ML20153D754

Annual Plant Mod Rept,Jul 1987 - June 1988

ML20153D754
Person / Time
Site:	Limerick
Issue date:	06/30/1988
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20153D731	List: ML20153D728 ML20153D754
References
NUDOCS 8809060028
Download: ML20153D754 (117)

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LIMERICK GENERATING STATION UNIT NO. 1 ANNUAL PLANT MODIFICATION REPORT JULY 1, 1987 THROUGH JUNE 30, 1988 SUBMITTED TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION w

PURSUANT TO I

FACILITY OPERATING LICENSE NPP-39 DOCKET NO. 50-352 L

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LIMERICK GENERATING STATION ANNUAL PLANT MODIFICATION REPORT JUNE 30, 1988 This report for Limerick Generating Station Unit No. 1, License No. NPF-39 (and previous License NPF-27), is issued in fulfillment of the reporting requirements of 10 CFR 50.59 (b).

The report covers modifications that were completed during the one year period ending June 30, 1988, including changes made to the facility as described in the safety analysis report.

1 For each of the modifications included in this report, the safety evaluation has determined that there are no unreviewed safety questions as defined in 10 CFR 50.59 (a) (2) in that (i) the probability of occurrence of the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report was not increased, or (ii) a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report was not created, or (iii) the margin of safety as defined in the basis for any Technical Specification was not reduced.

Note: The actual work involved in some of these mod!fications was started prior to July 1, 1987 but not completaf until after July 1, 1987 and before June 30, 1988.

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Docket No. 50-352 LIMERICK GENERATING STATION UNIT NO. 1 ANNUAL MODIFICAT'ON REPORT TABLE OF CONTENTS Item Mod. No. System Page 86-0024 Residual Heat Removal 5 84-0026 Residual Heat Renoval Service Water 7 85-0030 Reactor Enclosure HVAC and Standby Gas 9 Treatment Syttem 86-0034 Containment Atmospheric Control 11 '

84-0035 Residual Heat Removal 13 84-0106 Reactor Enclosure Cooling Water 15 86-0133 Residual Heat Removal 17 85-0137 Circulating Water and Cooling Towers 19 86-0176 Residual Heat Removal 21 85-0185 Liquid Radiation Collection 23 84-0189

[ 85-0302 Reactor Protection System Residual Heat Removal 25 28 85-0303 Residual Heat Removal 30 85-0326 Reactor Enclosure HVAC and Standby Gas 32 Treatment System 85-0464 Miscellaneous 34 85-0482 Structures 37 85-0505 Reactor Protection System 39 86-0508 Emergency Service Water 41 85-0516 Containment Atmospheric Control 43 86-0542 Plant Process Radiation Monitoring 45 85-0550 Miscellaneous 47 86-0573 Feedwater 49 85-0574 Containment Atmospheric Control 51 85-0680 Residual Heat Removal 52 85-0685 Emergency Service Water 54 85-0704 Plant Process Radiation Monitoring 56 f 85-0773 Containment Instrument Gas 58 85-0800 Main Turbine and Valves 60 85-0805 Reactor Protection System 62 85-0807 Residual Heat Removal Service Water 64 85-0812 Miscellaneous 66 85-0813 111scellaneous 67 85-0844 Containment Atmospheric Control 68 85-0846 Containment Atmospheric Control 70 86-0909 Reactor Recirculation 71 86-0993 Reactor Water Clean-up 73 85-2038 4 KV System Diesel Generator 75

[ 87-2118 87-2140 Neutron Monitoring Plant Chilled Water 76 78 86-5040 Reactor Cora Isolation Cooling 79

( 86-5059 86-5139 Reactor Procection System Omergency Service Water 81 83 86-5228 Residual Heat Removal 85 86-5235 Neutron Monitoring 87 E _

Docket. No. 50-352 LIMERICK dENERATING STATION h UNIT NO. 1 ANNUAL MODIFICATION REPORT TABLE OF CONTENTS Item Mod. No. System Page 86-5236 Containment Atmospheric Control 88 86-5246 Nuclear Boiler 90 86-5309 Security 92 87-5457 4KV Sy:stetn Diesel Generator 93 87-5503 Reactor Water Clean-up 95 87-5550 Control Rod Drive Hydraulic Control Unit 97 87-5573 Reactor Recirculation 98 87-5606 High Pressure Coolant Injection 100 Pump and Turbine 87-5627 Nuclear Boiler Instrumentation 101 87-5733 Nuclear Boiler 103 Procedure No. Description and Revision Number Page A-4 Plant Operations Review Committec 105 Procedure, Revision 8 A-50 Procedure for Conduct of Station Training, 107 Revision 2 A-50, App. B Licensed and Senior Licensed Operator, 109

( A-50, App. C Revision 2 Non-Licensed (Floor) Operator 111 Training, Revision 2 A-50, App. D Plant Staff Training, Revision 2 113 A-50, App. E Geberal Initial and Miscellaneous 115 Training, Revision 2

Limarick G2nerating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through Jun? 30, 1988 Page 5 Modification No.: 86-0024 A. System: Residual Heat Removal (RHR)

B. Descriptlon:.

Flow restricting orifices are being added in each of the LPCI test return lines at locations downstream of the globe valves that currently exist in the LPCI test return lines.

C. Reason for Change:

( The orifices are needed so that adequate RHR pump discharge pressure can be achieved (during use of the LPCI test mode or suppression pool cooling mode) without excessively throttling the globe valves. Without these orifices, the globe valves would be subject to significant damage as a result of cavi :ation.

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 safety analysis report?

Answer: No, the addition of orifices in the RHR test return lines does not change the way in which the RHR system operates. It nerely allowe the globe valves in the test return lines to be opened to a greater degree, while maintaining the same system pressure at the upstream end of the globe valves.

11) Does this mo,1fication create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

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Answer: No, addition of flanged connections to accommodate installation of the orifices does not have any effect on the criteria that are used in determining the types of accidents that are postulated.

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( Limarick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 6 iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, Technical Specifications 3/4.4.9, 3/4.5.1, and 3/4.6.2 were reviewed in making this determination. The modification of the RHR test return lines to include 01scharge ends

{ that are angled slightly upward should improve the ability to ensure that the limiting

( condition for operations specified in item q 3.6.2.1(a)(2)(a) of the Technical Specifications is complied with.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 7 Modification No.: 84-0026 A. System: Residaal Heat Removal Service Water (RHRSW)

B.

Description:

This modification is to provide local control of the 'B' RHRSW Pump at its pump motor control circuit breaker cubicle. l C. Reason for Change:

To satisfy redundant remote shutdown requiremen*,s without the

[ need to install temporary jumpers or lift leads.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because the implementation of this modification will provide a more reliable, efficient, and simpler procedure for implementing the existing redundant remote

[ shutdown method without compromising the design basis requirements ?f the Remote Shutdesn and RHRSW Systems.

11) Does this modificatton create the possibility for an accident or me.lfunction of a different type than any evaluated previously in the nafety analysis report?

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No, uecaune the implementation cf this modification will provide a more reliable, efficient, and simpler procedure for implementing the existir.g redundant remote shutdown m*thod without compromising the design basis requirements of the Remote Shutdown and RHRSW Systemt.

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Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 8

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

Answer: No, because the capability to achieve and maintain hot shutdown from locations outside of the Control Room in the event Control Room

( habitability is lost is not reduced.

Sufficient heat removal capability for removing core decay heat and mixing to assure

[ accurate temperature indication is maintained.

Bases 3/4.3.7.4 (Remote Shutdown System Instrumentation and Controls) and 3/4.4.9 (Residual Heat Removal) were reviewed to make

[ this determination.

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f Limarick Gene:: xing Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

{ Page 9 Modification No.: 85-0030

( A. System Reactor Enclosure HVAC and Standby Gas Treatment System (SGTS)

( B.

Description:

This modification involves the installation of six (6) hinged

( HVAC duct blank-off plates. These blank-off plates can be O manually opened or closed.

C. Reason for Change:

To provide ventilation or maintain the refueling area secondary containment when the railroad shaft access door is open.

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D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because the blind flanges are passive components designed to seismic Category I criteria.

11) Does this modification create the possibility for an accident or malfunction of a different type than any

[ evaluated previously in the safety analysis report?

Answer: No, this modification will provide the

[ capability to meet the FSAR and Technical Specification requirements to install blind flanges at all penetratioas which do not have ,

cutomatic isolation capability and are

( required to maintain refueling area secondary I

containment.

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k Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 10 111) Does this modification reduce the margin of safety as "

defined in the basis for the Technical Specifications?

Answer: No, because it meets the Technical Specification requirements to install blind flanges at any penetration required to

( maintain refueling area secondary containment integrity.

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Limerick Ger.arating Station ,

Unit 1 Annual Plant Modification Report f July 1, 1987 Through June 30, 1988 Page 11

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Mod. ication N1.: 96-0034 A. System: Containmen' Atmosphc ;? Control Hydrogen Recombiners B.

Description:

This modification adds pressure relier valves and redundant containr*nt isolation valves with associated local leak rate test connections to the outlet lines of the hydroger recombiners. This movification also relocates the hand switches for the existing inlet and outlet line isolation valves, adds redundant indicating lights for all the recombiner line isolation valves and adds a containmelit isolation signal with a key-locked bypass switch to the new valves and to existing vendor-supplied skid-mounted valves on

( the inlet lines to the hydrogen recombiners.

C. Reason for Change:

To add an automatic isolation valve in each of the hydrogen recombiner lines penetrating the containment before startup after the first refuel outage per NRC requirements and to

( provide indications for plant Operators.

D. Safety Evaluation Summary:

i) Does this modification increase the probebility of occurrence or the consequences of an accident or e malfunction of equipment important to safety as

{ previously evaluated in the safety analysis report?

l Answer: No, because the addition of containment isolation valves and pressure relief valves to

( the H2 recombiner subsystem has no interfaces with piping systems inside containment. These r valves are designed, fabricated, and installed L to the same quality standards as the portions of the system to which they are attached.

This modification enhances containment isolation capability and provides overpressure

( protection. It also imptoves containment integrity by minimizing the probability of

( containment bypass post-LOCA. FSAR Sections L 6.2.5, 15.6.5, and 6.2.5.1 were reviewed in makirig these determinations.

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Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 12 E

11) Does this moalfication create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

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Answer No, since the containment isolation valves are redundant to existing valves and the pressure

[ relief valves are required when the isolation valves are closed and the recombiners are not operating. Any leakage would be contained by

[ secondary containment. An electrical power supply or valve malfunction will allow at least one H2 recombiner train to remain operable. FSAR Sections 6.2.4, 6.2.7, 6.2.8,

[ 7.3.1.1, 7.3.2.6, and FSAR Table 6.2-20 were reviewed in making the above determinations.

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

[- Answer No, the margin of safety is not reduced since the recombiners will be protected from overpressurization during normal plant operation thus increasing the probability of their availability for their post-accident design function. The bases of Technical Specification Sections 3/4.6.1, 3/4.6.3, and

{ 3/4.6.6 were reviewed in making this decision.

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( Limarick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

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I Modification No.: 84-0035  !

( A. System: Residual Heat Removal B.

Description:

The PSV-51-206A & B Valves are to be retagged as PSV-51-106A.  !

& B. These valves are to be flanged and their discharge  ;

r- flanges (schematically nearest containment) are to be

( modified to provide leak test capability (Unit 2 valves will be retagged for Unit 1).

C. Reason for Change:

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To permit valve removal for in-service inspection testing and r to provide leak rate test capability to verify leak tightness L of the flanged connection. -

D. Safety Evaluation Summary:

[ 1) Does this modification increase the probability of occurrence or the consequences of an accident or r malfunction of equipment important to safety as L previously evaluated in the safety analysis report?

