ML20127C556

Annual Plant Mod Rept Jul 1991-June 1992 for Limerick Generating Station Units 1 & 2

ML20127C556
Person / Time
Site:	Limerick
Issue date:	06/30/1992
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
References
NUDOCS 9209090160
Download: ML20127C556 (80)

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< , &'t,' s a LIMERICK GENERATING-STATION UNIT NO. 1 and 2 J f*-' DOCKET NO.-50-352 (UNIT 1):

? < DOCKET NO, 50-353 (UNIT 2)

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ANNUAL' PLANT MOLIFICATION REPORT JULY 1; 1991'THROUGH JUNE 30; 1992' M

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SUBMITTED TO.

, c.. , 'THE_ UNITED STATES NUCLEAR REGULATORY COMMISSION 4 , ' PURSUANT TO<

FACILITY. OPERATING LICENSE NPF-39 (UNIT .1')

-AND NPF-85 (UNIT 2).

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LIMER7.CK GENERJTING STATION ANNUAL PLANT MODIFICATION REPORT AUGUST 31, 1992 ,

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.This repoit 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, 1992, including changes made to the facility

- as-described in.the UFSAR.

y 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 (i)' the I probability of. occurrence-of~the consequences of an accident-or  !

malfunction of' equipment important to safety previously evaluated

" fin - the UFSAR :- was -not increased, and (ii) a possibility for an accident or . malfunction- of a' dif f erent type than any evaluated I:-  : previously.in the-UFSAR was not created, and (iii) the margin of

. -safety as defined in~the basis'for any Technical Specification was not' reduced, e

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Docket No. 50-352 Docket No. 50-353 LIMERICK' GENERATING STATION ~

ANNUAL MODIFICATION REPORT TABLE OF CONTENTS Uni't 1 Modific3 cions System Page 5001-1 React or Water Cleanup 1 ,

5085-1 Miscellaneous 2 5315-1 (Rev.4) Structures and Snubbers 4 5416-1 Post Accident Sampling 5 5871-1 Circulating Water and Cooling 6 ,

Towers 5880-1 Nuclear Boiler 7 5914-1 4 KV System Diesel Generat ors 9 5936-1 480V System 11 3 5956-1 Feedwater 13 6036-1 Core Spray 15 6079 Fuel and Fuel Handling 17 >

6104-1 Containment Atmospheric Control 18 6133-1 Steam Leak Detection 2 6135-1 Fire Proteccion 22 6137-1 Plant Computers and Samac 24 6139-1 Snubbers 25 6168-1 Feedwater 28 Instrument Air 29

'. .6171-1 6182-1 Reactor Water Cleanup 31 6183-1 Reactor Enclosure HVAC and SBGTS 33 Nonconformance Reports L-90224 Compressed Air 35 L-91151 Residual Hea. Removal 37

_L-91236 Misc. Instrument Systems 39 LG92-00122 Reactor Vessel 41 Tests

, SP-T-Q 8 Feedwater 42

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Unit 12

. Modifications System- Pace

'5342-2 Condensate Filter Demineralizers 44 ,

~5515-2 Feedwater 46 '

5843-2 Reactor Enclosure HVAC and SBGTS 48

. 5956-2 Feedwater 50

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6097-2. Plant Computers and Samac 52 6108-2 -DC Systems 54 6115-2 Electro Hydraulic Control "i

.6120-2 Reactor Water Cleanup 58 6182-2 Reactor Water Cleanup 59 Tests ~

.SP-T-009 Feedwater 61 Unitis113f2 kandEcommon Modifications 094920 Communications 63 5993-0. Communications 64

. .6011-0 Communications 65

-6050-0 . Structures 66 6141-0 Fire Protection 67 9084'-0 . Plant Computers 68 Nonconfortrance Reports L-91014 Control Rod Drive Hydraulics 69 L-91073 Service Water 71 L-91169 . Emergency Se_vice. Water and 73-Residual Heat Removal Test _s_

S12.8.B Emergency Service' Water and 74 Residual Heat Removal Service Water-L l

Limerick Generating Station Unit 1 Annual Plant Modifi mtion Report July 1, 1991 Through June 30, 1992 Page 1 Modification No.: 5001=1 A. System: Reactor Water Cleanap B.

Description:

l'illing and venting of Reactor Water Cleanup pumps C. Reason for Chance:

Three new vent line:s and a demineralized water fill conrc '-ion will be added to each Reactor Water Cleanup recirculati' puinp system to provide sufficient ventilation in the Reactc. Yeter _7 ~

Cleanup pumps, D, Safetv Evaluation Summarv:

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? h Answer: No, the addition of vents and a demineralized water fill connection on the Reactor Water -

Cleanup system will be installec' 4 n a portion of the system which can be isolu.ed from the Reactor Coolant Pressure Boundary, ii) Does this modification create the possibility for an accident' or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, the vents and demineralized water fill connection will not affect any safety-related piping or other safety related commodities, iii) .Does this modification reduce the margin of safety as defined in the bases for the ' Technical Speci ficat' ions?

Answer: No, there is no applicable Technical Specification.

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 2

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14cdification No.: 5085'1 o

A. System: Miscellaneous B. Descriptiv.m This modification replaced Rosemount model 1151 transmitters installed in safety-related applications which require harsh k environment qualification, with Rosemount model 1153 transmitters. It also added a square roct extractor and a new signal resistor unit in the Residual Heat Removal (RHR) instrument loop.

C. Reason for Chance:

There is no longer a supplier for nuclear safety related model 1151 transmitters or spare parts. Regulation 10CFR50.49 was issued requiring all electrical equipment important. to saf ety (as defined in 10CFR50.49) be environmentally qualified.

D. Safety Evaluation Summarv:

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, those components replaced or added by this modification meet or exceed the requirements of their application. The model 1153B transmitter is equivalent to che model 1151

• transmitter in forn, fit, and function.

ii) 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, the modified instrument loops are nt : '

subject to new failure medes, because the replacement model 1153B transmitters are functionally equivalent to the orig: %1 transmitters .nd the modification to the FT-51-1N001 is consistent with the design of its redundant instrument loop.

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Unit 1

' Annual = Plant Nodification Report' l July 4, 199_ Through June 30,-1992 Page 3 iii)-Does'this modification reduce the margin of nafety as

+- defined'in the bases for the Techr4ical Specifications?

Answer: No, capability to measure plant process is not

-reduced. -All design and performance requirements applicable to the original design <

bases will continue to be satisfied.

_;. -Technical Specifications Sections- 3 / 4 . 3 .1:

through 3 /4. 3. 5 . and 3 /4.3.7 and their bases-Were reviewed to make this determination.

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Limerick Generating Station Unit l'

. Annual Plant Modification Report July 1, 1991 Through June' 30._1992 .,

Page 4 j Modi fi cation No . : 5315"1 (Rev. 4)

A. Systemi Structures and Snubbers

'B.

Description:

This modification decommissioned the snubber test machine and

, services. Modification 6050-0 relocated these services.

.C. Reason for Chance:

The snubber test f acility needed to be relocated to facilitate

~ the-installation 1of the Deep Bed Demineralizers.

~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, this modification was implemented per existing design-requirements.

- ii). Does - this modification create the _ possibility for an accident -or malfunction of a different type thran any

__ evaluated previously in the FSAR?

Answer: No , .this ' modification -was implemented per '

existing-design' requirements.

iii);Does this modification - reduce' the margin of ' safety as

-defined-in the~ bases for the' Technical Specifications?

Answer: No, the . l systems involved and the equipment that was - decommissioned do not af fect the

- . existing Technical Specifications. -This:

modification does not-affect-any commitments related to snubbers as described in the-Technical-Specifications Section 3/4.7.4.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 5 Modification No.: 541641 A. system: Post Accident Sampling B. Des cri p:: ion :

This modification upgraded the Post Accident Sampling System (PASS).

C. Reason f or Cha' ge:

This modification met PSCo's commitment to the NRC to improve the operability and reliability of the PASS.

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, the function of the PASS is not changed by this modification. The safety related portions of the PASS affected by this modification were modified with Q-Listed co.aponents which meet all applicable design criteria of the PASS and of Class IE systems.

The non-safety related portions do not affect the safety related portions of the PASS or nearby safety related systems.

ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, this modification only upgrades the equipment associated with the existing PASS and does not change its function or logic.

iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No, this modification does not impact any safety system described in the Technical Specifications or their bases. This change does not adversely affect the capability to  ;

safely shutdown the plant. l

Limerick Generating Station Unit 1 Annual Plant Modification Report July-1, 1991 Through June 30, 1992 Page 6

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-Modification No.: 5871'1 A. -System: Circulating Water and Cooling Towers B. -Description:

This 'modsfication installed a low water level detector downstream of the cooling tower outlet screen and provides a parallel alarm contact into the existing cooling tower. basin-Hi/Lo level alarm circuit.

-C. Reason forLChance:

In-order.to monitor the pressure drop across the screens, a l'owilevel detector.was installed downstream of the cooling

> tower outlet screens and actuates an alarm in the main control.-

+ -room'via.a common-status alarm when the water level drops-below-s predetermined' level. The operator is_ forewarned of the-outlet screens which may require cleaning, c

-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, this modification is not safety-related and enhances the reliability. 'o f the.

Circulating. water system.

ii)' Does this mo'dification create the possibility for an accident or ~ malfunction of a different type than_any evaluated previously in the FSAR?

i.aswer: No, the ' original functioaal design of the system as described in the FSAR is unchanged.

This; system is not safLty-related and failure.

analysis is not' evaluated in the FSAR.

r iii).Does this modification reduce the margin of safety as defined"in the bases for the Technical-Specifications?

Answer: No, there are not Technical Specifications applicable to this non-safety related system.

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Limerick. Generating Station Unit-1 Annual Plant Modification Report iJuly.1,'1991 Through June 30, 1992 Page 7

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{ Modification No.: 5880'1

'A . System: Nuclear Boiler B =. Deacription:

This - modification installed a test tap on the neck of-the valve body of valve HV-41-109A.

y C. Reason for Chance:

This modification was _-necessary for an alternate method for

-performance of' Local Leak Rate Testing (LLRT) of the feedwater long-path. recirculation valve H'/-41-109A.

