ML20081C951

Forwards Byron Nuclear Power Station 10CFR50.59 Summary Rept for 1994.Rept Consist of Descriptions & SE Summaries for Changes to Facility as Described in Sar.No Tests or Experiments Performed.Changes to FP Program Also Included

ML20081C951
Person / Time
Site:	Byron
Issue date:	03/10/1995
From:	Schwartz G COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
References
BYRON-95-0095, BYRON-95-95, NUDOCS 9503200073
Download: ML20081C951 (25)

Text

Com'rnonwealth hirx n Cenpany

. 15)run Generatmg 5 ation

, 4 450 North German Church Road 11)ron 11610M9791 Tel M15 23 F5 i 41 March 10, 1995 I

LTR: BYRON 95-0095 i

FILE: 2.7.611 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ,

Washington, D.C. 20555 Attention: Document Control Desk t

Subject:

Byron Station Units 1 and 2 <

10 CFR 50.59 Annual Report NRC Docket Nos. 50-454 and 50-455 Pursuant to the requirements of 10 CFR 50.59 (b) (2) , Byron Station is providing the required annual report for Byron Station (Facility Operating License Nos. NPF-37 and NPF-66). This report is being provided for the 1994 calendar year and consists of descriptions and safety evaluation summaries for changes to the facility as described in the safety analysis report. No tests or experiments governed by paragraph (a) of 10 CFR 50.59 were performed. Also included as part of this report are changes made to features of the fire protection program not previously presented to the NRC Staff.

Please direct any questions regarding this submittal to Laurie Lahti, Regulatory Assurance Department, at (815) 234-5441 extension 2852.

su G. K. Schwartz Station Manager Byron Nuclear Po Station GKS/LAL/rp Enclosure cct H.H. Peterson, Senior Resident Inspector - Byron G.F. Dick, Byron Project Manager - NRR J.B. Martin, Regional Administrator - RIII H.D. Pontious - NLA D.J. Klink - Byron SEC D.S. Huston - Braidwood (p:\95byhrsiby950095W31095) 9503200073 950310 i PDR ADOCK 05000454 '

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10 CFR 50.59 Summary Report 1994 l NRC Docket Nos. 50-454 and 50-455 Licence Nos. NPF-37 and NPF-66 r

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MODIFICATION M6-1-89-018-Al DESCRIPTION:

The modification replaced air operated valve, 1PS9350A, and manual valve 1PS9365A. These valves are isolation valves in the primary sampling system line from the steam side of the pressurizer. The modification was done because the old valves were prone to seat, stem packing, and body to bonnet leakage. The new valves are designed to minimize leakage.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the new piping and valves were designed, fabricated, nd installed in accordance with the Class 2 requirements of ASME Section II. The function and operation of the valves and syetem were not changed.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because system operation and performance remain unchanged. No new equipment failure modes or interactions have been created. The new valves were selected to improve system reliability.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because no margin of safety involves the specif. 'odel of valve used in the primary sampling system.

Technical f oi%; ; fication 3 /4.4, Reactor Coolant System, was not affected by aeplacement of valves 1PS9350A and IPS9365A.

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MINOR PLANT CHANGE N6-1-89-699 i

DESCRIPTION:

• The minor plant change lowered the set pressure of relief valve ICV 8119 from 300 psig to 230 psig. The change was made to address operational problems with diaphragm valves that could have been exposed to pressures in excess of 300 psig due to their location in the system.

I SAFETY EVALUATION

SUMMARY

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1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously -

evaluated in the UFSAR is not increased because lowering the valve setpoint allows the valve to perform its intended function. The lower setpoint protects the diaphragm valves in the system, yet it is high enough to avoid lifting the relief valve during normal, steady j state operation. Failure modes are bounded by the UFSAR analysis.

Furthermore, no credit is taken for the relief valve to mitigate any accidente.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because relief valve failure is within the scope of the small break loss of coolant accident. The change to the relief valve setpoint does not cause the initiation of any accidents or create new failure modes. -

3. The margin of safety, as defined in the basis for any Technical  ;

Specification, is nit reduced because the setpoint is not the basis for any Technical Specification. The modification allows the valve to perform its intended function.