Answer

~ No, it does not increase the probability of an

( accident since the seal assemblies are passive components whose primary safety function is to mitigate the consequences of an accident. The

[ potential for containment leakage will be reduced by permitting leak testing of the FSV-51-106A & B discharge flange connections following PSV reinstallation (e.g., after LLRT

( of the PSV). FSAR Sections 6.2, 6.3, and 15.6 were reviewed in making the above determinations.

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( Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 14

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11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

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Answer: No, failure of the seal would result in the l loss of the flange test capability. l

( Post-accident leakage of suppression pool water is very unlikely, since it would require I

i failure of both radundant passive seals. 1 However, such a failure would be less severe I

[ than those previously considered in the FSAR. l FSAR Sections 6.3.3.3, 9.3.3.3, and I 15.6.5.5.1.2e were reviewed in making the

[ above determination.

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

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Answer No Technical Specification is directly applicable to this change. Technical

[- Specification 3/4.6.1.2 is indirectly related in that this modification permits verification of no leakage at the flanges. T'echnical Specifications 3/4.5.3 (Suppression Chamber)

{ and 3/4.6.1 (Containment Systems) were reviewed in making the above determination.

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( Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

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[ Modification No.: 84-0106 A. System: Reactor Enclosure Cooling Water (RECW) Drywell Chilled Water (DCW)

( B.

Description:

This modif. cation consists of adding isolation signals to the

[ Reactor Enclosure Cooling Water (RECW) and the outboard L Drywell Chilled Water (DCW) containment isolation valves, upgrading the outboard DCW isolation valves, associated piping and cabling to safety-related status, and adding an

[ isolation bypass switch for the outboard DCW valves.

C. Reason for Char;>:

This modificatic 's required to upgrade the design of these isolation valves s. meet the requirements of 10CFR50, Appendix A, General Design Criteria 56 as required by License

[ Condition 2.C.10.

D. Safety Evaluation Summary:

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1) Does this modification increase the probability of r occurrence or the consequences of an accident or L malfunction of equipment important to safety as previously evaluated in the safety analysis report?

[ Answer, No, because this modification adds isolation signals to the DCW and RECW containment isolation valves which does not. adversely L affect tt.e safety related (isolation) function FSAR Sections 6.2.4, of these lines.

7.3.1.1.2, 7.3.2.2.2, 9.2.8, and 9.2.10 were reviewed to make this determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report

{- July 1, 1987 Through June 30, 1988 Page 16

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11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

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Answer: No, because the addition of isolacion signals' to the DCW and RECW containment isolation

( valves does not adversely affect the safety-related function of these lines.

Also, the addition of an isolation bypass

{- switch for the outboard CCW valves does not adversely affect the cafety related r (isolation) function of the DCW lines.

L iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications? l Answer: This modification does not reduce the margin of safety as defined in the basis for any Technical Specification. The bases for

[ Technical Specifications 3/4.3.2, 3/4.6.1, and 3/4/6.3 were reviewed in making this y determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 17

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Modification No.: 86-0133

[ A. System: Residual Heat Renioval (RHR)

B.

Description:

This modification provides position indication in the Control Room of manual valves Sl-lF067A and B and to interlock these )

valves with motor operated valves EV-51-1F004C and D such that both valves in a Residual Heat Removal (RHR) loop cannot be opened simultaneously. Also, a Control Room annunciator r will be added to alert Control Room personnel when valves L Sl-1F067A(B) and RHR pump minimum flow recirculation valves HV-51-lF007C(D) arc open simultaneously.

( C. Reason for Change:

This modification will prevent inadvertently establishing a L reactor drain path through the RHR shutdown cooling suction line to the suppression pool.

p D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or F malfunction of equipment important to safety as L

previously evaluated in the safety analysis report?

c Answer: No, this modification provides interlocks to L prevent inadvertently establishinn a reactor drain path to the suppression poc. The design of this modification is in accordance I with the design requirements of the RHR System and maintains the functional requirements of the RHR System, e

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[ Limerick Generating Station Unit 1 Annual Plant Modification Report

{ July 1,. 1987 Through June 30, 1988 Page 18 r

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[ 11) Does this modification create the possibility for an accident or malfunction of a different type than any

{ evaluated previously in the safety analysis report?

Answer No, this modification provides interlocks to prevent inadvertently establishing a reactor

( drain path to the suppression pool. The design of this modification is in accordance with the design requirements of the RHR System

{- and maintains the functional requirements of the RHR System.

iii) Does this modification reduce the margin of safety as

[ defined in the basis for the Technical Sp3cifications?

Answert No, the emergency core cooling system actuation instrumentation will continue to initiate actions to mitigate the consequences of accidents that are beyond the ability of the operator to control, within the operability requirements, trip setpoints, and response times specified. The shutdown cooling mode of the RHR System will continue

{ to provide sufficient heat removal capability for removing core decay heat, and mixing to assure accurate temperature indication.

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b Limerick Generating Station Unit 1 Annual Plant Modification Report

{ July 1, 1987 Through June 30, 1988 Page 19

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Modification No.: 85-0137 A. Systems RHR Service Water B.

Description:

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[ This modification will add a 1" drain valve and 1" bypass test line for the spray pond make-up line.

C. Reason for Change I To allow for in-service testing of the spray pond make-up

( check valves (12-0030 and 12-0031).

l D. Safety Evaluation Summary:

[ 1) Does this modification increase the probability of occurrence or the consequences of an accident or r malfunction of equipment important to safety as L previously evaluated in the safety analysis report?

Answer No, the drain valve and the bypass test line

[ will be closed for all plant operating conditions. The drain valve and bypass test line will be open only for in-service testing r of check valves12-003 and 12-0031. The L addition of the drain valves t.nd the bypass test line meets all the design requirements applicable to the existing piping.

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11) Does this modification create the possibility for an accident or malfunction of a different type than any r evaluated previously in the safety analysis report?

L Answer: No, this modification does not introduce any r new hazards in the plant. The addition of the L drain valve, the bypass test line, valve and all piping rework meets all the design requirements applicable to the existing

[ piping.

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( Limorick G:norcting Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

[ Page 20 111) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

( Answer No, because the Technical Specification does not address either the need for the check valves or the in-service testing of the above check valves.

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( Limorick Ganerating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

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P k Modification No.: 86-0176 A. System: Residual Heat Removal (RHR)

B.

Description:

N This modification provides for the installation of a transfer switch on the 'B' RHR pump motor circuit breaker cubicle.

- The transfer switch will enable Operations personnel to l

control the 'B' RHR pump via the pump motor circuit breaker test switch without the need to install temporary jumpers or lift leads.

C. Reason for Change:

The purpose of this modification is to provide local control of the 'B' Residual Heat Removal (RHR) pump at its pump motor circuit breaker cubicle. Local control of the 'B' RHR pump is required to satisfy redundant remote shutdown requirements without the need to install temporary jumpers or lift leads.

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 safety analysis report?

Answer No, implementation of this modification will provide a taore reliable, efficient, and simpler procedure for implementing the existing redundant remote snutdown method without compromising the design basis requirements of the Remote Shutdown and RHR Systems,

11) Does this modification create the possibility for an accident or malfunction of a different type *.han any evaluated previously in the safety analysis report?

Annwer, No, implementation of this modification will provide a more reliable, efficient and simpler procedure for implementing the existing redundant remote shutdown method without compromising the design basis requirements of the Remote Shutdown and RHR Systems.

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Limerick Generating Station I

Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 22 lii) Does this modification reduce the margin of sofety as defined in the basis for the Technical Specifications?

Answer.* No, capability to achieve and maintain hot shutdown from locations outside of the Control Room in the event Control Room habitability is lost is not reduced. Sufficient heat removal capability for removing core decay heat and mixing to assure accurate temperature indication is maintained. Bases 3/4.3.7.4 (Remote Shutdown System) and 3/4.4.9 (Residual Heat Removal) were reviewed to make this '

determination.

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Limerick Generating Station Ur.! t 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 23 r

5 Modification No.: 85-0185 A. System: Liquid Radwaste Collection B. Description This modification replaces the existing wet instrument reference leg for the drywell floce drain and equipment drain sump level instruments with a dry reference leg. Also, six level instruments will be relccated and the existing circuitry simplified to delete four level switches.

C. Reason for Change:

This modification will enhance the operability and improve the accuracy of the drywell sump level instruments.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment impor ant to safety as previously evaluated in the safety analysia report?

Answert

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No, becauto this modification meets the applicable requirements of the drywell sump level system and containment isolation system.

Implementation of this modification preserves the passive safety function associated with the sump level instrumentr. tion, and does not affect the performince or operation af any -

other safety or non-safety related equipment.

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 24

11) Does this modification create the possibility for an accident or malfunction of a different type than any

( evaluated previously in the safety analysis report?

Answer No, because implementation of this modification will enhance the operability and improve the accuracy of the sump level instrumentation. However, the functional operation of the drywell sump level system and the containment isolation system will not be affected by this modification. This modification will also not affect the performance or the operation of any other safety or non-safety related equipment.

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

Answer No, because implement,ation of this modification will enhance the operability and improve the accuracy of the sump level instruments thus preserving the margin of safety described in the bauls for Technical Specificatior Section 3/4.4.3.2. The deletion of four level switches and the circuitry revisions made by this modification will not affect the isolation system operability os described in the basiu for Technical Specification SecciorJ 3/4.3.2, 3/4.6.3.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 25 Modification No.: 84-0189 A. System: Reactor Protection System B.

Description:

This modification revises time delay setpoints for the trip signals in the Redundant Reactivity Control System that are used to trip the Recirculation Pumps (RPT) and automatically initiate the Standby Liquid Control System (SLCS). This modification also adds a switch which allows the operator to select a two or six minute time delay for the automatic SLCS initiation from a new two-stage card.

C. Reason for Change:

Revising the RPT trip output from ten seconds to nine seconds is to rike delay agree with the RRCS design specification of 9 + 1 second. Revision to the SLC automatic injection delay from 58 seconds to a 2 minute - 6 minute delay is being performed because analysis based on Limerick's three standby liquid pumps (as opposed to the 2 pumps assumed on original design) and Limerick's increased boron mixing efficiency showed that we could extend to a six minute delay without exceeding 190 degrees F bulk suppression pool temperature.

The new selector switch is to allow operators to select the time delay; 6 minutes for 3 pump operation, 2 minutes for 2 pump operation.

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Limarick Ganoroting Station i

Unit 1 f Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 26 D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the cor. sequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer No, because the analyses of the new time delay verifies that the response of the RRCS is satisfactory.

If the selector switches are placed in the two minute position when all pumps are operable, the only consequence would be that the injection would prematurely occur relative to the analyzed time delay of six minutes. This is prevented by using keylocked switches. In the unlikely event that a SLCS pump train is not operable for an extended period of time the selector switches would all be placed in the two minute position and tagged in this position. If a switch were to be placed back into the six minute position, status lights would be lit to reflect the mispositioned switch. On the local panel a "SLC auto injection delay timer selector trouble" status light will be lit. In the Control Room, both the "SLC auto injection TD-6 min (3 pump)" and the "SLCS auto injection TD-2 min (2 pump)"

status lights will be lit.

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

Answert No, because the new time delay is acceptable as analyzed. The operation of the switches will preclude any switch lineup that would

( allow the delay to be different than required.