' 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, the alternate-10CFR50, Appendix J,_ Type C~

--* leak test method- has been demonstrated to-maintain'the same direction'or pressurization on the. discharge seat'of the valve as normally-1

-performed. This method is more sensitive to leakage than-that previously used.

iii) . .Does- this: modification create the - possibility for an-accident or malfunction of a dif ferent _ type than any.

evaluated previously in_.the FSAR?.

Answer: .No, Jthe test tap;was designed and installed in accordance with the- prevailing. design and--

, installation- codes .and standards for ~t he intended., service' and' will not impair the operability of the valve.

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Limerick Generating Station Unit l Annual Plant Modification Report July 1, 1991 Through June--30, 1992

-d Page 8-f iii ) Does -this modi'fication reduce the margin of safety as

- defined in the bases for the Technical Specifications?-

Answer: No, the test method is designed to test tlie l sealing -capability of- the valve in the same l direction that post-accident -leakage _would occur and the test. tap added to the-valve.will' not impair. its normal isolation function.-

Technical Specification Sections 3. 0. 2, 3. 0. 4,

~ 4 . 0 .1, - . 4 . 0 . 3, 4.0.5, 3/4.3.2, 4.6.1.2, and

. 3/4.6.3 and associated bases were reviewed in making this determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July-1, 1991 Through June 30, 1992 Page 9-Modification No.: 5914-1

i. System: 4 KV-System Diesel Generators

'B.

Description:

This modification added a locked-open ball valve in the diesel generator starting air line between the air start manifold and the pressure regulator for the lower main bearing lube oil-booster.

C. Reason for Chance:

'The-ball valve will provide a means of isolating air to the main bearing. oil booster when it is desirable to use the air system to rotace the diesel to clear it of excess oil. This will avoid evacuating the main bearing oil booster cylinder so that oil remains available in the cylinder for any required emergency start of the diesel engine.

.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?

because the malfunction of components

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Answer: ' No ,

added by this modification does not af fect the -

function of the diesels or of their associated.

• systems'as' described in the-UFSAR. The added components meet existing cafety criteria.

ii) Does this modification create . the possibility- for an accident or malfunction of- a : dif ferent type than any_

evaluated previously in the FSAR?-

Answer: No, because - the Q-listed, Seismic Category I

-components added by this modification will not have any adverse impact ~on the diesels or_on any other safety-related system. Failure of the valve or failure to reopen the valve is no worse than the previously analyzed failure of' L the non-single failure proof lube oil booster

! cylinder.

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Limerick Generating Station Unit _.1 Annual Plant Modification Report July 1, 1991 Through June 30,-1992 Page-10

• ' iii) Does this. modi >fication reduce the margin of safety as defined in the bases-for_the Technical Specifications?

Answer: No, - ' becaus e the . modification does not altsr the intended function of the system involved.

Technical specification Section - 3 /4. 8.1 was .

reviewed-in making this determination.

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> Limerick Generating Station Unit 1 E*" Annual Plant Modification Report

-July.1,_ 1991 Through June 30, 1992 Page 11

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Modificati on -N'o . : 5938'1 j

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A. ~ System: 480V System i

B.- Description ,

This . modification - replaced . aluminum vertical bus bars with  !

copper-bus bars'and washers for connection between aluminum

. horizontal bus to copper _ vertical bus for both Seismic Class.

< I,: safety-related and Nonseismic Class I', non-safety related-480V AC- motor control _ centers -(MCCs) manufactured by R Eaton/ Cutler-Hammer. Company.

-C. . Reason for Chance:

Some failures of' aluminum vertical bus connections at

. .Eddystone Generating Station and Limerick Generating Station were reported. This modification will. increase the reliability of both the safety-related and non-safety related ,

MCCs.

D. Safety Eva;uation Summary:

,- -i ) - -Does this modification increase the probability of

-occurrence. or the . consequences of an accident or malfunctice of equipment. ' :important to _ safety _as preViously. evaluated in'the FSAR?

Answer: No,- this modification has no adverse affect on equ'ipment ,important to safety. -This modification increases the reliability-of the MCCs.

ii) ;Does - this modification create the possibility for an accident or malfunction of a different- type _than any evaluated previously.in the FSAR?

r Answer: No, this modification has no adverse af fect on equipment 1important to safety. The material

~ substitution of vertical bus and conical spring washers .for safety-related MCCs L

L complies with 10CFR21 requirements, j

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 12 iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No , Technical Specification 3/4.8 which governs the 480V AC MCCs does not specifically address the vertical bus material, nor does this material substitution impact the --

operation of any safety-related system.

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Limerick Generating Station Unit 1 Annual Plant 1 aification Report July 1, 1991 Th.sugh June 30, 1992 Page 13 Modification No.: 5956"1 A. Avstem: Feedwater B. Dorcription:

Thic modification installed General Electric's Zinc Injection Passivation (GEZIP) syst.em on Unit 1.

C. kenson for Chance:

4. The presenca of trace amounts of soluble ' nc in BWR reactor water has been shown to considerably r ,; ce .adiation buildup on primary piping and components. The GEZIP process consists of a skid-mounted !njection system for introducing a continuous dilute solution of zinc oxide into the feedwater system.

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, loss of power to the GEZIP system will not

-; cause a loss of feedwater to the reactor via an incorrect valve line-up; ch.ck valves have been incorporated into the design of the zinc injection piping to insure that the probability of occurrence of loss of feedwater

_ to the reactor is not incret ed by this modification. The ef fect of traces of solubj e ,

zinc in the feedwater has been found to have 7 no adverse effects on plant materials or on BWR fuel.

ii) Doi a this modification create the possibility for an accident or malfunction of a different type than any y evaluated previously in the FSAR?

Answer: No, the GEZIP system is not expected to have

- any adverse effects on the reactor pressure y

vessel, fuel cladding, parts of the fuel assembly, or the primary system piping. This modification installs nnn-safety related equipment in a non-safety related area of the plant. l

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Limerick Generating Station i Unit 1 Annual Plant Modification Report July 1991 Through June 30, 1992 '

1 Page 14 l l

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H iii) Does this modification reduce the margin of safety as l Jefined iin the bases for the Technical Specifications?

Answeg: No , tbe installation of the GEZIP syst eni, ,

including connections to the feedwater sustem and the demineralized water se tem, does not alter the intended function t. . the systems i involved. Technical Specification Sections 3/4.3.9 and 3/4.4.4 and their bases were reviewed in making this determination.

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Limerick Generating Station ,

Unit 1 A_nual Plant Modification Report

~ July 1, 1991 Through June 30, 1992 1 Page 15 I l

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Modi fication No : 6036Al A. Systems Core Spray  :

i B. Dencription:  !

- This modification resized two existing minimum flow orifices, each located in a dischargo-line common to a pair of Core  ;

- Spray pumps, and installed four new orifices, one locatedjin each pump's-individual:minflow-di: charge piping. i C. - Reason for Chance: ,

This modification' minimizes pump-to-pump interaction during minimum flow operation and insures that -minimum flow '

requirements are met-for each Core Spray pump.

., D . Fafety Evaluation Summary: l

- 1) 'Does this modification 3ncrease the probability of l occurrence o r- the cons 6gr.ences of an accident or -

malfunction . of equipment important' to safety as ,

previously evaluated in the FSAR?-

Answer - No , Core Spray -is used to mitigate the consequences of an accident and is not an t' accident'- ' initiator. A postulated - single

.. failure'of:the new flow orifices would result '

in-.an increase or a decrease in the minflow

' rate, which would cause the Core Spray loop to be inoperable. This - has been previously evaluated in the'SAR as acceptable.

ii ) Does~ this modification create the - 1.ossibility for ' an

~

accident or malfunction of a dif ferene - type than any 3

. evaluated previously.in the FSAR?

Answer:. No,-only the method of obtaining the required '

system resistance for proper minflow operation

- is being changed by-the addition of these new .

orifices and the resizing of the existing orifices.

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Annual Plant Modification Report July 1, 1991 Through June 30, 1992  :

Page 16 +

i iii) Does. this modification reduce the margin of safety as dafined in the bases for the Technical Specifications?

Answer _: No, since the short-stroke position of the minflow valves is- -not altered by this modification, Emergency Core Cooling System ,

(ECCS) response time is unchanged and the margin of safety is unchanged. The bases for .

Technical Specification Section 3/4.5 were reviewed in making this determination, i S

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Limerick Generating Station l Unit'l Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 17 .

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h Mcdification~No.:- 6079a1 .

A.

System: Fuel and Fuel' Handling B.

Description:

This~ modification upgraded the Unit 1 refueling platform.

C. Roanon for chance:

To improve the reliability, reduce fuel handling time, and ease future maintenance activitiea of the refueling platform. .

D. -Sofety Evaluation Suinmary:

-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 , no physical ~ changes are being performed which will af fect the platform's ability to  :

3 safely handle ' fuel assemblies and other  ;

components.

-ii)- Does ' this modification create the- possibility for an accident or- malfunction of- a different' type than any P

evaluated previously in=the FSAR?

Answer: No , the handling of fuel and the performance l p of other' activities were.not altered. '

iii) Does. this modification reduce the margin of safety as

-defined in the bases-for the Technical Specifications?

Answer: No,. .this' modification will not affect refueling platform handling activities, hoist load capacities, hoist raise interlocks or. the

• ability:to-load only rodded' cells.

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l Limerick Generating Station c

Unit 1 .

Annual Plant Modification Report  !

July 1, 1991 Through June 30, 1992 Page 18 r

Modification No.: 610441 i

r A. System:- Containment Atmospheric Control t B. pescription:  !

This modification-installed a 3/4 inch drain connectinn with a single shutoff valve and threaded cap between valvea ,

-1N-57-105 and HV-57-ll8 on the low volume exhaust line of' the- '

Containment Atmospheric Control (CAC) system at LGS Unit 1.

l C. Reason for Chance:

'The two inch low volume exhaust line piping configuration *

, creates a loop seal which serves no design fuaction.

The loop-

- s ea l. collects condensed water which may prevent exhaust of ,

gases through ~ the low . volume exhaust line. The drain connection will be used for occasional draining of any accumulated condensation-in the loop seal.