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. i MODIFICATION M6-1-91-020 DESCRIPTION:

The modification replaced motor operated valve ICC685, reactor coolart pump thermal barrier return isolation valve. The modification was installed to increase the motor operated valve thrust window margin. The replacement valve was smaller and requires less thrust to close under design ,

differential pressure conditions. The new motor operator was larger and provided more thrust capability.  ;

EAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, i or malfunction of equipment important to safety as previously ,

evaluated in the UFSAR is not iner- 'd because valve ICC685 is not an initiator of any accident des: oed in the UFSAR. The new valve and motor operator perform the sa: functions as the original valve.

The new motor operated valve increased the thrust margin and improved valve reliability. The change had no adverse impact on the Component Cooling System operation.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because valve functions remain unchanged. The small differences in valve performance characteristics were evaluated and were acceptable. No new failure modes were created.

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the replacement of valve ICC685 did not affect any parameters upon which Technical Specifications are based. The valve stroke time remains within the 10 second Technical Specification requirement.

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I MINOR PLANT CHANGE M6-1/2-91-692 i

DESCRIPTION:

The minor plant change added door handles to the inside and outside of the  ;

entrance doors for the Unit I and 2 Emergency Diesel Generator and Engineered Safety Features (ESP) Switchgear rooms. These handles were added to assist personnel in opening and closing the security doors and, thereby, reduce security alarms.

r SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously ,

evaluated in the UFSAR is not increased because the additional door  ;

handles did not adversely affect the door functions. The addition of the new handles did not affect the Underwriters Laboratory fire rating for the doors.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because  ;

door operation and function were not changed. No new failure modes  !

or system interactions were created.

3. The margin of safety, as defined in the basis for any Technical '

Specification, is not reduced because the change did not affect any parameters upon which the Technical Specifications are based.

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r MODIFICATION M6-0-92-003 1

l DESCRIPTION: ,

i The modification replaced the existing Westinghouse Hagan Optimac 2-pen recorder OUR-CWO32 with a Yokogawa 3-pen recorder. The new recorder records a new process variable, the Circulating Water bay level. l 1

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the function of the recorder is not chang'.d. The third input provides additional information to the control room operators in conjunction with the ,

existing indicator OLI-CWO41. The equipment is nct important to safety and does not affect any accidents evaluated in the UFSAR.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the new recorder provides the same information as the old recorder, along j with an additional. parameter. The circuit and logic used for the input to tF t.ew recorder are unchanged. No new failures were created. The new recorder is expected to be more reliable and easier to maintain.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameterr4 upon which Technical Specifications are based.

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MODIFICATION M6-1-92-004 DESCRIPTION:

The modification replaced incore thermocouple cables and connectors. The old cables and connectors were environmentally qualified for 10 years and were approaching the end of the qualified life. The replacement cables and ccnnectors were supplied by a different manufacturer and are environmentally qualified for 40 years.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the new cabling system maintains redundancy, electrical and physical separation per ,

the original design requirements. The change associated with the modification was physical, not functional. Post-modification testing was performed to verify proper system operation. The new cabling system reduced the number of connectors and cables.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the modification replaced existing connectors and mineral cables with a new 40 year qualified cabling system, due :o end of EQ life. The new cabling system maintains redundancy, electrical and physical seperation per the original design requirements. The change associated with the modification was physical, not functional,

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based.

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MODIFICATION M6-0-92-031 l

DESCRIPTION:

The modification made the following changes to the Rock River near the Byron Station River Screen House Intake structure:

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• Added 40 concrete " Iowa" vanes in the Rock River approximately 40 feet to 60 feet offshore of the River Screen House.

• Added 2 riprap wing dams in the Rock River approximately 1400 feet upstream of the River Screen House.

• Removed an upstream spur and reshaped the shoreline downstream of the River Screen House.

i These changes were made to reduce sediment build-up in front of the River Screen House.

SAFETY EVALUATION SUMMANY:

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the changes made at ,

the Rock River did not affect any accident initiators. The modifications reduce sediment build-up, thus ensuring adequate makeup water supply for the Ultimate Heat Sink.

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2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because in the event of failure, the new concrete vanes are designed not to i impact the River Screen House. No new accidents or malfunctions were created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes at the Rock River did not affect any parameters upon which Technical Specifications are based.