FSAR Sections 7.4.1.2, 7.6.1.8, and 9.3.5.2 were reviewed in making this determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 27 iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

. Answer: No, this modification will not reduce the margin of safety as defined in the Technical Specifications.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 28 Modification No.: 85-0302

( A. System: Residual Heat Removal (RHR)

B.

Description:

Install flanges to the inlet and outlet of one of the PSV-51-2F030 Valves, retag as PSV-51-lF030, and install leak test capability to the discharge flanges.

C. Reason for Change:

To permit valve removal for in-service inspection testing and to provide leak rate test capability to verify leak tightness of the flanged connection.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer No, this modification adds flanges with a testable seal assembly and does not affect the function of the associated equipment (valves / piping) related to safety. It does not increase the probability of an accident since the seal assembly is a passive component r

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whose primary safety function is to mitigate the consequences of an accident. The potential for containment leakage will be reduced by permitting leak testing of the

( PSV-51-lF030D discharge flange connection following PSV reinstallation (e.g., after LLRT of the PSV). FSAR Section 6.2, 6.3, and 15.6 were reviewed in making the above determination.

( Lim 2 rick Gonerating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 29

11) Does this modification create the-possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, failure of the seal would result in the loss of the flange test capability.

Post-accident leakage of suppression pool water is vety unlikely, since it would require failure of both redunuant passive seals.

However, such a failure would be less severe than those previously considered in the FSAR.

FSAR Sections 6.3.3.?, 9.3.3.3, and 15.6.5.5.1.2e were reviewed in making the above determination.

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

Answer: No Technical Specification is directly applicable to this change. Technical Specification 3/4.6.1.2 is indirectly related in that this modifi:ation permits verification of no leakage at the flanges. Technical Specifications 3/4.5.3 (Suppression Chamber) and 3/4.6.1 (Contatnment Systems) were reviewed in makinf the above determination.

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[ Limerick Generating Station Unit 1 Annual Plant Modification Report

[ July 1, 1987 Through June 30, 1988 5 Page 30 Modification No.: 85-0303 L A. System: Residual Heat Removal (RHR)

B. Lescription:

Modify the discharge flanges of Valves PSV-51-lF030A & C to add double 0-ring seal assemblies and test connections.

l C. Reason for Change:

To provide leak test capability to verify leak tightness of the flanged connection.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously (valuated in the safety analysis report?

Answer: No, it does not .** crease the probability of an accident since a seu' assembly is a passive component whose primary function is to mitigate the consequences of an accident.

'SAR Sections 5.4, 6.2, 6.3, and 15.6 were reviewed in making this determination, c

11) Does this modification create the possibility for an dCCident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, because poet-accident leakage of suppression pool water is very unlikely since it would require failure of both passive seals. However, such a failure would be less severe than those previously considered in the FSAR. PSAR Sections 6.3.3.3, 9.3.3.3 and 15.6.5.5.1.2e were reviewed in making this determination.

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( Lim 2 rick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 31 111) Does this modification reduce the margin of safety as defined in the basir for the Technical Specifications?

Answer No Technical Specification is directly applicable to this change. Technical Specification 3/4.6.1.2 is indirectly related in that this modification permits verification of no leakage at the flanges. Technical Specification Sections 3/4.5.3 and 3/4.6.1 were reviewed in making the above determination.

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( Limorick Genotating Station Unit 1

Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 32 Modification No.

85-0326 A. System Reactor Enclosure HVAC and Standby Gas Treatment system t

B.

Description:

This modification changes the control logic and replaces temperature sensor thermowells, flow switches, and time delay relays.

C. Reason for Change:

To improve operability and response time of the Standby G .

Treatment System (SGTS) heater control system.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of

( occurrence or the consequences of an accident or malfunction of equipment important to safety as >

previously evaluated in the safety analysis report?

Answer Nc, this modification does not increase bus loading. The design of this modification meets all the desica requirements applicele

( to the original design. These requirer.ents include, but are not limited to, sciamic and environmental qualification, sepa',ation criteria, quality assurance, testability and independence of redundant char.nels.

FSAR Sections 6.5.1.1, 7.3.1.1, and 7.3.2.7 were reviewed in determir.ang that a revision to the FSAR is not required.

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Limorick Ganorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1.188 Page 33

11) Does this modification create the possibility for an i accident or malfunction of a different type than any

[ evaluated previously in the safety analysis report?

Answer: This modification does not increase bus

( loading. The design of this modification f

I meets all the design requirements applicabl.)

to the original design. These requirements include, but are not limited to, seismic and environmental qualification, separation criteria, quality assurance, testability and independence of redundant channels.

FSAR Sections 6.5.1.1, 7.3.1.1, and 7.3.2.7 werc raviewed in determining that a revision to the PSAn is not required.

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

t Answer A change to the LGS Technical Specification is not required. The sections of the Technical Specification reviewed were 3/4.6.5 and 3/4.11.2

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' Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 34 yo31fication No.: 85-0464 A. System: Various B. kescription:

This modification replaces the red and black banana jacks, rated for 50 degrees Celsius with blue spade connectors (BJSLC's), rated for 220 degrees Celsius.

C. Reason for Change:

To provide BJSLC attachment points for temporary test lead connections to terminal strips as required for surveillance testing of instrumentation and control systems.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answe No, the BJSLC's are fully insulated when installed a.)d the insulation does not support combustion and is rated at 220 degrees C.

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Limerick Generating Station Unit 1 Annual Plant Modification Report

{ July 1, 1987 Through June 30, 1998 Page 35 5

11) Does this modification create the~ possibility for an accident or malfunction of a different type than any-evaluated previously in the safety analysis report?

Answer Nos the reasons are as follows:

(1) Loosening Connections This modification without precautions, could increase the frequency of loosening terminal strip screws thereby incteasing the probability of loss of the specific instrument or control system due to high contact resistance or an open circuit.

Screw loosening could result from connector movement due to test lead insertion and removal. However, this condition will be precluded by requiring that the connection be visually inspected and that the screw be checked for tightness after each use. The implementation of this procedure will negate the potential for system degradation that otherwise might be attributed to this modification.

(2) Metal Fatique The movement inherent with the connector usage could cause the connector metal to fatigue over a period of time with the resulting failure of the copper neck on the spade lug end of the connector. The potential for metal fatigue will be minimised by requiring that the lugs not be bent after the initial installation.

However, a fatigue failure would not af fect the opration of the plant since the banana plug connector is fully insulated except for the lug end. A complete fracture, which would cauce the BJSLC to fall from its terminal point, would not affect either the circuit to ohich it is attached or any other circuit since the part that might fall is insulated.

Limerick Generating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988 Page 36 These possible malfunctions are not evaluated in the FSAR.

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

Answer: No, the inspection and torquing of screw connections will avoid adverse consequences t af ter testing is cc:npleted.

Lim 2 rick Gonorating Stction Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988

( Page 37 a

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Modification No.: 85-0482

( A. Systems Structures B.

Description:

This modification installs an environmentally controlled enclosure at EL 352'-0" to allow personnel to work more efficiently during the refuel operations.

C. Reason for Change:

Implementation of this modification will decrease the time required to perform the refueling operation. Personnel can work in an environment free of airborne contamination and will not be required to wear protective clothing and respirators.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because there are no safety-related components in close proximity to the enclosure.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because there are no safety-related components in close proximity to the enclosure. In the event of a seismic occurrence, the light-weight prefabricated metal panels could collapse, but could not cause an accident or malfunction of equipment important tv uafe y previously evaluated.

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f Lim 3 rick G0nerating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 38 s

l 111) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

1 Answer, The proposed modification does not reduce the margin of safety as defined in the basis for any Technical Specification since the Technical Specifications do not address any requirements for a Refueling Floor Maintenance Supervisor's Office.

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Lim] rick GotArcting Station Unit 1 Annttal Plant Modification Report July 1, 1987 Through o'une 30, 1988 Page 39 l Modification No.: 85-0505 A. System: Reactor Protection System l

j B. Description l

l This modification connects the calibration unit to the same j isolated ground bus to which the Reactor Protection System Trip Unit is connected.

C. Reason for Change:

Connecting the calibration unit to the same isolated ground bus as the trip unit prevents a difference in ground bus

} potential from adversely affecting the accuracy of the calibration of the trip units.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of I occurrence or the consequences of an accidtnt or j malfunction of equipment important to safety as previously evaluated in the safety analysis report?

{ Answer: This modification will improve the l maintainability of the plant during routine surveillance testing. It does not affect the

} performance or operation of any other safety

) or non-safety related equipment as it connects the trip and the calibration units to the 1

common isolated ground bus. FSAR Section 7.1.2, 7.2.1, and 7.2.2 were reviewed in making this determination.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

1 Answer: This modification will improve the maintainability of the plant during routine surveillance testing. It does not affect the performance or operation of any other safety or non-safety related equipment as it connects the trip and the calibration units to the common isolated ground bus.

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Limerick Generatjng Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 40 111) Does this modification reduce the margin of safety as defined in the. basis for the Technical Specifications?

Answer No, since this modification is in accordance with the design requirements applicable to the original design. It will increase the safety

( margin as the accurate trip output signal will prevent any potential damage to the associated

, equipments.

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Limerick Generating Station Unit 1 Annual Plant MtJification Report July 1, 19E7 Through June 30, 1988 Page 41 Modification No.: 86-0508 i

A. System Emergency Service Water B.

Description:

This modification adds local starting capability to the "B" ESW Pump OBP548 by providing a SB-1 keylock selector switch at the 4KV Switchgear Panel 10A11608.

C. Reason for Change:

To permit starting capability for the Emergency Service Water (ESW) Pump OBP548 from outside the Control Room. This change is required in order to provide a redundant ESW pump that can be started for remote shutdown without requiring jumpering (or tripping logic in the test mode).

D. Safety Evaluation Summary:

1) Does this modificatien increase the probability of occurrence on the con".wquences of an accident or malfunction of eqtipment important to safety as previously evalsat,ed in tPn safety analysis report?

Answer:

No, the audition of a local keylock switch in4reases operational flexibility by providing 6,he capability of starting the ESW Pump "B" from odeside the Control Room. Automatic staiting and trlpping of the pump will be retained.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, because failure of any components or systems involved in this modification will not affect the redundant components or syster.s, which are adequately separated.

Lim 3 rick Gonorcting Ototion Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 42 111) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer No, the bar,es for Section 3/4.3.3, 3/4.3.7.4, 3/4.4.9, 3/4.7.1.2, 3/4.8.1, and 3/4.9.11 were reviewsd. No margins of safety were changed.

However, it is recommended that the new

( keylock switch be added to Table 3.3.7.4-1 of the Technical Specifications to include it in the periodic surveillance testing.

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f Limerick Generating Statien Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 43 Modification No.: 85-0516 A. Systems Containment Atmosphere control

3.

Description:

This modification adds test switches in Panel 10C600 to facilitate surveillance testing of the Containment Atmosphere Control System (CACS) combustible gas analyzer pressure

( differential circuits.

C. Reason for Change:

Surveillance testing of the CACS pressure differential circuits requires lifting of leads from the terminal block in Panels 10S205 and 10S206. The relanding of leads cannot be functionally verified after testing. Adding test switches in Panel 10C600 will eliminate the need for lifing leads.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer No, the addition of test switches does not t affect the system performance as described in the PSAR. The design of the modification is in accordance with the design requirements applicable to the original CACS design. FSAR Sections 6.2.5.2.2 and 7.3.1.1.6.1.2 were reviewed in making this determination,

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, the design of this modification is in accordance with the design requirements applicable to the original CACS design. PSAR Sections 6.2.5.2.2 and 7.3.1.1.6.1.2 were reviewed in making this determination.