D. Safety Evaluation Summary: l i) Does this modification 2.ncrease the probability of occurrence or the consequences of an accident or  ;

malfunction of- equipment important to safety as previously evaluated in.the FSAR? *

' Answer: LNo,_ the addition of the drain connection does 1 not affect pressure boundary integrity of-the low- _ volume purge _ line and containment isolation. This modification e.es not alter the' design function, design criteria, or -j testing acceptance' criteria ~ for the affected ^

piping system. Consequences of a malfunction of the inboard containment isolation valve is ..

not .-increased-because of the -leak rate testing l

.which- was' performed on the drain .line .- .i isolation valve and the' administrative controls' which will ensure that- the valve remains closed'.

..-> . .. . _ _ . . _ __-. _ _._ _ _ _ - _ - . . _ . . _ _ . _ _ _ . - _ . . . . _ _ _ _ _ . - = _ - _ _ _ _ . _

Limerick Generating Station I Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 l

Page 19  :

, I ii ) .Does this modification create the possibility for an '

accident er malfunction of a different type than any evaluated previcusly in the FSAR? ,

l Answer:- No, the draia connection is designed to the l applicable Code and piping- specification requirements to assure maintenance of the pressure boundary integrity. Appropriate .

testing was performed on the new valve to assure containment isolation. This modification does not alter the design function _ of the affected piping system and i does not add any new equipment of a different type than previously installed.

i-ii) _ Does - this modification reduce the margin of safety as  :

defined in the bases for the Technical Specifications?

Answer:

No , the drain connection with a normally -

l closed valve was designed and tested in l- acccrdance with the applicable Code and piping

• specification requirements. 7 l-l y

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 20

.Modificarson Moa : 6133'l Steam Leak-Detection A.. System:

B. -Description:

This' modification reolaced the Riley Temperature Monitoring Instrumentation'- associated with the Steam Leak Detection System -(SLDS) for Unit 1 with General Electric's Nuclear Measurement' Analysis and Control (NUMAC) Leak Detection Monitors-(LDMs)', 'Ihis modification also makes chcnges to the power feeds of,the SLDS_and replaces Residual Heat Removal-

-(RHR)' temperature switch TSH-51-lSl.

C. Reasg;t f or Chancte:

The Riley. Temperature Monitoring System was replaced because it was a source-of_several-Licensee Event Reports (LERs) due

'to spurious trip signals which had caused system isolations on both ^ units. Also,. the Riley ambient and- differential-temperature transmitter switches required the lifting of the thermocouple 3eads to perform the monthly functional testing.

D.- Safety Evajuation Summary: .

i). Does this modification increase. the probability ofi occurrence or the- consequences of an accident or malfunction- of -equipment important to safety as

.previously evaluated in theLFSAR?

Anshe_r: r No, -this modification. only replaces the existing- analog. Riley , temperature monitoring instrumentation with more reliable- and

accurate equipment, lessening the probability of malfunction. No changes to the design function of the SLDS or any other saf ety-relatedJand important to safety systems were made, This modification is considered an enhancement to the'.SLDS because the new equipment is' more reliable and .provides

-improved accuracy with easily serviceable components.

Litterick Generating Station Unit 1 l

Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 21 ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Annwer: No , there were no changes made to the isolation logic of either the Nuclear Steam Supply Shutof f System (NSSSS) or the Emergency Safeguard Systems (ESS). The installation of the new equipment eliminates some failure modes and spurious perations inherent to the previous instrumenuation. Failures will be detected by an automatic self-test function whicn is a part of the NUMAC LDM design. The ImMAC LDMs have gone through extensive testing to ensure their reliability and accuracy.

iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No, the replacement of the analog Riley temperature monitoring instrumentation with the mi roprocessor based MUMAC LDMs will not affect any of the allowable design limits for the SLDS addressed in the Technical Specifications. Also, station personnel will be able to perform the channel check and the -

monthly functional test for each individual temperature instrument loop using the NUMAC LDMs as required by the Technical Specifications.

. ... ,_ _ --. _. . . ......-w_ . . - _ . _ . . _ _ _ _ . _ _ _

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 22 1

Modification No;; 6135-1

-A. System: Fire Protection B. . ,

Description:

This modification extended the existing Turbine Generator F.re Detection and Suppression System to provide fire detection and suppression for the turbine generator bearings and beneath the appearance lagging.

C.. Reason- for Chance:-

This r~iification-was -to modify and enhance the existing Unit

- 1 Turbbie Generator' Fire Detection and Suppression System.

. - D. Sa f ety : Eva_lua tion - Summatv :

- i) D'oes 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 , the added components are not safety-

. related-and have no-impact on safety-related i systans . The Turbine Generator Fire Detection and-Suppression System 1 is not an initiator of accidents.

i~i ) - Does this modification create the. possibility

for an j accident . or malfunction of a different type than any'  ;

evaluated previously in the FSAR?- ]

Answer:. No, the Turbine Generator Fire Detection and Suppression System and its components are not' initiators of uccidents. This modificntion-does not' introduce'any'new failure mods for any; important to safety equipment. of the plant.

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e Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 23 iii) Does this modi'fication reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No, this modificacion does not impact ariy  !

saf ety featurcs of the plant. The existing Technical Specification commitments related to the plant fire suppression and detection systems are not af f ected by this modification.

-Technical Specification Sections 3/4.7.6 and 3/4.3,7.9 . were reviewed in making :this

, ' determination.

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lw Limerick Generating Station  :

4 Unit 1 Annual Plant Modification Report  ;

July 1, 1991 Through June 30, 1992 Page 24 Modification No.: 613741 A.

System: Plant Computers and Samac B.

Description:

This modification added a Radiation Area Access Control- (RAAC)

- system for Unit-1. The RAAC system provides permanent

-stations outside of'nine (9) . radiological area access points, p , Each station provides. corporate computer and telephone access and the capacity for future installation of an electronic dosimetry system.

C'. ' Reason-for Chance:

' This modification enhances the radiation monitoring _ capability of- the. plant 'perconnel- and allows Health Physies (HP) -

personnel the ability-to view and print' essential radiological exposure data;and Radiation Work Permit (RWP) data. ,

D..  : Safety Evaluation Summary:

i) Does this modification increase the probability of occurrence or the- consequences. of an- accident or malfune.: tion - _ of equipment important to safety as <

previously-evaluated in the FSAR?

Answer: 'No , this modification meets design, material, and construction standards applicable to the systems modified.: These changes make ,

. additionsLto the plant telephone and security a L systems, but all components are nonsafety-E-, -related and have no-impact on safety-related ,

systems. Physical and electrical separation .

was considered to isolate safety-related syctems'and. components.

'ii) Does. this modification ' create- the possibility for an H acciden; or malfunction of a' dif ferent type than any L evaluated'previously in the FSAR7 l\ l Answer: 'No, this _ modification does not create : the

_ potential for any type of _ accident because the components are not: accident initiators. This L modification' does not affect any. safety

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structure or_ component of the plant.

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- Limerick Generating Station Unit 1 Jmual Plant Modification Report

! July 1, 1991 Through June 30, 1992

Page 25 l

l i-

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iii) Does this modification reduce the margin of safety as  !

defined in the bases for the Technical Specifications?

i.

Answer: No , this' modification is in accordance wit'h ,

the Technical Specifications commitments related to the radiation protection program.

This change does not affect any safety features of the plant.

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, Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 26 .

Modification No.: 6139"1

~

A' . System: Snubbers B. -Description.

.This modification-is Phase A of the Limerick Snubber Reduction

-Program. Phase A removes snubbers from Unit 1 anchor to '

anchor piping systems that have similar piping configurations s to corresponding Unit 2 calculations.that were a part of the Limerick Unit 2 Snubber- Reduction Program.

The specific systems' invcived in this modification are Main Steam (Outside Containment), Diesel Generator. Standby Liquid control, Reactor Pressure Vessel (RPV) Head Vent, Main Steam Drain, and I g Fuel Pool Drain piping systems.

. C .. Reason-for Chance: 9 This modification is a part of the Limerick Snubber Reduction Program.-

D. .S3fstii Evaluation Summary:

j i) Does this modification increase the probatility of occurrence or the consequences. of :an accident or malfunction: of equipment important to safety as previously evaluated in the FSAR?

Answer: -No, the small- pipe line break is already considered in the probability of the Design Basis Accident. The-pipe break effects will not.have'an adverse impact on the design bases of any equipment important to safety inside the drywell. ,

ii)- Does - this . modification create the . possibility for an accident or malfunction of a - dif ferent t,pe than any-evaluated previously in the FSAR?

-Answer: No, snubbers were not removed from any piping system where equipment or components could not be qualified to withstand the etfects of pipe whip- and still perform their intended L function.

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i-Limerick Generating Station Unit 1 .;

Annual Plant Modification Report -l

July-1, 1991 Through June 30, 1992 Fage 27 1

1 iii ) Does this modification reduce the margin of safety as_ i defined-in the bases for the Technical Specifications? 1 Answer: No, the margin of safety as defined in the basis- of any Tachnical Specification is unchanged from previous values, because the effects from a postuleted pipe break at the new location is enveloped by previous analyses.

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Limerick Generating Station Unit 1 y*

Annual Plant Modification Report  ;

July 1, 1991 Through June 30, 1992 Page 28 Modification No.: 6168al A.- System: Feedwater B. Descrintion: ,

1 This modification installed a high point-vent on the suction piping .of each Reactor Feed Pump (RFP) 1AP101, 1BP101, and 1CP101, downstream _of the suction valve of each pump.

+

C. Reason for Chance:

~-A method to vent entrapped air from RFP suction piping from the: suction valves to the pump inlet was Leaded.

t D.- . Safety Pvaluation Summary:

i) Does- this modification increase the probability of -

occurrence or the consequences or an accident or malfunction of equipment important to safety as previously evaluated in the FSAR?

Answer: No, the _ vents were installed per existing design, material, and construction standards applicable to the feedwater system. This modification = does not affect any equipment.

important to safety. This, portion of the '

-feedwater system is not safety-ralated and'is not required to be operable following a-LOCA.