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l MINOR PIANT CHANGE M6-0-92-605 DESCRIPTION:

l The minor plant change replaced the Steam Generator (SG) blowdown sample panel cooling module and removed pressure indicating switches and solenoid valves associated with automatic sequencing of SG blowdown samples. The new cooling module was installed to improve sample conditioning. The pressure indicating switches were removed to eliminate a continuing source ,

of leakage. The solenoid valves were removed to eliminate sample cross contamination.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the proposed modification did not affect any accident initiators, equipment important to safety, or aystems required to function to mitigate the consequences of any accidents. The modification did not adversely affect the capability to take secondary system grab samples.

2. The possibility for an accident or malfunction of a different type than an;'previously evaluated in the UFSAR is not created because the ,

i change did ot alter the design basis of any system or adversely affect the function of any system or component. New accident ,

scenarios or malfunctions were not created.  ;

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3. The margin of safety, as defined in the basis for any Technical specification, is not redaced because the change did not affect any parameters upon which Technical Specifications are based.

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e EXEMPT CHANGE M6-1-92-852 DESCkIPTION:

The exempt change installed drain lines and isolation valves in the supply and return lines to the 1A containment building chilled water coils. The new drain lines were installed to facilitate draining low points in the chilled water lines where they run beneath the fuel transfer canal.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the affected chilled water lines are non-safety related and are not required to function to mitigate an accident or malfunction. The affected chilled water lines are isolated on an Engineered Safety Features signal.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the new drain lines for the chilled water piping did not add failure modes or change the operation of the system. The new pipe was designed to the original piping design requirements.

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4 The margin of safety, as defined in the basis for a.y Technical Specification, is not reduced because the affected chilled water lines are not addressed in the basis for any Technical Specification.

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c MODIFICATION M6-0-93-001 DESCRIPTION:

The modification added multiconductor fiber optic and coaxial cable from the Unit 1 and 2 plant process computers to the main control room center desks, the unit operator's areau, the shift engineer's office, and between ,

the process computers. The modification was done to enhance the communications between the process computers and operator work stations.

EAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because no accident initiators were affected by the change. The plant process computer system does not perform a safety function. The cable raceway was evaluated and the added load was acceptable. The fire protection system was not adversely affected by the change. No equipment important to safety was affected by the new cables.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created bec3use the nodification did not adversely affect any safety related systems or components. New failure modes were not created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because no margin of safety involves the plant process computer system. The change did not affect any pa ameters upon which Technical Specifications are based.

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EXEMPT CHANGE M6-0-93-894 l

DESCRIPTION:

The exempt change installed a new 30 inch butterfly valve to Nonessential Service Water line, OWSD6A-30". The new valve provides a maintenance isolation point for Nonessential Service Water equipment. To facilitate installation of the new valve, two line stops were added to Nonessential Service Water lines OWSD6A-30" and OWS549B-44".

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the Nonessential Service Water System has no impact on the probability of any accident described in the UFSAR. The probability of plant flooding was not increased because all new components meet system design requirements and pipe stresses did not exceed code allowables. The Nonessential Service Water System is not required to support the operation of any equipment important to safety. The modification did not affect any safety related equipment.

2. The possibility for an accident or malfunction of a different type than any previouJ1y evaluated in the UFSAR is not created because the function and the operation of the Nonessential Service Water system was not altered by the addition of this exempt change. Load increases were evaluated, and no new failure modes were created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the Nonessential Service Water system is not addressed by the Technical Specifications. The change did not affect parameters upon which Technical Specifications are based.

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):XEMPT CHANCY M6-0-94-814-Al DESCRIPTION:

This exempt change was part of a change to convert a storage room on the third flos- of the service building into office space. The partial exempt change made the following changes:

• Removed two Station Heat stations, associated valves, and piping.

• Removed and relocated various electrical circuit-3.

• Removed overhead lamps.

• Added a new heating, ventilation and air conditioning unit.

• Added new computer and phone tie-ins.

• Resized and relocated a machine shop ventilation system damper.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously I

evaluated in the UFSAR is not increased because all of the changes were to equipment in the service building. No accidents or malfunctions were affected. No equipment important t o safety was affected by the change.

2. The possibility for an accident or malfunction of a different type than any previoualy evaluated in the UFSAR is not created because the systems, structures, and components changed were limited to the non-safety service building. New failure modes were not created.

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes did not affect any parameters upon which Technical Specifications are based.