Lim 3 rick Gonorating Station i

Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 44 lii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answert No, this modification design is in accordance with the design requirements applicable to the original CACS design. Technical Specification 3/4.6.3.3 was reviewed in making this determination.

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Limerick G3norating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 45 Modification No.: 86-0542 A. System: Flant Process Radiation Monitoring

3.

Description:

This modification makes internal wiring changes in Panel 00C624. These changes are designed to utilize normally open instead of normally closed contacts within the WRAM annunciator auxiliary circuit making this circuit fail-safe.

C. Reason for Change:

To obtain automatic closure of drywell and suppression pool purge isolation valves upon loss of power to the control circuit.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipmen'. important to safety as previously evaluated in the safety analysis report?

Answer No, because this modification improves the operability and reliability of the plant by

( providing isolation signals to the drywell and suppression pool purge valves, even upon loss of power to the WRAM auxiliary circuit. It

( does not affect the performance or operation L of any otner safety or non-safety related equipment. l'SAR Sections 7.6.1.1.9, 7.6.2.1.9, 11.5.2.2.1.2 and Table 7.6-1 were

(' reviewed in making this determination.

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

Answer: No, chances of any adverse consequences are reduced as the circuit will operate during high radiation and loss of control power (failsafe) and provide isolation signals for

( the drywell and suppression pool purge valves.

Limorick Gonorating Station

(- Unit 1 Annual Plant Modification Report

( July 1, 1987 Thtough June 30, 1988

( Page 46 iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

( Answer No, since this modification is in accordance with the design requirements applicable to the original design. It will increase the safety margin as the isolation valves will close upon

( loss of power to the WRAM auxiliary circuit or during a HI-HI radiation signal from the north r stack and prevent the release of the contaminant to atmosphere under an accident

( condition. Technical Specifications Sections 3.3.7.11, 3.3.7.12, 3.11.1 and 3.11.2 were reviewed.

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Limorick Generating Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 47 Modification No.: 85-0550 A. System: Various B.

Description:

This modification consists of reclassifying doors 204 and 288, which were formerly pairs of doors, to single doors No.

204N, 204S, 288N, and 288S. Also, the addition of an electromagnetic closing device to Doors 204N and 288N improves the method for unlocking the doors and gaini 1 access into the Switchgear Room No. 336.

C. Reason for change:

This closing device will replace the existing latch bolt / strike closing function, which is difficult to operate.

D. Safety Evaluation Summary:

f i) Does this modification increase the probability of occurrence or the consequences of an accident or

/ malfunction of equipment important to safety as i previously evaluated in the safety analysis report?

Answer No, because this modification will increase

( the reliability of the locking devices for thene doors.

( 11) Does this modification creato the possibility for an I accident or malfunction of a different type than any evaluated previously in the safety analysis report?

( Answers No, because the locks are not required to function in the event of a pipe break in that the steam will driva the door against the door

( stop and gasket, sealing the opening. In the i event of a fire, the doors will remain closed since the fire doors are equipped with door closers with fusible links. The FSAR was reviewed and the tubject was not addressed in it.

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I Limsrick Ganarating Station Unit 1

' Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 48 iii) Does this modification reduce'the margin of safety as defined in the basis for the Technical Specifications?

(. Answer No,.because this change has no affect on the margin of sefety in the function of these doors. Technical Specification Section 3.7.7 was reviewed in making this determination.

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Limarick Genorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 49

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( Modification No.: 86-0573 A. System: Nuclear Boiler

(

B.

Description:

( Addition of vent and drain connections to aid the local leak rate testing of the feedwater system containment isolation Valves.

C. Reason for Changr As presently installed, it is not possible to completely drain the safeguard piping fill lines between the isolation valves and existing connections.

\ D. Safet.y Evaluation Summary:

( 1) Does this modification increase the probability of L occurrence or the consequences of an accident or malfunction of equipment important to safety as g previously evaluated in the safety analysis report?

Answer: No, because the new val' as and piping will be of the same seismic category, code classification, quality group 'nd "O" status as the existing lines, except tor the terminal ends and screwed caps. FSAR Sections 6.2.3.2.3.2 (Feedwater Fill System), 6.2.6.3

[ (LLRT), and 3.9.3 (Dynamic Analysis Loading Conditions) were reviewed in making this p

determination.

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11) Does this modification create the possibility for an accident or analfunction of a dif ferent type than any evaluated previously in the safety analysis report?

Answer: No, because the modification will enhance the operability of the plant by providing adequate

( measures to drain the safeguard piping. FSAR Sections 3.6.2 and 3.6.1.2.1.3 were reviewed in making this determination.

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Lim 2 rick G3nerating Station Unit 1 I Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 50 lii) Does-this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the containment LLRT vents and drains are not discussed directly in the l Technical Specifications. Sections 3/4-F and 3/4.6.3 were reviewed in making this determination.

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Limerick Ganarcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 51

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Modification No.: 05-0574 A. Systems Cor.tainment Atmospheric Control B.

Description:

{ This modification re routes a portion of the safety-related

} tubing that suppliec H2 as a reagent and calibration gas for the combustible gas analyzers so that it does not pass through any stairwell.

C. Reason for Change:

This modification will provide greater confidence la personnel safety since the stairwell is used as a life safety

( egress. Re-routing the tubing will provide better l atmospheric mixing and ventilation than the stairwell.

D. Safety Evaluation Summary:

i) Does this modification increase the probability of occurrence or the censequences of an accident or malfunction of equipment important to r,afety as

(- prevjously evaluated in the saferf analysis report?

Answer,: No, the tubing relocation does not affect the operation of the combustible gas analyzers er any other component or system. The safety of the plant is not reduced.

11) Doec this modification create the possibility for an accident or malfunction of a different type than .any evalueted previously in tha safety analysis report?

Answer: No, since this modification does not expose

, the tubing to any additional hazards and does i

L not affect any other components of the system.

FSAR Sections 6.2.5 and 9.5.1 were reviewed in making this determination..

f lii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

f Answer: No, Technical Specification basis 3/4.6.6 was reviewed in making this determination.

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LimDrick G3nsrating StGtion i Unit 1 l Annual Plant Modification Report  !

July 1, 1987 Through June 30, 1988 Page 52 Modification No.: 85-0680 A. System: Residual Heat Removal B.

Description:

One of the PSV-51-2F030 valves is to be flanged and retagged as PSV-51-lF030B, and its new discharge flange connection (schematically nearest containment) is to be modified to provide leak test capability.

C. Reason for Change: -

To permit valve removal for in-service inspection testin? and to provide leak test capability to verify leak tightness of the flanged :onnection.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident er malfunction of equipment important to safety as previously evaluated in the ss'ety analysis report?

Answer No, this modification repilces an existing flange gasket with a testable seal assembly and does not affect the function of the associated equipment (valves / piping) related to safety. It does not increase the probability of an accident since the seal assembly is a passive component whose primary safety function is to mitigate the consequences of an accident. The potential for containment leakage will be reduced by I permitting leak testing of P3V-51-lF030B l discharge flange connection following PSV reinstallation (e.g., after LLRT of the PSV).

, FSAR Section 6.2, 6.3, and 15.6 were reviewed I

in making the above determination.

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Lim 2 rick G nnrating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 53 f

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, failure of the seal would result in the loss of the flange test capability. Post accident leakage of suppression pool water ;s .

{ very unlikely, since it wou?d require failt re of both redundant passive seals. However, r such a failure would be lesc severe than tnose l previously considered in the FSAR. FSAR Sections 6.3.3.3, 9.3.3.3 and 35.6.5.5.1.2e were reviewed in making the above determination.

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

Answer: No Technical Specification is directly applienble to this change. Technical .

Specification 3/4.6.1.2 is indirectly related

( in that this modification permits verification of no leakage at the flanges. 'Iechnical Specifications 3/4.5.3 (Suppression Chamber) s and 3/4.6.1 (Containment Systems) were reviewed in ma9.ing the above detern.ination.,

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( Limarick Gsn9 rating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 54

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Modification No.: 85-0685 f A. System: Emergency Service Water B.

Description:

This modification installs moisture seals in conduits connected to instruments in the ESW pipe tunnel.

( C. Reason for Change:

This modification resolved a problem with high humidity in the ESW pipe tunnel that is attributed to the missing seals.

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D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as

. previously evaluated in the safety analysis report?

Answers No, moisture seals ir. the instrument conduits r will improve the .teliability of equipment and l instrument opevacions under normal plant conditions.

( 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previcusly in the safety analysis report?

Answer No, this modificati.on does not introduce any new hazards in the plant or potential for r interference with safety-related functions.

( The use of these seals does not change or alter the functional performance of the equipment to which they are connected.

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f Limarick Gansrating Station L Unit 1 Annual Plant Modification Report r-July 1, 1987 Through June 30, 1988 L

Page 55 r

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

Answer: No, since this modification is installing

( conduit seals for increased equipment reliability. This modification does not affect the control functions of either the ESW f or RHR Service Water Systems. Technical Specification Sections 3/4.7.1 were reviewed for this question.

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[ Limerick Ganorating Station i

Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988

( Page 56 i

f Modification No.: 85-0704 A. System: Reactor Protection System

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B. Descriptions f This modification reworks selected electrcnic circuit cards in the Redundant Reactivity Control System (RRCS) panels at Limerick Generating Station Unit 1.

C. Reason for Change:

This modification was required to correct problems in the

( RRCS discovered during RRCS startup and pre-operational testing and to implement improvements in the RRCS as recommended by the vendor (General Electric Co.).

D. Safety Evaluation Summary:

( i) Does this modification increase the probability of l' occurrenca or the conr.equences of an accident or malfunction of equipment important to safety e3 previously evaluated in the safety analysis report?

Answer: No, this modification increases the time delay for RRCS automatic initiation of SLCS to

, provide the other ATWS prevention and mitJgation features additional time to shutdown the reactor. It also provides operating personnel additional time to

( eva.ut.te the plant status and initiate additional actions to aid in shutting down the reactor. This modification will not increase the probability of an ATWS event, nor will

( this modification reduce the capability of the RRCS to respond to an ATWS event and limit its consequences as evaluated in the FSAR.

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f Limarick Ganarcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 57 f

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, the RRCS will continue to monitor selected plant parameters and when those parameters indicate a potential ATWS, RRCS will initiate

( the appropriate prevention and mitigation features as required to maintain the plant within acceptable limit' as evaluated in the FSAR. No additional accidents or malfunctions of the RRCS or the associated ATWS prevention and mitigation features are created as a-result of the changes to the plant design contained in this modification.

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

( defined in the basis for the Technical Specifications?

Answer:

No, the bases for Technical Specifications

( 3/4.1.5 and 3/4.3.4 were reviewed to make this determination. The SLCS will continue to provide backup capability for bringing the reactor from full power to a cold, Xcnon-free

(- shutdown as discussed in the basis for Technical Specification 3/4.1.5. The RRCS will continue to actuate the Art.S RPT as

( required in response to an ATWS event as discussed in the basis for Technical Specification 3/4.3.4.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 58 Modification No.: 85-0773

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A. System Primary Containment Instrument Gas B. Descriptions k

This modification re-routes a portion of the safety-related tubing that supplies nitrogen to the automatic depressurization system.

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C. Reason for Change:

Current routing of the 1/4" tubing associated with the A-2 and A-3 gas bottles at Elevation 217' are interfering with removal of the A-1 gas bottle. This problem has been identified as a personnel safety hazard.