.. i i ) Does this modification create - the possibility for an accident or malfunction of a- dif f erent ' type than any evaluated previously in the FSAR?

Answer: No , this modification : installed additional vents in the feedwater system similar to existing '. vents in the systen:. Addition of vents to the feedwater system'does not. create ,

the: possibility o f .. malfunction of any ,

equipment important'to-safety.

- . - . 1

-iii) Doesichis modification reduce _ the margin . of saf ety as~ l defined in'the" bases'for the Te hnical Specifications? )

Answer: Technical Specifications bases and UFSAR Section 15.0 were reviewed and no applicable section exists.

)

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-i Limerick Generating Station Unit 1 Annual Plant Modification Report

- July 1, 1991 Through June 30, 1992 Page 29 Modification No.: 61T141 1

A. System: Instrument Air B;- _pescriptien:

This modification-chaaged the process tap locations for

PSL-356110/210A,B, sitnal for-the Main Control Room (MCR) low

~

presore- alarm, ar d PT-15-120/220A,B, signal for the MCR pressure ibdicator, to'a common process tap (previously used for PSL-15-140/141 anc 240/241) downstream of the Instrument Air-Dryer'PacNage on the air header.. This tap _is also used for-the' local pressure indicator added by this modification.

Process . taps f or PSL-15-140/14' and 240/241 were changed to the' taps used 'or PSL-15-110/2.t0A,B, thereby maintaining an

~

air _ receiver lu- pressure signal to the MCR, as a digital computer point. The old pracess taps for PT-15-120/220A,3 were capped.

TC.- Feason-for Chance:

Instrument air header pressure was not adequately monitored in theJMCR. A: low pressure condition in the instrument air

-header couldiexist_ prior to any indication or alarm in the

,  : MCR .'

p '

D. : pafety Evaluation Summary:

• i)- Does_ this modification increase the probability of

. occurrence- or the consequences of- an accident or n: , malfunction of equipment important to srfety as k previously evaluated in the-FSAR?

Answer: No, 'this modification does not impact the i

4 jE ,

Linstrument air system's ability to perform its

. design basis function. These instruments

' perform . no safety-related function and are used -' for alarm and indication . only. . This- ,

p -

modification does not introduce a new failure mode nor. adversely affect equipment important

%fW j to safety.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 30 1

• =

ii) Does this modification create the possibility for an accident or malfunction of a different type than any j evaluated previously in the FSAR? l Answer: No , this mc dification does not change the function each device performs within the instrument air system. It enables better l indication and alarm monitoring of the I instrument' air header versas the receiver pressures which allows for quicker response and recovery from instrument air trouble. No other equipment important to tw fety relies on '

the operability of the devices invc1ved in this' modification. These devices have no safety-related function, iii) Does this modification reduce the margin of safety-as defined in-the bases for the Technical-Specifications?

Answer: No, the Technical Spec.fication does not address the Instrument hir System. Technical 6; ecification- Sections 3/4.3, 3/4.6,- 3/4.7-,

l and their bases have been reviewed in making this determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 31 Modification No.: 6182'1 A.

System: Reactor Water = Cleanup

Description:

. B.

This modification rerouted the Reactor Water Cleanup (RWCU)-

Precoat Tank overflow line to install a tee and associated valves to run the overflow line to the Dirty Radwaste (DRM) system during backwash ~ of the RWCU Filter Demineralizers-(F/Ds)'. In addition this modification cut and blanked a

. oortion of the recycle line, 2" - HBC-132, as a measure to t ensure the isolation of the precoat tank during F/D backwash.

o C. Reason'for' Chance:

This modification is to eliminate the possibility of a single

- active f ailure from contaminating the RWCU Precoat Tank during backwash operations of the RWCU F/D's.

Safety Evaluation Summary: -'

D.

i) - Does. this modification increase the - probability . of occurrence- or the consequences of an accident 'or malfunct on of equipment important to safety. as

. previously evaluated in the FSAR?

Answer: No , this- modification does not change the design or. the function of either the' floor q drain system or its collection tank. The drain system.' does not require or affect-the ,

operation of saf ety - related .. equipment . The '

removal of a portionlof the F9C-132 line does not impact the operation'of t-3 RWCU system.

.ii) Does this modification create the possibility for an accident 'or malfunction of a dif ferent type than any-evaluated previously.!n-the FSAR? ,

Answer: No, this modification maintains the original ,

design conditions of the RWCU. syst em. It will lL not cause'a new malfunction.of safety 'related

!- equipment since the floor drain system is-

!, passive and: the modification is in accordance with all current- design standards for the RWCU system.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 3' iii) Does this modi'fication reduce the margin of safety as defined in the bases for the Technical Specifications?  ;

Answer,a No , this modification does not change the system in any way and does not reduce the  ;

system performance, therefore, the margin of 1 safety. as. described in the Technical l Specifications is maintained. j 9

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_ Limerick Generating Station Unit 1

'=

Annual Plant Modification Report July 1, 1991 Through June 30, 1992 i Page 33 J i

Modification No.: 6183'] l A' System:- Reactor Enclosure Heating, Ventilation, and ' Air  !

Conditioning (HVAC) and Standby Gas Treatment j System (SBGTS)

B . _-

Description:

'4his mooification increcsed the secondary containment blowout pinel actuation setpoints in the Reactor Enclosure (RE) from ,

0.25 paid to:0.5 psid.

n; C. Reason for Chance:

There was a site event involvina actuation of RE blowout panels which resulted in a Licensee Event Report (LER).

^

D. Safecy-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?

a Answer:- No, increasing- the. panel release setpoint

> makes a . loss of secondary containment less likely. The blowout panels have _ maintained 1 their Seismic Category I installation criteria. Environmental qualification of-important to safety components, equipment, and systems have not been af fected. The secondary containment = differential pressure due to fan pressurization is less than that due to tornado depressurization.

'ii) Does this modification create the ponsibility for an accident or -malfunction of- a dif f erent . type than any .

evaluated previously-in the FSAR?

~

l Answer: No , the blowout panels are not initiators of L_ acciden' . The blowout panels were installed L' -in ac. -dance with Seismic Category I L criteri.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 34 iii ) Does this modification reduce the nargin of safety as defined in the bases for the Technical Specifications?

i Answar: - No , increasing the secondary containmelit blowout panel actuation setpoints does not impact any safety features of the plant.

Technical Specification Section - 3/4.6.5 was reviewed in making this determination, ,

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l Limerick Generating Station Unit 1 ,

' Annual Plant Modification Report l

July 1, 1991 Through June 30, 1992  ;

Page 35 i l

i NCR-No.i. L-90224

.A.

Systems: Compressed Air {

B.- Descriotion:  !

This Nonconformance Report (NCR) replaced _the copper tubing connecting the backup nitrocen bottle to the service air .

supply piping connected to the intiatable seals with stainless .

. st_ eel, replaced.the brass' valves with stainiess steel valves

'to be compatible with the tubing, and installed the missing valves..-_ Inflatable seals which are the Spent Fuel Pool (SFP) '

gate seals, are not being upgraded because the 1/4 inch copper tubing-is acceptable.

C. _ Reason for-Chance:

4 This NCR was issued to restore the design to the original configuration as shown.in the P&ID.

D; Safety Evaluatio'n Summary:

~i) Does ' this mo,dification~ - increase the probability of

. occurrence- or= the- consequences of an accident or-6 malfunction of- equipment- important to safety as ^

4_, previously evaluated in'the.FSAR?

Answer: ~ No , the Se::vice Air System and the inflatable seals 'are not initiators- of an accident

_previously evaluated in the UFSAR. The' repair meets the design, material, and construction

. standards ' applicable to the. service air supply.

to the' inflatable seals per the_ original design,. Safety-relate d systems are not involved-in the repair activity, ii) -Does- this modification : create _ the - possibility ' for an accident- or malfunction of a dif ferent type than any evaluated previously-in the FSAR? ,

t g Answer: No, the tubing . run f rom the nit rogen bottle to  :!

the service ' air piping does not impact the  ;

functionality of the - ni trogen bottle. The I nitrogen bottles and the inflatable seals will i- function as originally designed. 3 L

.l l

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Limerick Generating Station Unit 1.

Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 36

l t

- * - iii ) Does this modification reduce the margin of safety as j defined in the bases for the Technical Specifications?

Answer: The inflatable seals are not discussed i'n detail in the Technical Specifications. The Technical Specification Section 3/4.6.5 and their bases were reviewed in making this determination.

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m Limerick Generating Station Unit 1

' Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 37 NCR Uo.: L-91151 A. System: Residual Heat Removal (RHR)

B. Descri'ntion:

This activity removes the motor operated valves' (MOVs),

HV-51-1F026A and B, maintenance from the Environmental Qualification Report (EOR).

C. Eg,95 L W Channe HV-51-1F026A and B are installed in the steam condensing mode of the RHR system and are normally closed (de-energized) . The steam condensiny mode of RER has been eliminated per DCP-0493, theaby deleting the active safety related function of these valves. Investigatien revealed that the MOVs are tested by several surveillance tests which are performed when the unit ir in OPCON 4 or 5 only. Therefore, the existence of a potentially harsh environment and an Environmental Qualification (EQ) common cause failure is eliminated and an EQR is not necessary.

D. Safety Evaluat ion Summatv: _-

Does this modification increase the 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, HV-51-1F026A and B have no active safety function because the steam condensing mode of RHR has been C91eted per UFSAR Section S 4.7.1.1.5.

ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, the non-conformance is related to maintenarce tasks not performed as required on HV-51-1F026A and B. These valves do not have an active safety function.

~~"~---aum ~

f ",.y Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 38 iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specificaticas?

Answer _: Na, Technical Specifications Sections 4.3.2.2, 4.3.3.1, 4.3.3,2, 4.5.1.C.1, 4.5.2.1, and 4.8.4.2.2 were reviewed in making this determination.

d

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 39 NCR No.: L-91236 A. System: Miscellaneous Instrument Systems B.

Description:

This Nonconformance Report (NCR) involved an Instrument Setting Change Request (ISCR) no.91-047 which requested approval to increase the alarm setpoint of the Unit 1 Loose Parts Monitoring System (LPMS) f rom three times the background noise level to six times the background noise level.

