety as previously evaluated.

(This modification decreases the chances of malfunction by replacing the less' reliable

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pneumatic system with a more reliable elec-trical system).

2-Create a possibility for an accident or' mal-function of a different type than those pre-

. viously.. evaluated in the. safety analysis g v.94 4 4...

report.

3-Reduce the margin of safety as defined in the bases for Technical Specifications.

Therefore, this modification was deemed not to involve system increases protection).

12.

Freeze Protection for Instrumentation on the Condensate Storage, Refueling Water, and the Primary Water Storage Tanks The purpose of this modification was to improve the existing freeze protection for the level instrumentation on the Refueling Water Storage Tank, the Primary Water Storage Tank and the Condensate Storage Tank.

This modification consisted of the following:

1-Provide suitable outdoor insulation for the impulse piping, tubing and instrument enclosures.

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2-Weather-proofing and thermostatically controlled l

heating ele:nonts for the instrument enclosures.

3-Dual heat tracing for all the instrument impulse tubing.

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4-Low temperature alarms to alert the operator of l

any instrument heat trace failure or low temper-ature in the instrument enclosures.

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The replacement of the existing freeze protection (heat trace) with redundant heat trace brings the instrumentation lines freeze protection up to the same standards as are used on the boric acid piping systems heat trace.

The redundant heat trace will allow switchover, without removal of the line insulation, should the primary heat trace fail.

The heating and weather-proofing of the external in-strument cabinet will help insure controlled temperature for the existing tank level instrumentation.

Thus, the new freeze protection for the instrument lines and cabinet will improve the reliability of the' level instrumentation on the tanks.

Inasmuch as the freezing of the level instrumentation lines will be less likely with the upgraded freeze protection and the external level instruments will be better protected by the new weather resistant cabinets,_the probability "y"y

'of occurrences or the consequences of an accident or malfunction of a different type than those previously evaluated in the safety analysis report are not increased.

Since the added freeze protection is similar to the existing protection, and all instrumentation remains the same, the possibility of an accident or malfunction of a different type from an'y evaluated previously in the safety analysis report is not created.

The new freeze protection provides added assurance that Technical Specifications 3.3.A.1.A & 3.4.A.3 (R.W.S.T. &

Condensate Storage Tank volumes respectively) are met.

The margin of safety as defined in the bases for any Technical Specifications is not reduced.

Thus, this modification was deemed not to involve an unreviewed safety qucstion.

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13.

Addition of Stainless Steel Hose to the Component Coolinct Lines to the RHR Pumos Replacement of the residual heat removal (RHR) pump motors re-sulted in displacement of the cooling water connections from their original positions.

In lieu of a piping redesign which would involve extensive welding in a high radiation area, this modification provided flexible stainless steel hose to be used to re-establish the cooling water flow to these motors.

The sole concern related to this modification is the ability of the flexible hose to perform, as necessary, in a manner equivalent to the original cooling lines.

Since these are seismic class I lines, the effect of the proposed change on the ability of the lines to withstand a seismic event was reviewed and it was determined that, for its intendec purpose, flexible stainless steel hose is an accaptable replacement for the original method of connection and will not adversely affect the basis for the original design specification.

Since this modification does not degrade the seismic capacity of the lines involved and-is considered an acceptable material substitute, the probability and/or consequences of previously. evaluated accidents are not increased.

In addition, since.the modification involves passive com-Ic ponents only, no new type of ' accident can be creat'ed. -

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Finally, since the functional performance of the Component Cooling System is not degraded and continued cooling of the RHR pump motors is maintained, the margins of safety in the bases for the Technical Specifications are not reduced.

It was therefore concluded that the modification did not involve an unreviewed safety question.

14.

Boron Injection Tank Flanged Tee Connection This modification permits filling the Boron Injection Tank (BIT) without disconnecting the tank level trans-mitter (LT-944B) and removing piping insulation and heat tracing.

Prior to this modification the BIT was filled from the output of the Boric Acid Blender through a temporary con-nection located downstream of valve #294.

A hose was bolted to this temporary connection and to a 1" x 2" spool piece.

This spool piece was bolted to the flange of the 2"

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line leading to the BIT containing valve 1823D. In normal operation (non-filling) LT-944B is connected to the BIT via a flanged connection.

The flanged 4

connection, i ts rma t tracing, and insulation had to be removed before connecting the spool piece used in filling.

This modification provided a permanent flanged Tee and a valve, bolted to the flange Tee with a blank flange cover bolted to the valve's outlet during non-filling periods.

When BIT filling is required, the blank flanac will be removed and filling hose bolted to the valve's open end.

The new Tee and valve are heat traced.