D. Safety Evaluation Summary:

i) Does this modification increase the proDability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, this tubing re-routing does nct affect the operation of any other component. It only provides more access fer removal of A-1 gas bottles and eliminates the problem of personnel cafety ha::ards.

h 11) Does this modification create the posaibility for an accident or malfunction of a differeat type than any evaluated previously in the safety analysis report?

Answer No, since this modification does not exposa the tubing to any additional hazards and does l

not affect any other components of the system.

FSAR Sections 7.G.l.6, 9.3.1.3 and Figure 9.3.2 were reviewed in making this determination.

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Limarick Ganorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 59 f Does this modification reduce the margin of safety as lii) defined in the basis for the Technical Specifications?

Answer:

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No, Technical Specification 3/4.5 was reviewed in making this determination. The backup ADS pneumatic supply is not included in the Technical Specifications.

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s Limerick Generating Station l

Unit 1 Annual Plant Modification Report July,1, 1987 Through June 30, 1988 l Page 60 Modification No.: 85-0800 A. Systems Main Turbine and Valves B.

Description:

Relocation of turbine control valve fast closure trip switches.

C. Reason for Change:

Trip switches are presently mounted on the main steam control valves where frequent damage to the switch occurs due to vibrations of the MSCV's.

D. Safety Evaluatior. Summary:

1) Does this modification increase the probability of occurrence or the consequences cf an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because this change only physically relocates the prcssure switches to prevent their frequent failure and hence increases the reliability of the RPS for reactor scram.

FSAR Section 7.2 end the requiremente outlined in the FSAR Question 421.37 were reviewe:d in

{ naking &his determination.

11) Does this modification create the possibility for an accidant or malfunction of a different type than any evaluated previoucly in the safety analysis report?

Answer No, because this change will enhance the operability and safety o'! the plant by reducing vibration damage of equipment and subsequent exposure (ALARA) by minimizing maintenance and repairs.

Limerick G3nerating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 61 lii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because relocation of the switches does not require a change to any Technical Specifications based on a review of Technical Specification Section 3/4.3.1 for RPS Instrumentation. This modification is in accordance with the design requirements applicable to the original design and does not change any Limiting condition for Operation.

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f Lim 9 rick Gsnarating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 L Page 62 Modification No.: 85-0805 f A. System: Reactor Protection System B.

Description:

This modification involves the rework of the card select decoder cards, data acquisition and display decoder cards, power monitor cards, universal logic cards, and the analog trip modules installed in the RRCS panels in accordance with GE FDI's # TNVO R/0, R/1; TNVT R/0; TNVV R/0; TNVV R/0; and GE FDDR's #HH1-3562 R/0 and HH1-4527 R/0.

C. Reason for Change This modification will correct, update, and improve the RRCS system as a result of the system tescing and vendor recommendations.

D. Safety _ Evaluation Sur.Jnary:

3) Does this modification increase the probability of occurrence or the consequencea of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answers Wo, this modification increases the time delay for the RRCS automatic initiation of SLCS to provide the oth?r ATWS prevention and f

s mitigatien features additional time to shutdown the reactor. It also provides operating personnel additional time to evaluate the plant status and initiate additional actions to aid in shutting down the reactor. This modification enhances the ability of the RRCS to detect a genuine ATWS

( and initiate the appropriate ATWS prevention and mitigation features and eliminates known problems which can result in unnecessary and inadvertent initiations of the RRCS. The RRCS will continue to monitor selected plant parameters. When those parameters indicate a potential ATWS, RRCS will initiate the appropriate prevention and mitigation features as required to maintain the plant within acceptable limits as evaluated in the FSAR.

This modification will not increase the

Lim 2 rick G2narating Stetion Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 l Page 63 fi probability of an ATWS event, nor will this modification reduce the capability of the RRCS to respond to an ATWS event and limit its consequences as evaluated in the PSAR.

11) Does this modification create the possibility for an accident or malfunction of a different type than any

( evaluated previously it. the safety analysis report?

Answer: No, the RRCS will continue to monitor selected plant parameters and when those parametera indicate a potential ATWS, RRCS will initiate the appropriate prevention and mitigation features as required to maintain the plant within acceptable limits as evaluated in the FSAR. No additional accidents or malfunctions of the RRCS or the associated ATWS prevention and mitigation features are created as a result of the changes to the plant design contained in this modification.

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

Answer: No, the bases for Technical Specifications 3/4.1.5 and 3/4.3.4 were reviewed to make this determination. The SLCS will continue to provide backup capability for bringing the roactor from full power to a cold, Xenon-free >

shutdown as discussed in the bas!,s for Technical Specification 3/4.1.5. The RRCS will continue to actuate the ATWS RPT as required in response to an ATHS event as f discussed in the basis for Technical Specification 3/4.3.4.

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I f Limarick G3noratitig Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1938 Page 64 f'

Modification No.: 85-0807 A. System: Residual Heat Removal Service Water (RHRSW) and Spray Pond B.

Description:

This modification provides remote indication of spray pond temperature in the Control Room to eliminate the need for plant personnel to go to the spray pond to obtain the temperature reading.

C. Reason for Change:

Technical Specifications Section 3/4.7.1 requires

/ surveillance of the spray pond surface temperature (within

( the upper two feet of the surface) at least once per 24 hcurs when the spray pond temperature is greater than 32 degrees F.

The surveillance frequency increases to at least once per two hours when the spray pond temperature is greater than 85 degrees F.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because this modification merely provides remote indication of spray pond temperature in the Control Room to allow Operations personnel to more readily and conveniently satisfy the surveillance requirements.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, because this modification merely provides remote indication of spray pond temperature in the Control Room to allow Operations personnel to more readily and conveniently satjefy the surveillance requirements.

Limarick Gsn3 rating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 65 iii) 'Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer No, because this modification does not affect the cooling capacity available in the spray pond for continued operation of safety-related equipment during normal and accident conditions. Technical Specification Section 3/4.7.1 (Service Water Systems) was reviewed I in making this determination.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 66 4

Modification No.: 85-0812 A. System: Human Factors on Miscellaneous Systems B.

Description:

This modification revises Control Room and remote shutdown panel instrument scales to improve the man / machine interface.

C. Reason for Change:

The Control Room Design Review Team identified the need to improve the man / machine interface for the Control Room and l remote shutdown panels.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety an previously evaluated in the safety analysis report?

Answer: No, by improving the operator / machine interface of the Control Room and remote shutdosn pane.ls instrument scales, the r probability of occurrence and the consequences I of an accident will be reduced. FSAR Sections 1.13.2, Part I.D.1, 5.4, 7.1.2, 7.3.1.1.12, 7.3.2.12, 7.4.1, 7.4.2, and 9.2.3 were reviewed as part of this modification.

t 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, revising the instrument scales will not create any different type of accident or malfunction.

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

Answer No, the Technical Specifications were reviewed and there are no applicable sections for this modification.

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Limarick Gonorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page G7 Modification No.: 85-0813

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A. Systen: Human Factors on Miscellaneous Systems B.

Description:

This modification provides human factvis enhancements to the l Control Room and remote shutdown panels to improve the I man / machine interface. ]

C. Reason for Change:

The Control Room Der; gn Review Team identified the need to improve the man /mac.5.'ne interfaces in the Control Room and remote shutdown pane.s.

D. Safety Evaluation Summary:

i) Does this modification increase the probability of

[ occurrence or the consequences of an accident or L

malfunction of equipment important to safety as previously evaluated in the safety analysis report?

[ Answer, No, by improving the operator / machine interface with human factors enhancoments, the probability of occurrence and the consequences of an accident will be reduced.

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ii) Does this modification create the possibility for an

( accident or malfunction of a different type than any

[ evaluated previous.!.y in the safety analysis report?

Answer: No, revising the enhancements to the panel by painting, mimicking, and labeling will not create any different type of accident or malfunction.

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

Answer: No, the Technical Specifications were reviewed and there are no applicable sections for this modification.

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f Lim 2 rick G3norating Station Unit 1 Annual Plant Modification Report

( July 1, 1987 Through June 30, 1988

\ Page 68 f

Modification No.: 85-0844

{ A. Systems Containment Atmospheric Control B. Descriptions

( This modification installs four GE CR2940 switches, four Pomona double test jacks, and wiring into Panel 10C600.

Also, this modification adds two new annunciator windows to same panel.

C. Reason for Change:

This modification provides a means to complete surveilla. e testing without lifting leads from the terninal blocks in Panel 10C600 since relanding of leads cannot be functionally verified. This modification also provides the required inoperability annunciation in accordance with the guidelines of Regulatory Guidelines of 1.47.

D. Safety _ Evaluation Summary: ,

[ 1) Does this modificatior. increase the probability of 5 occurr ence or the consequences of an accident or malfunction of equipment important to safety as previously ovnluated in the safety naalysis report?

Answer: The addition of test switches, test jack adapters, and annunciation does not affect the system performance as described in the FSAR.

f Because of this modification, the description of the Combustible Gas Control Subsystem (CGCS) in the FSAR requires revision. An LDCN (PS-977) has been issued to provide the l corrected text. FSAR Sections 6.2.S.2.2 and 7.3.1.1.6.1.2 were reviewed in making this determination.

Lim 2 rick Gznorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 69

( 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

f Answer: The addition of test switches, test jack adapters, and annunciation does not affect the

( system performance as described in the FSAR.

l Because of this modification, the description of the Combustible Gas Control Subsystem An LDCN (CCCS) in the FSAR requires revision.

(FS-977) has been issued to provide the corrected text. FSAR Sections 6.2.5.2.2 and 7.3.1.1.6.1.2 were reviewed in making this determination.

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

Answer No, the design of this modification (MDCP-844) is in accordance with the design requirements applicable to the original CACS design.

( Technical Specification 3/4.6.6.3 was reviewed in making this determination.

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Lim 3 rick Gansrating Station.

Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 70 Modification No.: 85-0846 A. System: Containment Atmospheric Control (CACS)

B.

Description:

This modification will add test switches and jack adapters in Panel 10C600 and annunciation in Panel 10C800.

C. Reason for Change:

For surveillance testing of the CACS signal conditioner circuits.

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 safety analysis report?

Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original CACS design. FSAR Sections 6.2.5.2.2 and 7.3.1.1.6.1.2 were f reviewed iri making this determination.

11) Does this modification create the possibility for an accident or malfunction of a different type than any f evaluated previously in the safety analysis report?

Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original CACS design. FSAR Sections 6. 2. 5. 2. 2 and 7. 3.1.1. 6.1. 2 we ts) reviewed to make this determination.

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

Answer: No, because this modification does not require any change to the Technical Specifications.

Technical Specification 3/4.6.6.3 was reviewed in making this determination.

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Limarick Gsnarating Station H Unit 1 h' Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 71 Modification No.: 86-0909 A. System: Reactor Recirculation l B.

Description:

This modification adds an M-G set feeder breaker interlock in the reactor recirculation pump RPT breaker circuit.

C. Reason for Change:

This modification will prevent inadvertent closing of the RPT breaker when the M-G set is running.

D. Safety Evaluation Summary:

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1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as

( previously evaluated in the safoty analysis report?

Answer: No, the reliability of the r>lant is enhanced by providing proper fuse coordination, adequate isolation between Class lE and non-Class lE circuits, and an interlock between M-G set feedor breakers and each RPT breaker, thereby preventing an inadvertent closure of an P.PT breaker after it trips when the associated M-G set is running. It does not affect the performance or operation of any other safiity-related or non-safety-related equipment. FSAR Sections 5.1.1, 7.1.2.1.8, 15.3.1, and 8.1.6.1.14.4(d) and Table 7.1-3 were reviewed in making this determination.

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k Limarick Ganarating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 72

11) Does this modification create the pontelbility for an accident or malfunction of a differen. type than any evaluated previously in the safety ana. lysis report?