C. Reason for Chance:

The alarm setpoint change was requested to reduce the number of f alse alarms, thereby increasing operator confidence in the 3 LPMS.

D. Safety Evaluation Summary:

i) Does this modification increase the probability of _"

occurrence or the consequences of an accident or mal. function of equipment important to safety as previously evaluated in the FSAR?

Answer: No , the LPMS does not automatically initiate any automatic control, actuation, or trip functions of plant systems or equipment. The LPMS or the information supplied by the LPMS are not solely relied on by plant operators to take safety-relatei actions.

ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, increasing the LPMS alert setpoint does not change the functionality of the LPMS, the methods by which the LPMS identifies and locates loose parts and conveys that information to plant. operators, or the f ailure modes of the LPMS.

i

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 40 iii) Does this modi'fication reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No, the LPMS will continue to provide monitoring capability of the primary system to detect loose parts in accordance with current Technical Specifications and consistent _with _

regulatory guidance. Technical Specification 3/4.3.7.10 and its - bases were reviewed in making this determination.

4 O

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Y Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 41 b,

A: ..

. -- ~ .

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r i l '. ; y:.y n  ;.; , q Reactor Vessel n;f

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3. a Nonconfornance Report. (NCR) refers to the analyris of llaneous objects lost in the Reactor Vessel.

• dgy s C. Rea u 'wr Chance:

-This . .x

'% 9,

. uns to review the cumulative affects misceia.aneous objects to determine that there is no ct _omise made for' safe react.or operation .

D. Saf e-tv Fvaluation : Sutmvtry:

i) Ut. thin modification increase t h. .- probability of

,a occut Jw or the consequences of an : _ident or malfu'._. ion of. equipment important to cafety as-4 previouc]y evaluated in the FSAR?

Answe . No, the addition of these objects and the cun.ulative affects of other previously lost J

objects -in the reactor do no affect ny accident initiators. The lost objects will not adversely affect the chemical or

• se, metallurgical environment, will not block s y --control rod operation, will not cause fuel  ;

o >

bundl e #. low blockage, will not adversely s affect Residual Heat Removal (RHR) system M operability,, and will not cause dam ge to a jf other reactor internal components, w .i4) .

Does this mccification create the possibility for an accident- or malfunction of a different type than any evaluated previously in the FSAR?

Answer; No, the lost . objects will not create a chemical or corrosion, concern A.d will not

. - croate the potential for damage to reactor it.ternal components.

iii) Doee- this modification reduce the margin-nf safety as-defined in the bases for the Technical Spefications?

Answer: No, reactor water chemistry limits and reactor

. performance will be s".'f"ected.

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Limerick Generating Station l

• Unit 1 Annual Plant Modification Report

$ July 1, 1991 Through June 30,- 1992 Page~42-u >

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SP-T-008 P

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A. Syst ern: Feedwater  ;

M .

js B.- poscription: ,

t _

• 1. > . This_ test performs a feedwater flow measurement using "H.  ! radioactive. Sodium 'tNa24). tracer ~at Limerick Generating h Station Unit =1.

C, Peason f,pr Chance:- *

[ - Thisl tent.uis pertormed for on line flow measurements using a l

> cradioactive tracer to verify whether there is any: discrepancy-p M' in thelfeedwateriflow measured by.the venturis.

Saf et'v' Jdblatiop_gunmarz:

,,1 LD.

ci); 1Does - thic1 modification increase- the probability: of

. occurrence '.or: thet consequences . of _ a n' accident or 10 '

. mal. function . of equ.ipment important to' safety as y

~

Lpreviods'ly evalaated in' the FSAR?

Ansygr.: No,Lthe .tnjection of sodium nitrate (NANO 3) m ' ha t, no signifidant ef fect on the materials of'

.the reactar -or

Iuel cladding. : The 't:st is

,, done under nonnal -operation of L the unit. The ,

4, ,l 4 introduction of Na24- causes only 'negligs sle  ;

"s

, increase inithe-reactor coolant 1 activity.

,i V .:ii) i Does ithise n.odification create- the possibility E for an

-l La'ccident: or ' malfunction of a dif f erent type -- than:T any E 4 evaluated previously-in the FSAR?

• b " '

Answer: 'No,- the offectstof: such a- . small: quantity of r .

.n nodium nttrate onithe- componentsh of reactor:

l, 3 afessel, fuel cladding, and components- of.

'feedwater syste:n are negligible'. -

The increase :

s fin main steam E line radi nLion is within the l Y -

- normal ~ operating limits.

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Limerick Generating Station Unit t

-Annual Plant Modification Report July 1, 1991 Through Juse 30, 1992 O Page 43 -!

i P -ili) Does ' this i modi 2fication reduce the margin of safety as ,

defined in.the bases for the Technical Specifi ations?

Answer: . No, -- the 1 eactcr cot le;.nt chemi,. r a M ectividy remains wel1 within allowable 2 ini-; o snd the main steam line radiation incre_se is ,

negligible. Safety Limits and: Limiting Safety-Systems settings Technical Specifications.and-bases ~ ( 2 . 2 .1 ) -, Reactor . Coolant Chemistry Technical 592cification and bases '(3/4.4.4),.

Reactor - Coolant Specific-7 ctivity Technical ~

Specifications and bases (3 / 4. 4. 5) , and UFSAR

+ Sections 5.2.3 and 15.0 were reviewed in ,

making this determination.

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Limerick-Generating Station Unit-2 Annual Plant _ Modification Report July 1, 1991 Through. June 30, 1992 Page 44 .

4-Modification No.: 5342"2 A. , System:- Condensate Filter Demineralizers

. B '.

Description:

- This 1 modification installed .ew - inlet and outlet is Lation valves'for the condensate filter demineralizers during a plant shutdown.

4 C. Reason for' Chancre:

This modification provides positive means of isolation, as 2 ~

needed, and enablee on-line mainter ance of the existing valves which . control. the. flow through the conciensate filter

- demineralizers; D.- Safety Evaluation' Summary:

i)i  : Doe 3 this' modification increase the probability -of F occurrence or. the- consequences of 'an accident or L

malfunction; of-; equipment important to safety as p'eviously evaluated in.the FSAR? );

~ hnswer: No, the new7 isolation valves-do not impact the j

< -normal: operating conditionsLof the condensate filter demineralizers. - This modification does - .

not change; ' degrade, or prevent the response of-active or. passive-systems. )

11) = Does - this : modification create the possibility forLan-

accident or ' malfunction of- a= dif f erent type than any

- evaluated previously_in the FSAR?

Answer: No, 'this ' modification- does -not- affect -l

^

_ equipment- important'. to -safety or safety i related' systems. This modification meets the 9 seismic specifications for- this . system and_ the

,origina'1' design specification ' f or materials-

"nd construction practices.

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.h Limerick Generating' Station Unit ~2 Annual Plant Modification Report '

July 1, 1991 Through June 30, 1992 Page 45 iii)'Does this- modification reduce the ' margin of .saf ety as defined in the. bases for the Technical Specifications?

this modificationdoes -not involve 'a Answet: No,

. change in the initial system conditions or response time which affect' the course of an.

accident-analysis-supporting'the bases of the Technical Specifications. Technical Specifications 3/4.4 and 3/4.7 were reviewed

.in making-this determination.

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Limerick Generating Station .

Unit 2-Annual--Plant Modification Report July 1, 19" Through June 30, 1992 Page!46

, y i Modification No.: '5515-2

-A. "vstem: Feedwater "B.

Description:

~

This modification' changed the typa of coupling installed.

'between the Reactor Feed Pump 2B-P101 and its driver turbine 2B-S105.

1

-C._ Reasonefor-Chance:

This! modification replaced .the existing - gear-type coupling-  !

with -_ a _ dry coupling'; to . eliminate Reactor Feed : Pump (RFP) 0 4 vibration t. hat was experienced .during continuous operation of

.the existing Unit _1 gear-type couplings.

.y :Safetv Evaluation Summary:

Li) ~ -Does this:= modification increase the probability of occurrence -or the - consequences of an; accident' or

= malfunction of equipment- important to. Safety as

' ' previo6 sly evaluated in the FSAR?'

- ~ Answer: No , t.he RFP, its' driver turbine, and

. associated components, such.as the coupling,

.z are not: safety-related equipment. Failure of the coupling:doec not compromise any safety-5 'related -system or component and does not prevent a . safe shutdow.. of the plant.

This-modification' reduces the probability of.a loss by improving of -.f eedwater - accident the reliability of the coupling connecting the_ RFP

, -to'.its. driver turbine.

R l 'ii)  ; Does - this modification : create the possibility f o r .. an -

a sident oromalfunction: of, a different type than any j evaPtated previouslyJin the: FJAP.? i

- Answer: No, J the only accidents which could result f rom' I ialfailure_of.the. coupling and resultant loss ofnfeedwater flow have already been analyzed

. in 1FSAR Section 15.1.1, 15.2.7, and e n i 15.9.6.3'.F.n.

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Limerick Generating Station Unit 2 Annual Plant Modification Report July 1, 1991 Through June 30, 1992- -

~

Page ( '

-i i

L I

- - iii) Does: this modification reduce the margin of safety.as l

- defined in the bases for the Technical Specifications?

Answer: No, the' RFP coupling has no Technical

- Specification requirements. Technical-Specification 3/4.3.9 was reviewed in making this-determination.

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Limerick Generating Station Unit 2

• Annual Plant Modification' Report July'1, 1991 Through June 30, 1992 Page 48-4 Mod'ification No.: 584a^2 A. System: Reactor Enclosure Heating, Ventilating, and Ai'r Conditioning' -(HVAC) and Standby Gas ' Treatment System (SBGTS)

B.

Description:

This modification removed the trip capability of the low temperature switches TSL-76 7205 and TSL-76-215 for the Unit 2 Reactor. Building and Refueling Floor supply fans.

C, .R,ason e for Chance:

This modification prevents . spurious Reactor Enclosure and

= Refueling Floor HVAC supply fan trips caused by stratification' of : the - cold supply air. Spurious tripping of-these fans-causes 1 unnecessary startup - of the ~ SBGTS . The temperature

. Switches require manual ~ resetting after tripping.