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DOCUMENT CHANGE REQUEST 94-074 pESCRIPTION:

Work request #940019719 added a fire extinguisher in an area that maintenance uses for grinding. A DCR was issued to revise drawing M-58-8 to reflect the new fire extinguisher. This drawing is included in the Fire Protection Report.

SAFETY EVALUATION

SUMMARY

1. The probability of ar. occurrence or the consequence of an accident, or malfunction or equipment important to safety as previously evaluated in the UFSAR is not increased because the fire extinguisher was added to enhance personnel safety in the area used for grinding in the turbine building. No accidents or malfunctions were affected.

No equipment important to safety was affected by the change.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because no systems, structures, and components changed were affected. New failure modes were not created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes did not affect any parameters upon which Technical Specifications are based.

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SSCR 94-010 and 94-011 DESCRIPTION:

Comed's Nuclear Engineering and Technology Services Inservice Inspection /

Materials Group and Westinghouse determined that Technical Specification ,

3/4.4.9.3, " Reactor Coolant System - Overpressure Protection Systems,"

Figure J.4-4a (Power Operated Relief Valve (PORV) Setpoints) was non-conservative during certain Reactor Coolant Pump / Residual Heat Removal pump alignments and temperature ranges. An analysis was performed to determine new Cold Overpressure Mitigation System setpoints for Unit 1.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequences of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the revised i pressurizer PORV setpoints are more conservative under all low temperature operating conditions and will reduce the potential for exceeding 10CFR50 Appendix G lt..its on Reactor Coolant System (RCS) overpressurization.

2. The possibility for an accident or malfunction of a different type

• than any previously evaluated in the UFSAR is not created because the Cold Overpressure Mitigation System instrumentation was designed to accommodate pressure / temperature relationship setpoint changes. Both ,

PORVs have completely independent instrumentation to ensure a single failure will not result in exceeding 10CFR50 Appendix G limits.

3. The margin of safety, as defined an the basis for any Technical Specification, is not reduced because the conservatively developed setpoints bound worst case operating conditions for low temperature RCS overpressurization events. In the event of RCS pressurization at low temperature, the Pressurizer PORVs will lift earlier than current:v required '; Technical Specifications to prevent pressure from reacnn.g J.ppendix G limits. Therefore, the margin of safety is increased over the current setpoints stated in Technical Specification 3/4.4.9.3.

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SSCR 94-051 DESCRIPTION:

This change adjusted the intermediate range (IR) N36 channel 20% rod stop and 25% trip setpoints. This was required during the refueling outage to account for differences between the new core and old core fuel assembly loading patterne. The revised setpoints were predicted because acutal 20%

and 25% power IR currents were not yet determined.

1 SAFETY EVALUA'1 ION SIM4ARY:

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1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because these setpoints were moved in the conservative direction based on predicted 20% and 25%

power IR electrical current levels with a new fuel loading pattern.

That is, they would actuate at lower reactor power. Furthermore, the j instrumentation is for monitoring and protective functions only and cannot initiate an accident.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because *,he instrumentation was specifically designed to accommodate changes to these setpoints based on the most recent core fuel conditions. There is no physical change to plant equipment. The setpoint change conservatively changes the current level at which a protective function is initiated. No malfunction or new accident was created.

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the revised setpoints allow rod stop and reactor trip to occur at a lower reactor power in the event of an uncontr 11ed power increase while the reactor is shut down.

The change was implemented to maintain the margin of safety as defined in Technical Specification 3/4.3.

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4 SSCR 94-073,94-074, 94-075, and 94-076 I

DESCRIPTION 1 The Auxiliary Feedwater (AF) pump low suction pressure Essential Service Water (SX) switchover setpoint was revised due to an issue identified by the AF Design Basis Review Team. A non-seismic pipe break could result in AF suction prescute drop to atmospheric, thus, preventing the current sub-atmospheric SX switchover setpoint from being reached. This change revised the SX switchover setpoint to positive atmospheric pressure to ensure switchover to the safety related SX water supply will occur.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequences of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the low suction pressure setpoint is in no way related to the events that initiate the analyzed accidents. The new setpoints in combination with raised condensate storage tank (CST) level actually increase the reliability of the AF system over that which currently exists by ensuring proper operation of the SX switchover even in the event that the loop seal on the AF pump suction piping is lost. This will maintain AF system reliability at or above its current level.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the changes to the AF pump low suction prescure setpoint and CST level do ,

not involve any hardware changes. The raised CST level ensures that '

the positive atmospheric setpoint will not reduce the reliability of either the AF pump or the SX switchover actuation.  !