Answer:

No, the reliability of the plant is enhanced by providing proper fuse coordination, adequate isolation between Class 1E and non-Class lE circuits, and an interlock between M-G set feeder breakers and each I associated RPT breaker. These measurts will

( prevent an inadvertent closure of the RPT l breaker after it trips when the associated M-G j set is running. FSAR Sections 5.4.1, 7.1.2.1.8, 15.3.1, and 8.1.6.14.4(d) and Table 7.1-3 9ere reviewed in making this determination.

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

f. Answer No, this modification is in accordance with the design requirements applicable to the original design. This modification decreases the potential for damage to the recirculation i pump mo'c or, RPT breakers and M G set. I

'itchnical Specification 3/4.3.4 was reviewed in naking this determination.

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Limarick Ganarcting Stotion

{ Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 73 Modification No.: 96-0993 A. System: Reactor Water Cleanup System B.

Description:

Replacement of Reactor Water Cleanup (RWCU) System flow square root converters, C. Reason for Change:

f To correct a deficiency found in the safety-related square root converter cards from non-adjustable low voltage cut-off which causes signal error that can produce a RWCU isolation to a new low voltage cut-off adjustment type.

D. Safety Evalua ion Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Anawer No, because the six (6) replacement square root converter cards, installed through implementation of this modification, meet all the applicable requirements of the system to which they are being installed.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because the six (6) replacement square root converter cards, installed through

( implementation of this modifications are

( functionally identical to the existing units.

Lim 2 rick Ganarating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 74 111) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer No, because the six (6) replacement square root converter cards, installed through

implementation of this modification are functionally identical to the existing units and will preserve the margin of safety as defined in all applicable sections of the Technical Specification, including 3/4.3.2 (Isolation Actuation Instrumentation).

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I Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 75 Modification No.: 85-2038 A. System: 4 KV System Diesel Generator B.

Description:

This modification involves setpoint changes to the Emergency Diesel Generator Engine Protective Alarm / Trip Bypass features.

C. Reason for Change:

To prevent spurious alarms or trips during performance of slow starts to the emergency diesel generators.

D. Safety Evaluation Summary:

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1) Does this modification increase the probability of g occurrence or the consequences of an accident or l malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer No, none of the instrumentation which could

{ impact the safety function of the diesel generators is affected by this change. FSAR Sections 8.3.1 and 9.5.4 through 9.5.8 were reviewed in making this determination.

11) Does this modification create the possibility for an accident or malfunct!,on of a different type than any evaluated previously in the s6fety analysis report? )

( Answer: No, none of the instrumentation which could t impact the safety function of the diesel i generators is affected by this change. An informational change to FSAR Sections 9.5.4.2,

( 9.5.5.5, and 9.5.6.2 will be required to revise engine process descriptions to account for the revised setpoints.

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

( Answer: No, the margin of safety as defined in the bases for Technical Specification 3/4.8.1 is not increased.

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Lim] rick G narcting Station j Unit 1

( Annual Plant Modification Report 1

July 1, 1987 Through June 30, 1988 Page 76 Modit.'icat ion No. : 87-2118 l A. System: Neutron Monitoring B.

Description:

1 This modification provides the required APRM, flow unit, and rod block setpoints associated with the increased core flow e4!.1:artial feedwater t eating for Limerick Generating Station Unit L, Cycle 1.

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C. Reason for Change:

f i Technical Specification Amendment No. 3 made chrnges to support operation with reduced feedwdter heating and increased core flow.

D. S h l. L2 valuation Summary:

1) Doer 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 safety analysis report?

Answer:

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No, for the contrc? rod block instrument setpoint changes the flow unit upscale trip performs no safety func* ion and has not been given credit by any LGS cerign basis transient or accident analysis. For tne MG set scoop

/ tube mechanical and electrical stop overspeed setpoint changes the transient where

) recirculation flow increases from 105% to the

) limiter setting of 109S have been reviewed and are covered by the application of the Kf curve (Technical Specification Figure 3.2.3-2) for 109%. The addition of the high flow clamping feature to the Rod Block Monitor (RBM) ensures t the current RBM setpoints cannot be exceeded.

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Limerick G3norcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 77

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, for the control rod block instrument retpoint change, the function of the trip level as on indication / alarm of unintended high flow operation is enhanced. For the MG set scoop tube mechanical and electrical stop overspeed setpoint changes, application of the Kf curve for 109% assures the operating margin to the safety limit MCPR currently in the Technical Specification is maintained. For r the Rod Block Mcnitor (RBM), a high flow clamping feature is added to ensure the 106 and 109% rod blocks currently included in the Technical Specifications cannot be exceeded, thus maintaining the margin of safety currently embodied in the rod withdrawal error analysis, iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

( Answer: The current Technical Specifications, with the exception of the MCFR operating limits, are adequate and preclude the violation of any

[ safety limits for ICF and/or PFH operations.

L Accordingly, the MCPR limits are revised to assure that the margin of safety is maintained as demonstrated in the analysis provided by

General Electric Report NEDC-31323, "Increased Core Plow and Partial Feedwater Heating Analyses for Limerick Generating Station, Unit 1, Cycle 1".

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Limarick Gsnorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 78 Modification No.: 87-2140 A. System: Drywell Chilled Water B. Descriptions

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This modification changes the alarm setpoint of FAH-87-120 from .5 gpm above identified leak rate to .45 gpm above identified leak rate.

C. Reason for Change l This setpoint change will preclude the need to recalibrate L every time eithe:: a single or dual element is out of service.

D. Safety Evaluation Summary:

i) Does this modification increase the probability of occurrence or the consequences of an accident or r malfunction of equipment important to safety as L' previously evaluated in the safety analysis r;eport?

, Answer: No, the Drywell Air Cooler Condensate Drain

( Flow Monitoring System is not safety related and still performs its required function, f 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysir, report?

r Answer: No, because quantitative drywell leakage will still be detected by the Drywell Sump Level Monitor!ng System.

s lii) Does this modification reduce the margin of safety as defined in the basis for the Technict.1 Specifications?

s Answer No, because the intended function of the Drywell Air Cooler Condersate Drain Flow

, System is still met.

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Limorick Gonsrating Station

) Unit 1 l- Annual Plant Modification Report L July 1, 1987 Through June 30, 1988 l Page 79 Modification No.: 86-5040

( A. System: High Pressure Coolant Injection / Reactor Core Isolation Cooling B.

Description:

HPCI and RCIC test return valves will be modified to enable them to throttle the flow for the high pressure system test using the low pressure orifice plates and spacers. This will require the reorientation of HPCI and RCIC Test Return Line Valves HV-55-lF008 and HV-49-1F022 so that flow is from above l the disc (inlet becomes outlet).

C. Reason for Change:

These valves and orifice plates will reduce the HPCI/RCIC test pressure to permit system discharge to the condensate .

storage tank during their respective high pressure system tests.

D. Safet') Evaluation Summag :

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as

( previously evaluated in the safety analysis report?

Answer: No, this modification requires changes to the

[ HPCI/RCIC test return valves but does not i impact HPCI/RCIC full Llow test capability during normal operation or the testing of these valves during the power generation mode.

( The modified valves will continue to meet all design criteria originally apf licable to the valves. FSAR Sections 6.3.2.2.1 and 6.3.4 were reviewed in making this determination.

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Limerick Gsnorcting Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 80

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because these HPCI/RCIC modifications require changes to safety related test valves, but have no impact on the original system design including but not limited to system operation and testing, code class and seismic design, missile protection, pipe rupture i effects, environmental qualifications, and The electrical or control logic requirements.

modified valves will continue to meet all r

design criteria originally applicable to the l valvec. FSAR Sections 6.3.2.2.1 and 6.3.4 were reviewed in making this determination.

( iii) Does this modificatien reduce the margin of safety as defined in the basis for the Technical Specifications?

[ Answer: No, these modifications will maintain the L

capability for the system functional tests and verification of correct valve position. This r

modification does not require a change to any

[

Technical Specification based on a review of Technical Specification Section 4.5.1 (HPCI Surveillance Requirement 1) and 4.7.3 (RCIC f Surveillance Requirements).

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Lim 9 rick Ganorating Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 l Page 81 l

Modification No.: 86-5059 l A. System: Reactor Protection System B.

Description:

Remove spare electronic circuit cards installed in Redundant Reactivity Control System (RRCS) panels, and replace with 7

blank circuit cards.

C. Reason for Change:

This mcdification will reduce the possibility of the RRCS

{ self -test subsystem detecting test faults associated witn thesi spare cards, f D. Safety Evaluation Summary:

i) Does this modification increase the probability of occurrence or the consequences of an acc!. dent or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

( Answer: No, this modification removes spare circuit cards installed in the RRCS panels which are not required for the RRCS to be operational.

' Remeval of the spare cards reduces the susceptibility of the RRCS self-test subsystem to test faults, thereby improving the '

automatic surveillance of the RRCS. The RRCS

< will continue to operate as originally designed.

11) Does this modification create the possibility for un accident or malfunction of a different type than any evaluated previously in the safety analysis report?

4 Answer No, removal of the spare cards reduces the susceptibility of the RRCS self-test subsystem

- to test faults, thereby improving the automatic surveillance of the RRCS. The RRCS will continue to operate as originally designed.

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{ Lim 2 rick Gsnorating Station Unit 1 Annual Plant Modification Report

, July 1, 1987 Through June 30, 1988 l

Page 82

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

Answer No, the basis for Technical Specification 3/4.3.4 was reviewed to make this determination. The RRCS will continue to actuate the ATWS recirculation pump trip as required in response to an ATWS event.

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1 Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 83 Modification No.: 86-5139 A. System: Emergency Service Water B.

Description:

This modification installs a 3/4" globe valve, piping, and fitting connection pieces in lines #HBC-194 downstream of each diesel generator jacket water heat exchanger.

C. Reason for Change:

This modification supports future ESW system flow balancing by adding pressure test connections. This modification also relocatos the flow orifices to ensure accurate pressure readings.

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D. Safety 2 valuation 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 safety analysis report?

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Answer: No, this modification facilitaces future flow r balancing. The additions meet all the design

{ requirements applicable to the existing piping. FSAR Section 9.2.2 was reviewed to facilitate answering this question,

11) Does this modification create the possibility for an accident or malfunction of a different type than any ,

evaluated previously in the safety analysis report?

Answer: No, this modification facilitates future flow balancing. The additions meet all the design

( requirements applicable to the existing piping. These requirements include, but are not limited to, seismic design criteria and quality assurance.

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Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 84 i

I lii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

l Answer:

No, because the Technical Specifications do I

not address any requirements for pressure test connections.

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i Lim 2 rick Gsnoroting Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 85 Modification No.: 86-5228 A. System: Residual Heat Removal B.

Description:

This modification raises the set pressure of RHR Pump Suction Thermal Relief Valves PSV-51-lF030A,B,C and D by replacing the valve spring.

C. Reasor, for Change:

To prevent inadvertent actuation of the thermal relief valves due to over pressurization from the condensate transfer keep-full system.

g D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or -

( malfunction of equipment important to safety as previously evaluated in the safety analysis report?

f Answer No, this modification will help prevent inadvertent valve actuation while having no effect on the valve function. The RHR pump suction piping cannot be over-psessurized since the new set pressure is less than the system design pressure. The modification will meet all of the design requirements applicable to the existing relief valve.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, this modification will help prevent inadvertent valve actuation while having no effect on the valve function. The RHR pump suction piping cannot be over-pressurized

( since the new set pressure is less than the system design pressure. The modification will meet all of the design requirements applicable to the existing relief valve.