D. Safetv Evaluation Summary:

'i) Does this modification increase the probability ~ of

occurrence: or the ccnsequences of an accident or equipment -important .t o safety as

-malfunction of

_previously evaluated inlthe.FSAR?'

l Answel: No, the function' of .the low, temperature switches is replaced-by Station Procedures.

Active ~or passive equipment that respond to an; y' accident Jwill not be changed or degraded-by.

1this modification.

ii) ~ Does this modification - create - the possibility for an accident or- malfunction - of a ' .dif f erent type than any

-evaluated previously-in the FSAR?-

' Answer: No, the reactor-enclosure and refueling' floor supplyJfans have no safety-related function.

-The originel design intent .of the reactor c enclosure and refueling area supply fans:.are not affected by this modification.

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Limerick Generating' Station Unit 2 Annual Plant Modification Report July ~1, 1991 Through June 30, 1992 Page 49 i

" - - iii ) Does this modification' reduce the ' margin of saf ety as -

. defined in the bases for the Technical Specifications?

'Answel: No, this modification does not affect- the

- safety-related part of the reactor enclosure and refueling area Irv'AC systems. Technical Specifications Sections 3 /4.3.2 and 3 /4.6.5 and their bases were reviewed in making-this-determination.

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Limerick Generating Station Unit 2

^ '

3 Annual Plant Modification Report July 1,.1991 Through June 30,:1992

~

-Page 50-j .c .

~~ ' Modification No,: 595642 p , A. Svetem: Feedwater.

B.

Description:

!This modification! installed General Electric's Zinc Injection Passivation - (GEZIP)- system .on . Unit 2.

. C.= Reason for Chance:

The presence _of trace amounts of soluble zinc in BWn reactor water-hascbeen:shown to considerably reduce radia ion buildup

~

on primary piping.and components. The GEEIP prevess consists of a! skid-mounted- injection ' system for introducing a continuous dilute solution of zinc oxide into.the-feedwater 4 o system.

D.  : Safety Evaluation Summatv: }

il Does; this

modification increase the probability of

. . occurrence ,c the consequences- of an accident or Lmalfunction as

~

of equipment important to safety

-previously evaluated in the FSAR?

m- Answer: No,-? loss of power'to thE. GEZIP system will not 2

-cause a loss of feedwater-to the reactor via U an inccrrect valve line-up; check valves nave i been incorporatedeintolthe design of the zinc- 1 injection piping 'to insure that the

.. probability of occurrence of loss of feedwater s to' the reactor is not increased by _ this ,

modification. The ef fect of traces of soluble

> zine in the feenwater has'beenifound to have no- adverse ef fects ~oni plant materials or on-

\ BWR-fuel.

ii) Does i"1. -modificatier creatc ~ the _ possibility for an saccident or malfunction . of . a different type than any a  : evaluated;previously in tho'FSAR?

. Answer: No, the GEZIP system-is not expected to_have any adverse; ef f ects on the reactor pressure vessel,- fuel cladding, parts of- the- fuel assembly, or-the' primary system piping. 'This

-modification' installs -non-safety- related equipment ~-in a non-safety related area of the

-plent.'.

- .- ~,  ;.-.-, - , , , . . - - , . - , _

1 l

Limerick Generating Station Unit 2 Annual Plant Modification Report July 1, 1991 Through J'ine 30, 1992 Page 51 iii) Does this modification reduce the margin of safety as defined in tne basas for the Technical Specifications?

Answer: No, the installation of the CEZIP sys t er6, including connections to the feedwater system and the demineralized water system, does not alter the intended function of the systems _

involved. Technical Specification Sections 3/4.3.9 and 3/4.4.4 and their bases were reviewed in making this determination.

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~ Limerick. Generating Station:

Unit 2

• Annual Plant Modification Report July 1, 1991 Through June 30, 1992.

Page 52 w

"- 14pdi fication No. : 6097'2

- A. Sys t en - Plant Comput,ra and Samac Bi - Des'crintion:

This - modification upgraded tne Safety Parameter Data System (6PDS).~ portion of . the Plant Monitoring-System (PMS) to make the -screen / curve display' agree -with the Transient Response

, 1 Implementation: Plan:(TRIP) procedures.

<  : C. Reason for: Chance: I

+

This modification-upgraded the Unit 2 PMS SPDS to reflect the

-revision" of. the~-=BWR Owner's Group Emergency- Procedure ,

Guidelines-(EPGs),, Revision 4.

• 2 D. Safety Evaluation Summary:

i) Does this modification increase the probability of.

1 occurrence or -: . the- consequences- of an accident ot inalfunction. _ of ~

equipment -important- to_ safety as ,

previously evaluated-in the FSAR? j 1

. Answer: No,- _ this - modification does unor affect .the d

-Class _lE! input modules to:PMS. A failure of

PMS can not render a malfunction of the Class 1E: input modules _ to .PMS_ due to its circuit

, isolation-capability; . .;

ii) Does this" ~mor" fication create the- possibility for an

.accidenti or ualfunction of ~a ' dif ferent type than any y"~

evaluated previouslysin the FSAR?'

t Answer: No, the' circuit isolation capability of Class

- . lE. .PMS input - _ modules will not be affected, ensuring' that no failure of PMS can 'be leflected back into the-safety systems.

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Limerick Generating Station Unit 2 Annual Plant Modification Peport July 1, 1991 Through June 30, 1992 Page 53 s

' iii) Does thin modification reduce the margin of satety as defined in the bases tor the Techttical Specifienticns?

snswer- No, SPDF will be operational during all tuodes of reactor operation defined in Technical Specifications table 1.2. The operability of SPDS d'es not constitute a L2O for operation becauoe nard-wired Class lE instrumentation is available in the Control Room if SPDS is inoperetbl e .

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34

- Limerick Generating Station Unit 0

- Annual Plant Modification Report

• - July 1, 1991 Through June 30, 1992 _!

Page 54 ,

I

~ .

' Modification No.: 6108e2

- A .- - System: DC.-Systeme .

E.

Description:

This modification' replaced the underrated fuses in the 125/250V DC Motor Control Centers '(MCCs). and panels, and anded <

a' second set o f C l a s s .- l E fuses / fuse blocks for the High

. Pressure Coolant - In j ection/ Reactor Core Isolaticn' Cooling

, (HPCI/RCIC) _nonsafety related pump motors and new fuse holders on.MCC 20D20T, Compartments 01, 02, 03.

C. Joason^for ynance:

The'125/250V-DC:MCCs and panels were. replaced with properly-

' rated L fuse's capable- of. meeting-' the design requirements for voltage; rating and' interrupting capability.

D.

i Syfety Evaluation Sumr.arv:

i)- lDoes?:this modification _ increase the _ probability of occurrence or the consequences of an- accident - or 4 x malfunction of equipment- important to safety as l previously' evaluated in.the'FSAR?  !

Answer: . No, f this ' change _ 'will have L n impact on-the

,a'ccidenq analysis _ - described. in the- FSAR Chapter 15. 1The rep.Lacement of _ underrated

. fuses in: the .MCCs. and _ panels bring - this equipment . ie.ofcompliance wih the original'

' design - intent.

This modification- does not l --degrade' any : system structure or component reliability' and therefore' all- systems, .

structures fand components perform as 1 previously designed, b ii) Does this -modification create- the _' possibility (for an.

accident- or- malfunction of; a - dif ferent type than any

' evaluated previourly-in~the FSAR?~

Answor: No ,' the -installation of properly rated fuses,

' new Lfuse blocks, and_ series connected fuses

' m e e t s ._ t h e original design criteria' with no effcet on -the SAR accident analysis, and

• brought this equipment - into compliance with the1 original ~ design intent for ' the DC ' Power j, Distribution System.

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Limerack Generating Station Unit 0 Annual Plant Modification Report July 1. 1991 Through June 30, 1992 Page 55 ii i ) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

Answer: No, the changes 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. Technical Specification --

Section 3/4.8.2 and 3/4.8.3 were revieved in making this determination.

--*.---_----_-_____.__.___._______._m_ _ _ _ _ _ . . _ _ _ _ _ . , . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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Limerick Generating: Station

. Unit 2 Annua _ Plant Modification Report

-July 1,.1991 Through June 30, 1992 Page 56 l

-a >

. l H

l -~

Modification No.: 6115"2 l

1 1

? A. System: Electro Hydraulic Control (EHC)

B.

Description:

This mocification added hydr.V .c accumulaters, valve manifolds and. associated one inch sping and fittings.to the EHC; System Fluid. Actuator _ Supply .FAS) for each of the four

mainiturbine control valves. Also, P AS tubing routed f rom the .

EHC unit to the control valves were replaced with schedule 80 stainless steel piping and associate 3 hanger material.

?CL . Reason?fer-Chance:

.This modi'fication provides increased Tydraulic damping of the EHC(system and' improves-the quality of_the welded' joints.

-Db -Safety Evaluation Summary:

4

~

i) Does this- 'n'odification : increase -the probability of occurrence. or; sthe consequences. of an accident or malfunction' of. equipment. 'important to safety as

_previously evaluated in.the-FSAR? j iAnswel:= 'No,..once the EHC -system hes 1 tripped,-the h -accumulators .are> isolated from the- trip

"" circuit,_ because ti. :y' are _ outside . of - the trip; boundary. The accumulators-will not prevent the _ EHC system f rom _ performing its ' design function. ' Th.ts . modification will lower the probability-of turbine trip events.

ii) Does thin' modification- create the - possibility f or an -

accident or malfunction of a - dif ferent -type- than any evaluated previously in~the-FSAR?

r

' Answer: - No , : the-EHC. system is:not-safety-related_cnd-its failure .does- not directly affect any-

equipment itnportant _ .to _ safety.

This modification does- not- introduce modes- of; f ailure - - that have not been. previously. 1

' considered. j L ~j 1

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'l i Limerick Generating Station .) '

Unit 2

. Annual Flant Modification Report 1

. July'1,: 1991.Through June 30, 1992 -1 Page 57 0': .iii ) Does this modification reduce the margin of caf ety ; as defined in the bases for the Technical Specifications?.

