ML20210J920

CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802- 990201

ML20210J920
Person / Time
Site:	Comanche Peak
Issue date:	02/01/1999
From:	TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20210J913	List: ML20210J920 ML20210J939 TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630
References
NUDOCS 9908050142
Download: ML20210J920 (84)

Text

COMANCHE PEAK STEAM ELECTRIC STATION 10CFR50.59 EVALUATION

SUMMARY

REPORT 0008 l

9908050142 990002 PDR ADOCK 05000445 R Pm L -.

Attachment 1 to TXX-99182 Page 2 of 85 i COMANCHE PEAK UNITS 1 AND 2 10CFR50.59 EVALUATION

SUMMARY

REPORT 0008 TABLE OF CONTENTS l SE-91-062 Rev. 9 SE-98-020 Rev. O SA-98-022 l SE-94-079 Rev. 2 SE-98-021 Rev. O SA-98-029 l l- SE-95-007 Rev. O SA-96-067 SE-98-022 Rev. 0 l SE-96-022 Rev. O SA-96-093 - SE-98-023 Rev. O SA-98-026 l SE-96-026 Rev. 0 l SE-97-005 Rev. O SA-97-018 SA-98-033 l SE-97-020 Rev.1 SA-98-023 SE-98-025 Rev. 0 SE-97-023 Rev. O SA-97-033 SE-98-027 Rev. O SA-98-046 SE-97-031 Rev. O SA-97-043 SE-98-028 Rev. O SA-98-049 SE-97-033 Rev. O SE-98-029 Rev. O

SE-97-034 Rev. O SE-98-030 - Rev.1 SA-98-050 SE-97-045 Rev. O SA-97-056 SE-98-032 Rev. O SA-98-072 l SE-97-047 Rev. O SE-98-033 Rev. O SA-98-060

! SE-97-050 Rev. O SA-97-073 SE-98-035 Rev. O SA-98-089 SE-97-051 Rev. O SA-97-076 SE-98-036 Rev. O SE-97-055 Rev. O SA-97-078 SE-98-037 Rev. O SE-97-058 Rev. O SE-98-038 Rev. O SA-98-100 SE-97-060 Rev. O SE-98-039 Rev.1 i SE-97-062 Rev. O SA-97-089 SE-98-040 Rev. O SA-98-124 SE-97-063 Rev. O SA-97-092 SE-98-041 Rev. O SA-98-067 SA-97-093 SE-98-042 Rev. O SA-98-129 l SE-97-064 Rev. O SA-97-097 SE-98-046 Rev. O SA-98-142

SA-97-098 SE-98-047 Rev. 0

'SE-97-065 Rev.1 SA-97-096 SE-99-001 Rev. O SA-99-001 SA-97-150 SE-99-002 Rev. 2 L SE-97-068 Rev. O SE-99-003 Rev. O SA-99-004 ,

l . SE-97-070 Rev. O SA-97-114 SE-99-005 Rev. O j l SE-97-072 Rev. O SA-97-116 SE-99-006 Rev. O l i SE-97-082 Rev. O SA-97-148 SE-99-007 Rev. O SA-97-075 SE-97-083 Rev. O SA-97-149 SE-99-009 Rev. O SA-98-012 SE-97-089 Rev. O SA-97-158 SE-99-010 Rev. O a r SE-98-001 Rev. O SA-97-111 SE-99-012 Rev. 0 l SE-98-005 Rev. O SE-99-013 Rev. O

SE-98-007 Rev. O SA-98-007 SE-99-014 Rev. O SE-98-008 Rev. O SA-98-008 SE-99-015 Rev. 0 l SE-98-010 Rev. O SA-98-011 SE-99-016 Rev. O SE-98-011 Rev. O SE-99-017 Rev. O SE-98-012 Rev. O SA-98-014 SE-99-019 Rev. O SA-98-0140 SE-98-013 Rev. O SA-98-019 SE-99-023 Rev. O SE-98-014 Rev. O SE-99-024 Rev. O SE-98-015 Rev. O SE-99-026 Rev. O SE-98-016 Rev. O SA-98-016 SE-99-027 Rev. O SA-98-127 SE-98-017 Rev. O SE-98-018 Rev. O SE-98-019 Rev. 0 l

Attachment 1 to TXX-99182 TU Elactric Page 3 of 85 Unit: NN2 Evaluation Number SE-91-062 Revision 9 l

l Activity

Title:

l RADIOACTIVE MATERIAL' AND RADIOACTIVE WASTE HANDLING AND l STAGING IN AREAS OUTSIDE THE PLANT Description of Change (s):

Due to insufficient space inside the plant, designated areas outside the plant are l

required for radioactive material and radioactive waste handling and staging. The fenced area east of the Fuel Building and areas in and adjacent to Warehouse C will be used for radioactive material and radioactive waste handling and staging. Revision 8:

This revision adds abrasive blasting of contaminated components within suitable enclosures maintained under negative pressure to the list of evaluated activities.