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Lim 3 rick G;norating Station Unit 1 Annual Plant Modification Report

, July 1, 1987 Through June 30, 1988 l

Page 86 l

l 1

111) De,es *.his modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, the Technical Specifications do not i address any requirements for the RHR pump

) suction piping thermal relief. Technical Specifications 3/4.4.9, 3/4.6.3, 3/4.5.1 and 1 3/4.5.2, which refer to the RHR System were l reviewed in making this determination.

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Limorick GOnorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1908 Page 87 Modification No.: 86-5235 A. System: Neutron Monitoring B.

Description:

This modification replaces Local Power Range Monitor (LPRM)

'SHA' type connectors with Qualified Quick Release Whittaker

'OLN' connectors.

C. Reason for Change:

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This modification is being initiated to minimize the radiation exposure to I&C personnel due to the maintenance l and repair requirements of the existing LPRM assemblies.

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 safety analysis report?

f Answer No, the 'OLN' connectors are tested to perform against the expected and dynamic service conditions and improves the original design and installation due to its quick disconnect feature.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, has been designed and tested to meet or exceed the performance requirements for the original equipment.

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

Answer,: This modification does not reduce the margin of safety as defined in the basis for any Technical Specification Section 2.2.1 (Reactor Protection System Instrumentation Setpoint).

Lim 2 rick Ganorating Station Unit 1 l

Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 88 Modification No.: S6-5236 A. System: Containment Atmospheric Control B.

Description:

This modification adds pressure test fittings to the inboard containment purge isolation valves and flange connections, adds isolation valves to the personnel airlock door pressure test connections, and adds secondary isolation valves to a t CAC purge supply drain line and various test connections on the PPRM and CAC Systems. It also removes unnecessary test connections.

C. Peason for Chanje:

This modification will provide compliance with 10CFR50, Appendix A, General Design Criteria (GDC) 53, 54, and 56 due to its more conservative design.

, D. Safety Evaluation Cummary:

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

{ previously evaluated in the safety analysis report?

Answer No, the new isolation valves will provide additional redundant isolation barriers on the affected lines. This modification will be k

consistent with the conclusion on Criterion 56 as referenced in FSAR Section 6.2.4.3.1.3.3.

All modified systems will continue to meet all design criteria originally applicable to those systems.

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Lim 3 rick Generating Stction Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 89 I

11) Does this modification create the~ possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, the new isolation valves will provide I

additional redundant isolation barriers on the affected lines. This modification will be consistent with the conclusion on Criterion 56 f as referenced in FSAR Section 6.2.4.3.1.3.3.

All modified systems will continue to meet all design criteria originally applicable to those systems.

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

Answer No, this modification adds secondary isolation boundaries to existing primary isolation boundaries. Therefore, this modification does not reduce the margin of safety as defined in

the basis of any Technical Specification.

Technical Specification Section 3/4.6.1, 3/4.6.3 and Table 3.6.3-1 were reviewed in making this determination.

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Limorick G3nsroting Station Unit 1 f Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 90 Modification No.: 86-5246 A. System: Nuclear Boiler B.

Description:

This modification involves the installation of (14) dual three-way solenoid valves supplied by GE/ Target Rock

) #PSV-41-1F013A,B,C,D,F,G,H,J,K,L,M,St the installation of blind flanges in place of PSV-41-140E,H,K,M,S and the installation of caps in place of PSV-41-142A,B,C,D,F,G,L,N.

C. Reason for Change To provide new solenoid valves capable of withstanding pneumatic supply line pressure up to 250 psig, and also to remove the interim fix originally installed to maintain pneumatic supply line pressure below the rated 135 psig of '

the old solenoid valves.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer No, the upgraded solenoid valves and modified air operators will be qualified to meet all seismic, environmental qualification, and operability requirements following all accidents previously evaluated in the PSAR.

The new solenoid valves and modified air operators increase the reliability of the SRV's, thus the probability of inadvertent SRV actuation is reduced and the probability of the occurrence of an accident previously evaluated is unchanged.

Limorick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 91

11) Does this modification create the possibility for an accident or malfunction et a different type than any evaluated previously in the safety analysis report?

Answer No, the new upgraded solenoid valves and modified air operators have the same function as the existing ones. They will be qualified to meet all required seismic, environmental qualification, and operability requirements.

No new possibility for malfunction is created by their installation. The upgraded solenoid valves and modified air operators will not compromise any safety-related system or component or prevent a safe shutdown of the i

plant.

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

Answer No, the Technical Specification requirements do not specifically identify solenoid valves l

and air operators in Technical Specification 3/4.3.3, 3/4.4.2, 3/4.5,1, 3/4.5.2, or 3/4.6.2, but the solenoid valves and air operators are needed to be functional in order

, to manually actuate the main steam SRV's. The upgraded solenoid valves and air operators will serve the same function as the existing solenoid valves and air operators.

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Lim 3 rick Gonarcting Station Unit 1

! Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 92 Modification No.: 86-5309 A. System: Security B. Descriptions Convert the entire refueling floor to a vital area to l accommodate refueling of the Unit i reactor.

C. Reason for Change l To modify the refueling floor area and hatchway to facilitate refueling operations for Unit 1.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, the modification does not affect Unit 1 safety related equipment. Floor penetrations, conduit, and fire barriers will be installed in accordance with approved procedures to insure that the structural integrity and fire rating of the refuel floor are not compromised.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

)

Answer No, because the mod does not affect Unit 1 l safety-related equipment. It uM rades the i security condition of the refueling floor to permit refueling operations.

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

i Answer: No, because the Security Systems and Unit 2 HVAC Systems affected by this modification are j not discussed in the Unit 1 Technical Specifications.

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Limorick GGnorcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 93 Modification No.: 87-5457 A. System: 4KV and Diesel Generator System B.

Description:

This modification removes fire protection trips in the diesel generator control circuits.

C. Reason for Change:

These trips are being removed to eliminate the only non-safety-related trip and correct a condition of non-conformance with the requirements of the Limerick FPER.

D. Safety Pvaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or l malfunction of equipment important to safety as previously evaluated in the safety analysis report?

I Answer: No, the removal of the fire protection system trips to the D/G's increases their availability and reduces the consequences of an accident as the D/G's now will not be vulnerable to a trip from a non-safety-related system. In addition, the ability to attain safe shutdown due to an Appendix R fire in the I

service water pipe tunnel is improved since a potential failure mechanism leading to disability of the D/G's is removed.

11) Does this modification create the possibility for an accident or malfunction of a different type than any I

evaluated previously in the safety analysis report?

Answer No, this modification does not introduce any new hazards in the plant or potential for h interference with safety-related functions.

This modification enhances the reliability of the D/G's oy removing the non-safety-related trip from the D/G controls.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 94 111) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer No, since the Technical Specifications and associated bases address the loss of a single D/G, this condition has no impact on the margin of safety defined in the bases for any Technical Specification. Also, the Technical Specifications do not reference the fire protection trips in the D/G circuits.

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Lim 3 rick Gonorating Station Unit 1

} Annual Plant Modification Report '

July 1, 1987 Through June 30, 1988 Page 95 r

Modification No.: 87-5503 l i

A. Systemt Reactor Water Clean-up (RWCU)

B.

Description:

Provide new penetration assemblies through the Reactor Water i Clean-up (RWCU) pump room walls. .

C. Reason for Change  !

To route utility lines required to facilitate the maintenance activities related to the Reactor Water Clean-up pumps, when l required.  ;

I D. Safety Evaluation Summary: t

1) Does this modification increase the probability of '

occurrence or the consequences of an accident or malfunction of equipment important to safety as i previously evaluated in the safety analysis report? '

Answert The penetration assembly meets all applicable }

design criteria for the RWCU pump room wall, L such as the HELB steam tightness requirement i and structural integrity. The probability of i a HELB occurring in the RWCU system is not L increased because no changes are being made to the RWCU system. There is no interference {

between the penetration assemblies and any L safety related equipment. The lines from both t ends of the penetration assembly to the  !

) connecting utility lines will be flexible l hoses and the electrical connection will be t done via tamporary flex conduit. The plant fire protection features are not affected by this change.

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Lim 3 rick G3norating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 96

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answers The modification does not introduce any new hazards since it does not involve safety-related equipment and will not affect any safety-related components. As discussed in paragraph IV.A.1, of the safety evaluation, the penetration assembly meets all applicable design criteria for the RWCU pump room wall.

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

l Answer: No, since there are no requirements in the Technical Specification which relate to the RWCU pump room walls or the subject utilities being used for maintenance purposes. This I

modification does not adversely affect the

, capability of safely shutting down the plant when required.

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Limorick Gonorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 97 Modification No.: 87-5550 A. Systems Control Rod Drive Hydraulic Control Unit (CRD HCU)

B.

Description:

This modification installs temporary lifting beams in the Reactor Enclosure in Areas 11, 12, 15, and 16, at Elevation 253'.

C. Reason for Change:

The beams will facilitate lifting of the CRD HCU water accumulators.

D. Safety Evaluation Summary:

1) 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 safety analysis report?

Answer No, because the temporary beams meet all applicable design criteria for Seismic Category IIA Plant Structural Components.

11) Does this modification create the possibility for an accident or malfunction of a different type than any j evaluated previously in the safety analysis report?

Answer: No, because the temporary beams meet all applicable design criteria for seismic Category IIA plant structural components.

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

Answer No, because this modification is in compliance with the provisions of Technical Specification Section 3/4.1.3 since the HCU water accumulators will only be lifted when the plant is in the shutdown mode (see sub-section 3.1.3.5.b.2).

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Lim 3 rick Ganarcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 98 Modification No.: 87-5573 A. System: Reactor Recirculation B.

Description:

This modification provides primary and ba:kup overcurrent protection for 1) the reactor recirculation pump motor space heater power circuits, 2) reactor recirculation pump M-G set drive motor breaker control power circuits, 3) reactor recirculation generator drive and field breaker lockout and auxiliary circuit power and 4) Reactor Protection System (RPS) main steam line isolation valve trip sensor control power to protect the penetration assemblies in penetrations 10JX106A, 10JX106B, 10JX105A, 10JX105B, 10JX105C and 10JX105D.

C. Reason for Change:

This modification provides primary and backup protection that will increase the level of penetration conductor overcurrent protection to comply with the recommendations of Regulatory Guide 1.63 which are committed to in the FSAR.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of l occurrence or the consequences of an accident or malfunction of equipment important to safety as l previously evaluated in the safety analysis report?

Answer:

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No, the additio of redundant overcurrent protection only affects the non-safety-related l RRPM space heater power circuits, RRPM-G set drive motor breaker control power circuit and reactor recirculation generator drive and I

field breaker lockout and auxiliary circuit control power. The additional fuses provide increased assurance that the safety-related penetration assemblies will be protected if an overcurrent event occurs.

Limarick G3norating Stetion Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 99

11) Does this modification create the possibility for an accident c; malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because it adds / replaces fuses in addition to the existing circuit breaker / fuses to provido primary and backup overcurrent protection to the penetration assemblies.

FFAR Sections 8.1.6.1.12 and 7.2 were reviewed in making this determination.

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

Answer No, Technical Specification Section 3/4.8.4, which was reviewed in making this determination, does not address 120VAC and 125VDC fuses, i

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Limerick Generating Station Unic 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 100 Modification No.: 87-5606 A. System: High Pressure Ccolant Injection System B.

Description:

HPCI turbine stop valves pressure test connection.

C. Reason fcr Change:

The addition of a pressure test connection to the HPCI Turbine Stop Valve TV-b6-112 is to monitor the steam balance chamber pressure during periodic system testing.