Answer: No, because-this modification greatly reducss the . obabi]'ty of EMC system weld failures ano subsequ .c loss of EhC, there will-be a- -

corresponding increase in past safety margins-due to a more-reliable EHC sysr.em. Technical

? Spec #ication Bases 3/4.3.1, 3 / 4 ~ 3 '. 8, and 1.2 .

were reviewed in making this, determination.

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t Limerick Generating Station _

Unit 2 '

Annual Plant Modification Report July 1, 1991 Through June 30, 1992-Page 58 Modification No.: 6120+2 A '. System: Reactor Water' Cleanup B.

Description:

.This modification replaced the existing 4" diameter Reactor Water Cleanup valve 44-HV-2F039 with another valve that.is a 3" diameter, but.using an improved disc design.

C. -Reascn fcr Chance:

The Reactor Water _ Cleanup valve 44-HV-?r039 had been found to leak excessively during.the Local Leak Rate Test.

D. Safety Evaluation Summary:

.i) -Does this modification sacrease the probability of

. occurrence or- the consequences- of an- accident or malfunction of ec 7 ment important to safety as previously evaluatec :. the FSAR?

Answer:. No, the valve meets or exceeds.the original ,

valve . purchase: order requirements for R material, design, testing, inspection and installation asLspecified.in the USFAR. The l ,

new valve'does not affect other systems since

'its- function or method of function 'has not changed.

'iii: .Does this modification create _ the possibility f or - an accident or- malfunction of a different type than any.

^-

evaluated:previously in-the FSAR?

Answer: No , the check valve continues to function as

. originally designed. The_new valve has been ev'aluatedLto have no impact _on Reactor Water Cleanup- system flow 'or functional. l requirements. :No other modifications are being l

- made.: to c.ny safety- related equipment or i equipment..important to safety. 'l Liii)- Does this- modification reduce the margir of safety as .

defined in the bases for the Tecbr.ical Specifications? l, Answer: No, the new valve - is designed - _to -_the-- same valve design specifications, qualification and .

I function as.the valve it-replaces.

. _ - ~ . . . . _ - . . . _ . _ m V Limerick Generating Station Unit 2 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 59 4 'l g m 6182"2

- Modification No.:  ;

E' '

A '.=. System: Reactor Water Cleanup B. -

Description:

' This modification rerouted the Reactor Water Cleanup (RWCU)

Precoat Tank overflowL line to install' a tee and associated.

1 Ve Lyalv'es to run the overflow line to the Dirty Radwree tDRW)

- system during backwash of' the RWCU' Filter Deminerdlizer3 g ..i?/Ds)..

C .- Reason- for Chance:

This modification is to eliminate the possibility of a single

. active f ailure from contaminating the RWCU Precoat Tank during

.- backwash operations'of.the RWCU F/D's.

D.- Safety Evc.luation-Summaryi i)- 'Does-Lthis' modification increasi -the probability of n ' occurrence or the consequences -of an- accident or malfunction of equipment important to- safety as ipreviously evaluated-inlthe FSAR?

, Answer: .No, this - modification' does1 not change the design or- the function of: ;either the . floor drain system ora its Ecollection. tank. The-drain system - does not require or af f ect . the -

~

~

operation'of safety _related. equipment.

lii)' Does. this modification create the -possibility - for ~an accident or- malfunction- of. a dif ferent type.than ~ any fevaluated previousl/ in'the FSAR?

Aris_.wer : No,-this modification maintains.the original design conditions of the RWCU system. .It will lnot-cause-a new malfunction'of safety related-

'___ m equipment since the 1 floor drain system is

!? passive and the modification is in accordance=

j. ,

with all current design standards for the RWCU' l:_

Tsystem.

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Limerick Generating Station Unit 2.

Annual Plant Modification Report July 1,.1991.Through June 30 ;?92

<; 60 l

4 i

iii ) Does this- modificatior. reduce the margin of safety as i

defined in the bases for the Technical Specifications?

Answer: No, this. modification does not change the system in any way and does not reduce the i I

systein performance, therefore, che margin of.

safety as described in the Technical Specifications is maintained.

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_ . Unit 2

" ' Annual-Plant Modification Report. ,

July 1, 1991 Through June 30,- 1992:

Page 61 a -.

v r.

Test No.: SP-T-009-l A'. . System: Feedw'ater ,

B. '

Description:

'This- test performs' -a feedwater flow measurement using radioactiveL sodium. (Na24) tracer at Limerick Generating

Station Unit-2. A similar test was'done for Unit 1. This review is; based onisome of'the actual data of Unit-1.

a.

," C. Reason'for Chance:

' .Th)sjtest is-performed-for on line flow measurements using a '

' radioactive tracer- to verify whether there is any discrepancy-

-in the.feedwater-flow measured by the venturis.

. D. Safety-Evalt' tion' Summary:

5 i) Does' this-' modification. increase the probability of g occurrence or ' thel consequences of an accident or

. malfunction. of _ equipment important to- safety as previously evaluated in the:FSAR?

A_nswer: No', the injection of -sodium nitrate (NANO 3) 1hasLno significant;effect'on the materials of

' the reactor- or f uel - _ cladding . The cest .- is Ldone under normal-operation-of the: unit. -The-

introductioni of - Na24 - causes only negligible increase in the reactor coolant-activity.

ii): - Does ': this .nodification create the > possibility -for an accider.? :or malfunction of a different type than an?-

evalunted previously in the FSAR?--

Answer: 1.No, the: effects of such a small quantity of sodium - nitrate on: the components of reactor.

vessel, - fuel- cladding, and components of-

.2 ifeedwater . system are negligible. The increase in main steam line radiation is within the-normal . operating limits.

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Limerick Generating Station Unit-2 Annual Plant Modification Report

' July 1, 1991 Through June 30, 1992 Page 62

--l iii ) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

l Answer: No,- the. reactor coolant chemistry and activit'y

- remains well within allowable limita and the-main steam line radiation increase is negligible. Safety Limits and Limiting' Safety Systems settings Technical Specifications and bases: (2.2.1), Reactor Coolant Chemistry .

Technical Specification and bases (3/4.4.4), I Reactor Coolant Specific-Activity Technical Specifications and bases (3/4.4.5), and UFSAR Sections _S.2.3 and 15.0 were leviewed -in i i

making this_deternination.

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t 7 _ Limerick Generating Station'

> > Unit 0

• Annual Plant Modification Report July 1, 1991.Through June 30, 1992-

-Page 63 y

,y Modification'.o.: '0949r0 l

A '. System: Communications

-B- .

Description:

.g This modification _ upgraded the existing power supplies to the Jplant telephone and. radio systems.

C. -Reason for Chance:

This- modification : increases the availability of the plant  !

. telephone;and radio' systems.

D. Safety Evaluation' Summary:

(Does this modification increase .the. probability- of N i) occurrence- 'or .the consequences of en accident or  ;

-malfunction' of equipment important to safety as i - previously evaluated in-the_FSAR?

y by- this R l Answer: No, those comr.onents installed l; - modification will not alter or 'af fect the function of any- components- required. for safety.

E ii) Does '- this modification-- create 1the possibility for an-F accident f or? mal-function of a different type than - any b

J ,

evaluated previously in the FSAR?

);  !-A-swer: No, this modification upgraded power supplies-to Dimension 2000,' Prelude, ENS, and-the. plant L-radio 'systemiand ~is in accordance with'the

' existing design . criteria for these systems.

L  ;

!g

- This - modification is an improvement to the-C communication systems and'-does not adversely K ' affect any safety features of the plant.

~iii)- Does 'this :- modification reduce'the= margin of safety'as idefined'in-the bases for the Technical Specifications?

Answer: -No, .the

- Technical Specifications- do not

._ address the -power- supplies to the -plant communication systems. .

Technical Specifications Sections 3/4.7.7, 3/4.8, and 3/4.9.S' were reviewed in making- this-

determination. ,

=

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a Limerick Generating Station Unit 0 Annual Plant Modification Report vuly 1,-1991-Through June- 30, 1992 Page-64' e.

N

. Modification No.: -5993-0

.A. ' System: Communications M- B.

Description:

.This modification upgraded the present radio communications

~

system between the Main Control Room, Remote Shutdown Panel '

l Room,-and. Operational' Support Center.

C. -Reason for Chance:

<The radio communications system was upgraded to one that will survive >and operate'duringLa-loss of power or a fire in'any -

given-areaLof the plant as described in the Fire Protection Evaluation Report (FPER) Appendix R.

D. Safety Evaluation Summary:

.i) Does this modification increase the probability of

- . occurrence or the : consequences of an accident or malfunctioa of equipment important to safety as

.previously evaluated in the FSAR?.

Answer: No, f ailure of any component associated-with this modification will-not affect any safety features of the plant.1 This change improved the radio communications. system-of the. plant and was ' implemented in accordance with the existing _ design criteria for the _ subject system.

ii) ~ :Does this modification ; create the possibility for an -

accident or- malfunction - of a dif ferent type than any.

evaluated previously in the FSAR?

Answer: No, -this modification was . implemented in accordanceLwith the existing-design criteria 4

=for the radio': communications - system and does

-not-introduce ainew mode of f ailure_ for any 1 safety-related equipment of the plant.

iii)~ Does .this- modification reduce the margin of safety as l

defined inLthe bases for the Technical Specifications?

Answer: No, this modification does not alter. the 4 intended function of the radio communications I W < system.

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Limerick Generating Station Unit 0

• Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 65 Modification No.: 6011-0 A. System: Communications B. Descriotion:

This modification extended portions of the onsite communication systems to the of f site Limerick Training Center.

Telephone, radio, and public address system equipment were installed in the Limerick simulator to parallel communications with the main control room.

C. Reason for Chance:

This modification was necessary to satisfy a corporate management commitment tilat all Limerick Generating Station emergency drill exercises would be performed from the s.imulator in lieu of the main control 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 , this modification will not cause any impact or malfunction to plant communications or any other plant system. No equipment that is important to safety was modified or _t s af f ected by this c' ange.

ii) Dta.3 this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

p3swer: No, none of the equipment installed is safety-related and does not affect anything that is safety-related, iii) Does this modification redure the margin of safety as defined in the bases for the Technical Specificationst Answer: Mo, this modification does not adversely af fect the capability for safely shutting down the plant. The Technical Specifications do not address the equipment or functions involved in this modification.