Revision 9: This revision adds building 3K14 to the areas evaluated for the performance of the activities addressed within this Safety Evaluation. Specifically, abrasive blasting and self-contained CO2 decontamination within this additional structure are evlauated and determined to be acceptable. In addition, the use of evaporator to concentrate the radioactive effluent from the onsite vendor laundry is also evaluated and incorporated into the scope of this Safety Evaluation.

Summary of Evaluation:

This evaluaiton considered normal operations in these areas and potential waste handling mishaps. It was determined that this activity does not involve an unreviewed safety question because the impacts of the credible mishaps are enveloped by existing analyses that are within 10CFR100 limits.

'l

r

' Attachment 1 to TXX-99182 TU El:ctric f Page4 of 85 Unit: NN2 i.

Evaluation Number SE-94-079 Revision 2 Activity

Title:

UNIT 1 STEAM GENERATOR ATMOSPHERIC RELIEF VALVE RETROFIT Description of Change (s):

l This activity will retrofit the existing Unit 1 Steam Generator Atmospheric Relief Valves

l. (ARVs), utilizing CCI DRAG velocity control trim and new actuators. A fire protection line is being rerot;ted to avoid an !nterference. Conduits to the actuator limit switches are being upsized and rerouted as required and connecting ECSAs are being changed.

Instrument air tubing to the new actuators is also being rerouted as required.

l Summary of Evaluation:  ;

The ARV retrofit will provide tighter valve shutoff, which will reduce steam loss and seat damage to the valves. The retrofit will improve controllability of the valves and will also preclude the need for routine stroke length checks. The fire protection line being rerouted will have no adverse effect on the fire suppression coverage in the affected room. Since the ARV retrofit is being designed and installed to the existing design requirements as delineated in the LBDs, this activity will have no adverse impact on I_ any existing structures, system, or components. This activity will not have any affect on accidents, malfunctions or the margin of safety as described in the LBDs.

l 1-l

l l Attachment 1 to TXX-99182 TU El:ctric

[ Page 5 of 85 Unit: NN2 Evaluation Number SE-95-007 Revision 0

' Activity

Title:

Rebalancing Loadings / Changing Description to Regulating Transformer for Transformers CPX-EPTRNT-42,-43,-44 & -45 l

Description of Change (s):

1 Calculation 16345-EE(B)-044 R5 (CCN-001 & -004) has been issued to balance the transformer loads between the phases by rearranging the circuits. The activities associated with this evaluation involve plant modification, revisions to design basis l documents DBD-EE-057 & DBD-ME-011 and engineering specification 2323-ES-100 l by DCN 7926 RO, and updating FSAR section 8.3 to reflect these loading changes.

Additionally, FSAR section 8.3 is revised to change the description of these transformers CFX- EPTRNT-42,-43,-44, and -45 from " isolating transformers to

" regulating transformers". i

, Summary of Evaluation:

Some of these transformers were unbalanced between their phases. Therefore the loads in panels fed from these transformers are being rearranged to achieve balanced loads between the phases of the transformers. The rearrangements of the loading have no adverse impact on Class 1E system. These transformers are non Class 1E

! regulating transformers per DBD-EE-041 Revision 5 and are not used for isolating l purposes. The isolation of Class 1E bus is provided by two Class 1E breakers in series at Motor Control Center feeding these transformers and therefore the transformer description is being changed to " regulating transformers". These activities do not have any effect on accidents, margin of safety or malfunction as described in licensing basis

documents. Based on the results of this evaluation, implementation of the proposed activities do not involve an unreviewed safety question.

i I

l-l

l. '

L i _.

l' Attachment 1 to TXX-99182 TU Elsctric Page 6 of 85 Unit: NN2 l Evaluation Number SE-96-022 Revision 0 1 Activity

Title:

, SSPS INPUT RELAY SURVEILLANCE EXTENSION -

l l Description of Change (s):

Prior to the installation of bypass test capability in the 7300 Process Protection System and the Nuclear instrumentation System (NIS) at Comanche Peak, the Solid State  ;