D. S fety Evaluation Summay :

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 safety analysis report?

Answer No, because the pressure test connection will be permanently installed and will meet the design criteria applicable to the HPCI turbine stop valves.

11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, neither the permanent pressure test connection nor the temporary test instrumentation will affect the safety-related function of the HPCI System.

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

Answer: No, because the addition of the pressure test connection does not affect the surveillance requirements of Technical Specification 3/4.5.1.

Limerick Generating Station  !

l Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 '

Page 101 i

Modification No.: 87-5627 A. System: Nuclear Boiler B.

Description:

l This modification replaces the calcium silicate insulation on  !

the Laedwater check valves with the Nukon blanket insulation.  !

C. Reason for Change:

This modification will reduce overall maintenance by as much (

as 50% and actual stay time by approximately 80%. This modification will also reduce radwaste because the Nukon blanket insulation is re-useable.  ;

D. Safety Evaluation Summary:

Does this modification increase the probability of l

i) occurrence or the consequences of an accident or l malfunction of equipment important to safety as previously evaluated in the safety analysis report? l Answer No, this change makes no functional change to j the Feedwater System. There will be no increase in the probability of occurrence or i the consequences of an accident because heat  !

( load and pipe stress considerations remain i

! within allowable values. This change will

! maintain the system's capability to function l as presently designed.

I 11) Does this modification create the possibility for an I accident or malfunction of a different typ than any  !

evaluated previously in the safety analysis report?

Answer No, there are no functional changes to the [

l Feedwater System and the system will maintain (

[ its capability to function as presently l designed. No accidents or malfunctions can l l

occur in the system that has not been i j considered in the present system design. l

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Lim 3 rick Gon3rcting Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988  ;

Page 102 [

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

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Answer: No, since there are no functional changes to j the system and because the system will  !

maintain its capability to function as l presently designed.  !

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Limorick Gonorating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1980 Page 103 I

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Modification No.: 87-5733 1

A. System: Nuclear Boiler B.

Description:

This modification deletes the LOCA Level II isolation signal from the control circuitry of the Main Steam Line Bypass Leakage Vent Valves HV41-140 and 141.

l C. Reason for Change 1

This modification will prevent the possibility of unnecessary venting of steam into the main steam tunnel during a reactor water low level II condition.

D. Safety Evaluation Summary:

1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluatec in the safety analysis report?

Answert This modification does not prevent the vent valves HV41-140 and 141 from performing their I

safety related functions. A large steam release to the steam tunnel has been analyzed l in Chapter 15 of the FSAR as part of the main steam line break accident. Elimination of automatic isolation signal to Vent Valvus l NV41-140 and 141 would reduce the probability l

of occurrence of this accident. These valves

! are no more likely to malfunction (not open) if they are opened manually or automatically, i

The pat-LOCA opening of Valves MV41-140 and 141 is a safety-related function to prevent secondary containment bypass leakage and for which credit is specifically taken in FSAR Section 6.2.3.2 and 6.2-15.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 104 l 11) t modification create the possibility for an

. or malfunction of a different type than any

e. .6 previously in the safety analysis report? .': {_

Ar.swe r : No, this modification affects safety-related equipment and wiring but does not prevent the  ;}

subject valves from performing their .

/

safety-related function. /

The operability of the system to the degree required to perform its safety-related functions (as defined by MSIV-LCS operability requirements to which this system is analogous in function) is maintained in this '

modification since the change only replaces an automatic valve actuation with a manual '

actuation. .

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defined in the basis for the Technical Specifications?

Answer:~-

No, this modification deletes the automatic -

opening of Vent Valves HV41-140 and 141 but it does not prevent them from performing their secondary containment bypass leakage control function since the subject valves are operable  :,-

manually using the procedures GP-8 and T-250. /

This modificatior, eliminates the possibility of dumping of radioactive eteam into the steam e , ,

tunnel in the event of a LOCA Level II. The MSL Drain Vent Valves HV41-140 and 141 are not addressed in any Technical Specifications. .

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l Limarick Gensrating Station Unit 1 ,

Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 105 Procedure Number:: A-4 A. Procedure Name and R2 vision Number:

Plant Operations Review Committee Procedure, Revision 8 B. Description of Change:

1. There is an organizational change in the structure of upper management. The responsibilities of the "Station Superintendent" are now delegated to the "Plant Manager". This change has occurred numerous times throughout the procedure.

2. The members of the PORC committee have changed. The chairman of the PORC has changed from Station Superintendent to the Superintendent of Operations.

3. The position of the Superintendent, Generation Division 4

- Nuclear no longer exists. The LGS responsibilities of this position are now held by the Vice President - LGS.

C. Reason for Change:

I The change is due to a reorganization in the management structure.

I D. Safety Evaluation Summary:

1) Does this procedure revision increase the probability of l occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

l Answers

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No, because this revision reflects l organizational and PORC membership changes l requested by PECo in a License Amendment Application. Tech. Spec. changes have not been approved and issued by the NRC however f NRC letter (Varga to Bauer 12/18/87) stated that implementation of the changes may proceed immediately.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1983 Page 106

11) Does this procedure revision create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because even though the Tech. Spec.

changes have not been approved, the NRC has given the plant permission to implement the changes immediately (letter Varga to Bauer 12/18/67).

iii) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because even though the Tech. Spec.

changes have not been approved, the NRC has given the plant permission to implement the changes immediately (letter Varga to Bauer .

12/18/87).

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 107 Procedure Number A-50 A. Procedure Name and Revision Number:

Procedure for Conduct of Station Training, Revision 2 B. Description of Change:

The revision adds commitments to base training programs on a systematic approach to training.

l l Personnel titles are changed to reflect the new corporate / station organization.

The procedure now requires certification of instructors and provides a mechanism for this.

The revision adds additional groups to "Plant Staff" and adds

or amends their training requirements.

Requalification training now includes review of industry events and plant changes.

The revision makes changes to reflect the 1987 revision to 10CFR 55.

The Nuclear Training Group may, in addition to the Fossil Hydra Group administer non-licensed operator qualification ex a.ni na t ion s .

C. Reason for Change:

The reason for the procedure revisions include the following:

1. Amendment of 10CFR 55, 1987

2. Change in corporate and stacion organization

3. Enhanced commitment to INPO training methodologies

Limerick Generating Station Unit 1 Annual ?lant Modification Report July 1, '

987 Through June 30, 1988 Page 108 D. Safety Evaluation Summary

i) Does this procedure revision increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because having the procedure reflect the actual plant organization avoids confusion or I omissions that might af fect accidt:nt l probabilities or severities. Additionally compliance with current regulations has no l adverse effect.

l ii) Does this procedure revision create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety al.alysis report?

Answer: Nc because compliance with the current regulations and current station organization

. will encourage operation within established, analyzed bounds, iii) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the procedure still meets all Technical Specifications requirements.

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l Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 109 i Procedure Number: A-50, Appendix B l

l A. Procedure Name and Revision Number:

Licensed and Senior Licensed Operator Revision 2

, B. Description cf Change:

i

! Personnel titles are changed to reflect the new organization.

1 INPO guidelines are committed to and implemented.

The number of lectures per cycle are doubled frcm 6 to 12.

The concept of "actively performing the function" is added for maintenance of an active license.

The number of bours per quarter "at the controls" needed to naintain an active licenso is increased from 16 to 56.

The requirements for requiring active status are increased from an oral exam to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> "at the controls" under supervision and completion of a OJT manual.

The revision includes review of industry events in the requalification program.

The revision changes the license term from 2 years to 6 years.

The procedure now includes a provision for removing licensed personnel from licensed duties for failures during the requalification program.

C. Reason for Change:

The reason for the procedure revisions include the following:

1. Amendment of 10CFR 55, 1987

2. Change in corporate and station organization

3. Enhanced commitment to INPO training methodologies

Limerick Generating Station Unit 1 Annual Pl&nt Mcdificatien Report July 1, 1987 Through June 30, 1988 Page 110 D. Safety Evaluation Summary:

i) Does this procedure revision increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because having the procedure comply with current regulations and reflect the actual

, plant organization avoids confusion or omissions that might affect accident probabilities or severities.

11) Does this procedure revision create the possibility for an accident or malfunction of a different t}pe than any evaluated previously in the safety knalysis report?

Answer: No, because compliance with the current regulations and ine]usion cf actual plant crganization will tend to re-enforce operation within establisned, analyr.ed bounds.

iii) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the procedure still reflects all Technical Specification requiremente.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 121 Procedure Number: A-50, Appendix C A. Procedure Name and Revision Number:

Non-Licensed (Floor) Operator Training, Revision 2 B. Description of Change:

Personnel titles are changed to reflect the new station organization.

Nuclear Training section in addition to Fossil-Hydro may give qualification examination.

Non-Licensed supervisors are included in the program.

Documentation of Instructor review of qualification books and review of industry events have been added to the program.

C. Reason for Change:

The reason for the procedure revisions is the change in the corporate and station organizations. Additionally changes are included to enhance the program.

D. Safety Evaluation Summary:

1) Does this procedure cevision increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated la the safety analysis report?

Answer: No, because having the procedure reflect the actual plant organization avoids confusion or omissions that might affect accident probabilities.

11) Does this procedure revision create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer: No, because including the actual plant organization will encourage operation within established analyzed bounds.

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 112 k

lii) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the procedure still meets Technical Specification requirements.

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Limerick Generating Station Unit 1 Annual Plant Modification Report s July 1, 1987 Through June 30, 1988 Page 113 Procedure Number: A-50, Appendix D

?

A. Procedure Name and Revision Number:

Plant Staff Training, Revision 2 B. Description of Change:

Additional groups including raintenance, instrumentation and controls and the Technical Assistant on Shift are added to the plant staff training program.

Review of industry events is added to the program.

C. Reason for Change:

The reason for the procedure revisions is the change in the corporate and station organizations. Additionally there is an enhanced commitment to INPO training methodologies.

D. Safety Evaluation Summary:

1) Does this procedure revision increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

Answer: No, because having the procedure reflect the actual plant organization avoids confusion or ..

omissions that might affect accident o probabilities or severities.

ii) Does this procedure revision create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, because inclusion of actual plant organization will encourage operation within established analyzed bounds.

Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 114 111) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the procedure still meets Technical Specification requirements.

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Limerick Generating Station Unit 1 Annual Plant Modification Report July 1, 1987 Through June 30, 1988 Page 115 Procedure Number: A-50, Appandix E A. Procedure Name and Revision Number:

General Initial and Miscellaneous Training, Revision 2 B. Description of Change:

Personnel titles are changed to reflect the new station organization.

The frequency for fire drills is increased.

Training of refueling platform operators is added.

C. Reason for Change:

The station organization has changed. Additional training was included for the implementation of station requirements.

D. Safety Evaluation Summary:

1) Does this procedure revision increase the probability of occurrence or the consequences of en act'. dent or malfunction of equipment important to safety as previously evaluated in the safety analysis report?

l Answer: No, because having the procedure reflect the i actual plant organization avoids confuuion or omissions that might affect accident probabilities or severity. Also additional or more frequent training improves operator skills,

11) Does this procedure revision create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?

Answer No, because having the procedure reflect the actual plant organization and include additional training will aid in operation along established, analyze 6 lines.

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Limerick Generating Station Unit 1 Annual Plant Modification Report "

July 1, 1987 Through June 30, 1988 Page 116 '..

,e lii) Does this procedure revision reduce the margin of safety as defined in the basis for the Technical Specifications?

Answer: No, because the procedure still meets "e Technical Specification requirements. -

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