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because, the setpoint for SX switchover listed in Technical Specification Table 3.3-4 is 1.22" Hg Vacuum l (14.1 psia) which is considered a lower limit. The new setpoint will  !

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UFSAR DRAFT REVISION PACKAGE 3-044 l DESCRIPTION:

This UFSAR change updated the feedwater system malfunction transient causing a reduction in feedwater temperature presented in Section 15.1.1.

Currently, ;his section describes the maximum temperature reduction resulting from bypass of a low pressure heater string. Calculations 7 demonstrated that bypass of a high pressure heater string resulted in a more severe feedwater temperature reduction.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the UFSAR conservatively assumes a 55'F reduction in feedwater temperature which bounds the isolation of a high pressure heater string.

Furthermore, a 55'F decrease in feedwater temperature is bounded by the excessive load increase event.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the calculations did not result in any change to the plant or the licensing basis. No new or more severe plant conditions were created or uncovered.

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the maximum feedwater reduction is bounded by the current licensing basis analysis.

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e UFSAR DRAFT REVISION PACKAGE 5-049 DESCRIPTION:

This UFSAR change incorporated the vendor's recommendations for shutting down a Reactor Coolant Pump (RCP) with number 1 seal leakage outside operating limits. The changes incorporated in the station's abnormal operating procedures give specific guidance on monitoring RCP parameters and actions to mitigate damage to the RCPs.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the procedure changes allow for diagnosis and mitigation prior to any gross failure.

2. The possibility for an accident or malfunction of a different type than any previously evalunted in the UFSAR is not created because the procedure changes allow 1.'r additional monitoring of pun.p parameters and early diagnosis of pump seal failures. This allows the unit to be placed in a safe condition prior to gross failure.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.

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d UFSAR DRAFT REVISION PACKAGE 5-055 7ESCRIPTION:

Comed deleted a commitment to Regulatory Guide 1.47, " Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems," as Speciff*d in the UFSAR. Specifically, the Equipment Status Display (ESD) panel was disabled and human factor improvements, programs and procedures were used to meet the intent of the Regulatory Guide.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because there is no direct failure mechanism associated with the ESD Panel. The ESD Panel is a monitoring system that is isolated from safety related equipment and does not provide any protection or control functions. Required information is still available to operators.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because the operation, performance or failure of the ESD panel does not impact the performance of any safety related system. Information previously provided by the ESD panel to meet the intent of Regulatory Guide 1.47 is collectively available through the group monitor lights, enhanced control room indication, training, staffing, and administrative programs, each of which have been previously evaluated by the NRC.

No new failure modes were identified. All equipment failures associated with ESD, as well as control room enhancements now being relied upon, have been previously evaluated.

While the ESD in itself is non-safety related, most of the computer points that feed ESD are directly connected to safety related equipment but use non-safety related contacts or auxiliary switch contacts. The ESD is a monitoring system that is isolated from safety related equipment and does not provide any protection or control functions. Taking credit for other available information to meet the intent of Regulatory Guide 1.47 introduces no direct failure mechanism. Therefore, the change does not result in an analyzed transient that impacts the units' ability to control reactivity, remove core heat, or provide or process primary coolant.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.

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i UFSAR DRAFT REVISION PACKAGE 5-065 DESCRIPTION:

This UFSAR change revised a commitment to regulatory position C of Regulatory Guide 1.93, " Availability of Electric Power Sources". The ,

purpose for the revision of this UFSAR commitment is to permit Comed the option of performing periodic preventative maintenance on the System Auxiliary Transformers (SAT) with both units at power. Regulatory Guide 1.93 requires that preventative maintenance be constrained to those periods when the affected unit is in cold shutdown or refueling.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because an evaluation was performed demonstrating that the probability of losing the remaining offsite power source to the affected unit while performing preventative maintenance on the SAT is essentially unchanged from the '

probability of a unit experiencing a loss of offsite power under the normal electrical lineup. As described in the UFSAR, the plant is designed with a variety of available power sources. With one SAT out ,

of service for maintenance, sufficient onsite and offsite power sources remain available to assure that diverse power availability is retained. The loss of nonemergency ac power is analyzed in Chapter 15 of the UFSAR and demonstrates that natural circulation of the reacb,t coolant system after reactor coolant pump coastdown is sufficient to prevent fuel or clad damage. Furthermore, the loss of nonemergency ac power is not a limiting transient with respect to offsite dose.