Protection System (SSPS) normally energized input relays were cycled (tested) quarterly as part of the Analog Channel Operational Test (ACOT). The input relay test was performed as part of ACOT since the normally energized channels where required to be tripped when out of service. Since installation of bypass test capability precludes the need to place a channel in the trip condition, cycling of the SSPS input relays will now be performed every 18 months as part of the channel calibration testing requirements. 1 Summary of Evaluation

This activity consists of a change in the surveillance period for the input relays and does not involve any functional or hardware changes. Input relay testing performed every 18 months, rather than quarterly, will not affect the operability or reliability of the input relays. Cycling of the SSPS input relays is not required to determine operability of the channel after removal of the bypassed condition. Several SSPS input relays must fail simultaneously for such failures to result in a loss of function.- The probability of a loss of function is unaffected by the surveillance period extension.

Attachment 1 to TXX-99182 TU El:ctric Page 7 of 85 Unit: NN2 Evaluation Number SE-96-026 Revision 0 Activity

Title:

Installation of ASME Code Class Blind Flange Outside Containment to Seal Penetration Description of Change (s):

The new design provides for the installation of an ASME code class blind flange outside containment to seal off the penetration that does not meet acceptable local leak rate criteria. The design basis provides the justification for using the blind flange as a repair to the outside containmnet isolation valve.

Summary of Evaluation:

The evaluation determined that the blind flange is an acceptable substitute for the

- outside containment valve under the Technical Specifications. The seal provided by the double "O" ring on the blind flange is equal to or better than the seal privided by the rubber seat material in the containment isolation valve.

Attachment 1 to TXX-99182 TU El:ctric Page 8 of 85 Unit: NN2 l' '

L Evaluation Number SE-97-005 Revision 0  ;

Activity

Title:

installation of a new pump skid to split the Condenser Vacuum and Water Box Priming l

functions  ;

I Description of Change (s):

This activity entails installing a new vacuum pump skid in Unit 1 to improve the existing Condenser Vacuum (CV) and Waterbox Priming System. This will reduce maintenance activities associated with the existing condenser exhausters. There is a continuous problem stemming from water carryover from the waterbox priming portion of the .

system and biological growth in the system. Piping from the main and auxiliary

condenser waterboxes and the Turbine Plant Cooling Water (TPCW) heat exchanger will be disconnected from the respective condenser shell exhaust piping and run separately to a new duplex vacuum priming pump skid. This will leave the existing condenser exhausters for the main condenser side air removal process. There are no new regulatory commitments changed due to the installation of this new vacuum pump skid.

Summary of Evaluation:

All credible failure modes have been previously analyzed and no new failure modes are introduced by the implementation of this activity. There is no effect on accidents and malfunctions evaluated in the Licensing Basis Documents. There is no potential for creating a new type of unanalyzed event. There is no impact on the Technical Specifications or their bases, nor is there any affect on the margin of safety as a result of this activity or its implementation.

l o

\

i

p Attachment 1 to TXX-99182 TU El:ctric Page 9 of 85 Unit: NN2 Evaluatirn Number SE-97-020 Revision 1 Activity

Title:

i LDCR-SA-97-035 & 98-023; Polar Crane Operation During Modes 1-4 to Support Polar Crane Inspection, Functional Checks and Prev. Maint.

Description of Change (s):

Revision 0 Prior to entering outages, polar crane operation is required to perform certain inspections, functional checks and preventative maintenance (PM) activities. To preclude the crane from being a restraint to refueling operations the PMs should be performed prior to the refueling outages. The polar crane may be energized during MODES 1-4. The crane will remain essentially in the park position (FSAR Figure 1.2-8). No load will be carried during MODES 1-4. A compensatory measure (operator, in direct communication with the control room, at the power supply disconnect outside containment) is established to prevent inadvertent operation of crane due to High Energy Line Break in containment. Revision 1 Use the polar crane as a work platform in Modes 3 and 4.

Summary of Evaluation:

Should a LOCA or MSLB occur during crane operation the potential exists for the crane to operate spuriously due to environmental effects causing damage to the safety related SSCs inside the reactor building. To preclude this from occurring during operation of the crane during Modes 1-4 an operator in communication with the Control Room shall be stationed at the power supply disconnect outside containment. Should either area become uninhabitable, the operator shall open the power disconnect and leave the area. Any movement of the crane should be small enough so that the crane ope'rator inside containment can safely exit the crane in Modes 1 and 2. The crane is to remain essentially in the park position (FSAR Section 9.1.4.2.3.14, Figure 1.2-8) during mode 1 and 2. During Mode 3 and 4 the crane may be operated through its full 360 degree travel range. The trolley is to remain as close to the liner plate / crane rail as possible. The book is not to be moved outside the park position. The hook should not be placed in a location to impact any safety related SSC (e.g., Hydrogen Recombiner).