[;

• Limerick Generating Station Unit 0 Annual Plant Modification Report y - July 1, 1991 Through June 30, 1992 Page 66 n

k zModification No.: 6050 '

~

' A. System: Structures cB. Descrir> tion: ,

This modification installed new facilities to support:

s nubber ; testing, personnel anti-contamination clothing

. storage / issue, Unit 1 and 2 Condensate Ion Chromatography, and hot. tool storage / issue.

-- C . Reason for Change:

, .These- activitie' were previcusly housed in temporary facilities,Jwhich must be removed to allow Unit 1 and 2 Deep KB edjDeminerali;:er installation. .

~

D. Safetv Evaluation Summary:

' i) > Does. thic . 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, this modification is not safety-related and~ has- no impact on safety- related components.

Lii)! Does this . modification create _ the possibility for an

-faccident or malfunction of a dif f erent type than any evaluated previously_in the=FSAR?

Answer: LNo, this _ modification adds nonsafety-related -

facilities.and utilities in nonsafety-related ,

areas and- _has no . impact on systems. or o structures important to safety, ciii) Does-this modification reduce the margin of safety as

-defined in the bases -for the Technical: Specification:.3?

Answer: The snubber testing requirements described in-Technical Specification Section ' /4.7. 4 will not- be impacted by the new Sr.ubber Test

,' Facility. Although -- Fire Suppression System changes are being made in the Turbine

-Building,-- these changes will not affect Technical Specifications, Section 3/4.7.6 commitments. i

w.

Limerick-Generating Station Unit 0 Annual Plant Modification Report July 1, 3991 Through June 30, 1992 Page 67 Modification No.: 6141"O A. System: Fire Protection B. Descriotion:

This modification tied the Limerick Training Center Fire Protection System into the Limerick Station Fire Protection System.

C. Reason for Change:

This modification was necessary to provide adequate fire protection at the Training Center.

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, no safety-related systems are affected by this change. This UFSAR figure will not impact the design or operation of any safety-related equipment of the plant.

ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, no safety-related systems are affected by this change.

iii) Does this modification reduce the margin of saf ety as defined in the bases for the Technical Specifications?

Answel: No, the UFSAR figure change does not alter the intended function of the Fire Protection System. Technical Specification Section 3/4.7.6 was reviewea- in making this determination.

. _ _ = _ - _ _ _ _ _ _ _ _ _

1e

" Limerick Generating Station Unit-0 Annual Plant Modification Report-July 1, 1991 Through June 30, 1992 Page 68 Modification No.:

9084"O A. System: Plant Computers

- B.

Description:

To Irovide. data collection of river flow information-to Unit 1.

, C. Reason for-Chance:

To provide-river flow-information and' transmit data to the Control.-Room for Unit 1. Also, revise the-data links between Limerick Generating Station.and the Perkiomen and Bradshaw pumping: stations.

D. Safety Evaluation Summary:

ti) Does this modification increase the probabili.ty of

,._ -occurrence or- the consequences of an accident or malfunction of equipment-- important to- safety as previously. evaluated in the FSAR?

Answer: ;Noi the equipment-is not safety-related. The design of this modification is in accordance with the' applicable-system design criteria.

ii) - Does . this modification create the possibility .for an acci' dent or malfunction of a dif f erent._ - type than --any

. evaluated previously in~the FSAR?

' Answer: No,=the addition of data-and the modification of data Llinks' do not . degrade safety-related components or systems.

-iii) Does - this modi-fication reduce the margin of E saf ety as -

defined ~in the bases for the; Technical Specifications?

Answer: Noi this modification does -not - change = the operation 'or function of safety related systems. Technical Specification Section 3/4.7 was . reviewed. in making this determination.

I

Limerick Generating Station Units 1 & 2 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 69 NCR No.: L-91014 A. System: Control Rod Drive Hydraulics B. De scrit>t i on :

This Nonconformance Report (NCR) allows the Use-As-Is of Robertshaw scram valve palcs until part replacements can be completed during a normal maintenance schedule.

C. Reason for Chance:

A letter from General Electric stated that Robertshaw has been supplying essentially commercial grade scram valves, pressure indicators, and parts since the expiration of their "N" stamp in 1965.

D. Safety Evaluation Summ9rv:

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, with two exceptions (the heavy hex nut and bonnet nut) the scram valve parts are identical in design, materials, and construction and throughout all testa and actual operations to date, they have pertormed in an identical manner. Through analytical and experimental analysis, the two exceptions aave been proven by General Electric to be capable of performing their safety function.

The scram valves obtained from Robertshaw after expiration of their "N" stamp program have proven to be functional equivalents of the components available previously.

ii)- Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, use of the existing scram valve; cannot create any type of accident other than that described in the UFSAR. No new type of malfunction of the scram valves other than i that previously evaluated in the SAR can be l created by using the components installed.

_ . . _ . ~ . _ _ . . . _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ . _

Limerick Generating Station Units'1 &

• Annual-Plant Modification Report July 1, 1991 Through June'30, 1992 Page 70 iii) Does this modification reduce ~ the margin of safety as defined in the bases for the Technical Specifications?

Ansuer: No, system response time and all othsr-operational parameters are unchanged. This is supported by results obtained through surveillance testing. Technical '

Specifications Bases for Sections 3/4.1.3 were reviewed-in making this determination.

t

Limerick Generating Station Units 1 & 2 i

Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 71 NCR No.: L-91073

7. Svstem: Service Water B.

Description:

This Nonconformance Report (NCR) proposed that the venting of noncondensables accumulating in the Service ' , er System (SWS) be done manually.

C. Reason for Chance-Manual venting eliminates debris restricting the flow from cracked open vent valves that have been experienced with the continuous venting approach.

D. Safetv Evaluation Summarv:

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 , the SWS is not safety--related and is not required to mitigate any accidents evcluated in the SAR. Failure of the SWS does not compromise any safety-related system nr component, nor does it prevent a safe shutdown of the plant.

ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, improper venting is possible with either the continuous or the_ manual venting methods during abnormal conditions. No SWS equipment is safety-related and the proposed revision will not change the existing SWS equipment functional capability.

Limerick Generating Station Units 1 & 2 >

Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 72

.esesar.'-

- iii ) Does this modification reduce the margin of cafety as "

defined in the bases for the Technical Specifications?

Answer: This revision does not change the design basi's or functional capability of the SWS or equipment and does not adversely affect any ,

safety-related systems, structures, or g components. Technical Specifications '

requirements and basis applicable to this revision are not affected.

l i

Li 3 rick Generating Station Units 1 & 0 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 73 NCR No.: L-91169 A. System: Emergency Service Water (ESW1 and Residual Hea't Removal (RHR)

B.

Description:

The use-as-is disposition allows the use of PYCO temperature elements (TEs) and requires that the environmen 31 qualification report (EQR) be revised to reflect the as-built confiraration.

C. By. son for Chancre :

The manufacturer and model number of TE-051-105A,B and TE-051-007A,B were found to be different from those stated in the EQR.

D. Safety Eva1uation Summar_v:

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, the TEs are properly designed and qualified for their intended safety funtion and are equivalent to the TEs listed in the ECR.

ii)- Does this modification create the possibility for an accident or ' malfunction of a different type than any evaluated previously in the FSAR?

Answer No , the TEs are of similar design. They are environnentally qualified and qualified for the intended safety function.

iii) Does this modification reduce the margin of safety as defined in the bases for the Technical Specifications?

_ Answer: No, the TEs are equivalent to the TEs listed in the EQR with regard to function and qualification. Environmental qualification reports 16436-82N (PYCO) and 548-8854-2 (NEED) have been reviewed in making this determination. Also, Technical Specification Section 3.7.1.1 was reviewed.

s

.. Limerick Gcnerating Station 2.;

Unit 0 Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 7(

Test No.: S12.8.B A. System: Emergency Service Water ( E::iW) , Residual Hea't Removal Service Water (RHRSW)

B.

Description:

This activity- inj ects Betz Clam Trol (CT-1) into the ESW/RHRSW

- wet pit-located inside the spray pond pump house by either manual addition or by.use rf a chemical injection system.

C. Reason for Chance:

This process is to minimize and to mitigate biological fouling and poss:ble microbiologically induced corrosion (MIC) from fouling;the RHR Heat Exchanger tubes on-the smrvice water -

4 sidc.

D. Safety-Evaluation Summary:

- i ) -- -Does .this modification increase the probability of-occurrence or the monsequences .of an accident or malfunction .of equipment important to safety as previously. evaluated in-the FSAR?

' 3,pswer: --No,'if an. intrusion-of the-chemical'into the Radwaste System were to occur, the product is completely- ion-exchangeable and- would be L

processed ..through plant demineralizers

)_ systems.- Also, if the total expected storage volume-of CT-1-(500-gal.) would-inadvertently:

't get released to the spray pond, the spray. pond available volume of 28.9 million gallons would result in - dilut i'on that would further: be-diluted- by cooling tower- blowdown _or detoxification agents. The only components in:

cdirect contact with the undiluted chemical is; th'e- _ injection / skid . equipment. These components have Mo safety-related function and their ' failure- has no - 1 impact on RHRSW--

operation. There is no. modification of equipment important- to safety nor . are any

-affected by this. activity.

i

Limerick Generating Station j l

Unit 0

l.

• Annual Plant Modification Report July 1, 1991 Through June 30, 1992 Page 75 ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR?

Answer: No, this activity does not impact nor adversely affect any other cooling system needed for safe shutdown of the p] ant or accident mitigation. The presence of CT-1 in the system does not arfect the ability of the RHRSW Syutem or the spray pond to perform their design function. The use of CT-1 at *he intended dosage and duration has been reviewed -

and has been found to be non-detrimental to the equipment.

iii) Does this modification reduce the margin et safety as defined in the bases for the Technical Specifications?

Answer: No, the chemical treatment of the heat exchangers is not gaverned by any Technical Specification. Technical Specifications Sections 3/4.7, 3/4.4, and 3/4.9 and their bases were reviewed in making this determination.

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