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2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not increased because no new failure modes are introduced, nor have any new transient initiators been identified which are not bounded by the current analyses. The bounding transients are assumed to occur concurrent with a loss of offsite power. The loss of offsite power is not explicitly or implicitly assumed to initiate any of the bounding transients.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.

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ADMINISTRATIVE TECHNICAL REQUIREMENTS AMENDMENT 8 DESCRIPTION:

This amendment to the Administrative Technical Requirements changed the frequencies of some fire protection surveillances from 6 months to 18 months in the following areas: smoke detectors, restorable heat detectors, and fire detector circuit supervisory functions. The amendment also proposed to electrically activate Electro-Thermal Links (ETL) every 10 years instead of 18 months. The frequency for drop testing ETL fire dampers is also revised.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because there were no physical equipment alterations. The new test frequencies do not significantly affect system or component reliability. The fire barriers and components remain capable of performing their design function of protecting against the consequences of a fire.

Malfunctions of fire protection equipment are not considered in the UFSAR.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not increased because there is no change to the functionality of any fire protection equipment. The changes to the testing frequencies for the .fentified fire protection systems and components does not adversely impact systems or functions

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.

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I DRY ACTIVATED WASTE STORAGE FACILITY DESCRIPTION:

The change converted an onsite warehouse building to a Dry Activated Waste (DAW) storage facility. The DAW storage facility was added to temporarily augment the onsite low level storage capability.

1 SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously l evaluated in the UFSAR is not increased because a release of radioactive materials from the DAW storage facility due to a fire, tornado, or seismic event was evaluated and the resultant dose would be well below 10CFR20 and 40CFR190 limits. A monitoring program is in place to assure that the off-site dose projections are not exceeded. The addition of the DAW storage facility did not affect the design or operation of any safety related systems or structures.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not increased because the addition of the DAW storage facility did not affect the design or operation of any systems or structures important to safety. No new failure modes were created.

3. The margin of safety, as defined in the basis for any Technical )

Specification, is not reduced because this change does not affect any i parameters upon which Technical Specifications are based.

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e WORK RSOUEST NUMBERS 940040471 AND 940040473 DESCRIPTION:

Four Steam Generator tubes were removed by work request numbers 940040471 and 940040473. The affected tubes were 3-107 and 23-44 from Steam '

Generator A, and 20-7 and 20-102 from Steam Generator C. Each tube remnant was cut on the hot leg side, approximately 4 to 6 inches below the eighth support plate, with the exception of tube 23-44, which was cut 4 to 6 inches below the third tube support plate. Each tube remnant was expanded into the support plate above the cut prior to tube remeval. This expansion provided additional support for the remnant tube. The tubes were plugged to prevent Reactor Coolant from entering the secondary side. Westinghouse Safety Evaluation SECL-94-163, Revision 1 supports the change.

SAFETY EVALUATION

SUMMARY

1. The probability of an occurrence or the consequence of an accident, or malfunction of equipment important to safety as previously evaluated in the UFSAR is not increased because the operation of Steam Generators A and C with the tube remnants is not expected to adversely affect the primary pressure boundary or result in any additional structural load on the surrounding tubes during normal or postulated accident conditions. Analyses confirmed that the postulated loads and calculated stress levels in the remnant pieces would not interact with tubes remaining in the steam generator.

2. The possibility for an accident or malfunction of a different type than any previously evaluated in the UFSAR is not created because both Steam Generators A and C met all previous design criteria specified in UFSAR. The limiting consequence of the interaction of the identified tube remnants with adjacent active tubes would be a single tube rupture, which is bounded by the current accident analyses.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the removal of the designated portion of the hot leg sections of tubes in Steam Generator A and C is not expected to adversely affect the primary pressure boundary.

The cut tubes would not interact with adjacent active tubes during subsequent plant operation. There is no impact on the requirements in the Byron Technical Specifications for the inspection and plugging as a result from removing these tubes.

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