2 The previous flanged connection between LT-944B and the BIT was replaced with a new flanged Tee connection with the fill valve attached to the Tee.

The new pressure boundary is the Tee and the valve.

If the valve were to leak, the leakage would be stopped by the blank flange bolted to the valve outlet.

To pre-vent boric acid from depositing on internal surfaces, the new elements are also. heat traced.

The new Tee, t

valve, and flange cover were designed to the same specificationa and quality requirements as the existing

. system.

The BIT and its associated piping have a seismic I clas-sification; this modification will not degrade this

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classification..

i t-Figure 6.2-1 of the Unit 2 FSAR shows only two heat

'j traced lines connecting the BIT to LT-944B, with iso-lation valves 1823C and 18230 in the lines respectively.

This modification adds a Tee flange and fill valve, with blank flange on the valve outlet, between 1823D and LT-944B.

With these additions being heat traced, a double pressure boundary established at the new fill i

valve, and all materials meeting system requirements the following has been concluded:

(1)

The probability of occurrence or consequences s

of an accident or malfunction of equipment i

important to safety previously evaluated in the j

safety analysis is not increased.

(2)

The possibility for an accident or malfunction f

of a different type from any evaluated previously in the safety analysis report is not created.

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i-(3)

The bases of any Technical Specification is not changed.

Thus the nargin of safety as defined in these bases is not reduced.

For these reasons this modification was deemed not to involve an unreviewed safety question.

15.

Modify Vents to Reduce Mass and Tendency Toward Vibration Induced Weld Cracking l

Certain vent points have either an isolation valve with j

an extending pipe blanked off with a blind flange, or in the case of some instrument vents, a pipe plug threaded 4

into the instrument.

When vibration of the vent line occurs, a stress is placed on the weld joint where the vent line originates.

This vibration induced stress is decreased if the mass at the blind flange is decreased.

With respect to the vent pipe plug utilized by the instru-ments, after repeated use the connection would become susceptible to leakage.

In attempting to eliminate a leak, overtorquing of the pipe plug and possible damage to instrument threads can take place.

The problems associated with the above vents can be solved by installation of Swagelok compression. fittings.

These fare'of smaller mass than a blind flange and in the process of tightening, two opposing torques are utilized, thus not stressing the member from which the li'ne originates.

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The modifications are in accordance with applicable codes, approved welding procedures and material and other

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specifications.

Therefore, the integrity of the piping is not compromised or degraded.

During the 1980 a number of the vents were modified as described.

The function of the vent points / lines will not be changed and the probability of their failure will be reduced i

with this modification.

Thus, the margin of safety as defined in Technical Specifications is not reduced.

The possibility of failure of the vent points is re-duced with the modification.

The type of failure would be the same with or without the modification.

Thus, the possibility for an accident or malfunction of a different type from any other previously evaluated in the safety analysis is not created.

Also, the possibility j

for an accident or malfunction of a different type than

'l any evaluated previously in the safety analysis is not created.

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' Hification was deemed not to rn.-

e p.stion.

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16.

• Installation of Undervoltage Alarm on 480 Volt safeguards Buses The purpose of this modification was to provide a cap-ability for alerting the control room operator to an undervoltage condition on the 480V safeguards buses in advance of attaining an actual undervoltage trip level.

The modification connects with the 120V supply past the 480-120V transformer.

The new undervoltage relay monitors the voltage from the 480 volt safeguards buses and alarms in the CCR.

The relay is set at 480 volt (for the high setting) and 448V (for the low setting, 93.3%).

A separate indicator light is used to provide indication that the undervoltage alarm circuit is activated.

There is one undervoltage relay installed on each 480V safe-guards bus (2A, 3A, 5A & 6 A).

The new undervoltage alarm is in addition to existing undervoltage relays.

The existing relays trip the bus at 46% undervoltage, while the new relays will alarm at 93.3%, but have no tripping function.

The modification was made to class "A" standards-with sections class IE.

. The'undervoltage alarm is'used for operator' info rmati~on,

and there is no automatic function associated with its operation.

The. alarms do.not change any existing con-

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'tro1 or alarms on the 480 vol't safeguards' busses.

Thus, the probability of occurrence or the consequences of an-accident or malfunction of equipment important to safety previously evaluated in the safety analysis report are not increased.

Similar low voltage alarms and trips exist on the 480 volt system.

This addition does not change or produce a condition different from that which previously existed.

Therefore, the possibility for an accident or malfunction of a different type from any evaluated previously in the safety analysis report is not created.

This modification does not change the Technical Spec-ifications or bases as described in Section 3.7, but will aid in determining an undervoltage condition, either during normal operation or when the diesels are in oper-ation.

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

i Therefore, this modification was deemed not to involve an unreviewed safety question.

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