No load is to be carried by the crane. The limitations in this SE will be incorporated into the appropriate Maintenance procedures and DBDs. This activity does not pose any unreviewed safety question.

l L

r Attachment 1 to TXX-99182 TU El:ctric Page 10 of 85 Unit: NN2 l-Evaluation Number SE-97-023 Revision 0 -

Activity

Title:

' Modify control logic for 1-FV-2239 to " failed closed" in the event of an electrical power failure in control circuit Description of Change (s): .

l The control logic for 1-FV-2239 is being changed to " fail closed" in the event of an electrical power failure in the control circuit. The normal valve function, to open in order to maintain adequate flow and protect the Condensate Pumps, remains unchanged.

Also, loss of air failure will continue to result in an " failed open" valve position.

Summary of Evaluation:

This change to the control circuit will result in the valve remaining in the normally closed position (normal power /high flow operations) or repositioning a closed position (Iow power / low flow operation) in the event of a fuse failure. Operators will take other actions in the event of low flow coincident with a fuse failure to protect the Condensate Pumps, which have no safety function and are low energy pumps with sufficient time available for the operator to establish adequate recirculation flow. This modification results in more stable plant operations and continues to ensure the Condensate Pumps are protected from low flow conditions. A positive effect will be realized for the accident analysis as the until will be less susceptible to a loss of feedwater transient that can lead to a reactor trip.

i I

L l

y

Attachment 1 to TXX-99182 TU El ctric Page 11 of 85 Unit

NN2 Evaluation Number SE-97-031 Revision 0 -

Activity

Title:

Design Modification for Letdown isolation on Safety injection Signal "S" for Valves 1-LCV-459 and 1-LCV-460-

' Description of Change (s):

This Unit 1. design modification provides an automatic closure on a Safety injection

l. Signal for Letdown isolation valves 1-LCV-0459 and 1-LCV-460. This automatic l closure will then automatically cause the Letdown Orifice Isolation valves 1-8149 A, B, j C to go closed due to the present electrical interlock scheme. By providing this

! automatic isolation on a Safety injection Signal, relief valve 1-8117 will not lift (due to  ;

l the closure of Containment Isolation Valves 8152 and 8160 on safety injection '

i actuation signals) elminating an ALARA concern and ensuring manual operator action i

j. is not required during a safety injection signal. A new handswitch will also be installed l that will give the Operator the ability to bypass the Safety injection Signal for both

valves 1-LCV-0459 and 1-LCV-460. This bypass will be used during the performance l l of surveillances when closure of these valves is not desired. The system design l basis document and the FSAR (Table 7.3-4) will require updating to reflect 1-LCV-0459 1 and 1-LCV-460 as equipment actuated on a Safety injection Signal. They will l

appropriately note that the ESFAS function is "None" since the closure is not required l for Nuclear Safety.

l

! Summary of Evaluation:

l Containment isolation Valves 8152 and 8160 close on safety injection actuation signals. If the letdown isolation valves LCV-0459 and LCV-460 are not closed, as has hapened during spurious events, relief valve 8117 has lifted (as designed) and exceeded the capacity of the pressurizer r. nef tank. This ALARA concern was i addressed by changes to the Emergency O mating Procedures (EOPs) to close the I valves manuaily which is an " operations wc 4 around." By providing automatic isolation l on a Safety injection Signal, relief valve 1-8117 will not lift eliminating the ALARA concern and ensuring manual operator action is not required during a safety injection signal. This Safety injection actuation is solely for the purpose of assisting in the L response to a Safety injection Signal so that the EOP step is not considered an L operator work around. This EOP step will not be altered because it is acceptable to

, have the Operator verify that the automatic Letdown isolation of the "S" signal did -

i occur. This EOP step may be removed from the procedure in the future as it is no longer needed for a spurious SI. The function of these valves, (to prevent the uncovering of the pressurizer heaters on low pressurizer level), has not been altered.

The added signal is not required for safety. The new handswitch was evaluated for

Human Factors and was found to be acceptable based on the guidance in NUREG-700. The addition of the Class 1E cable and switch, and the'use of an existing Safety-related relay will not create any event that has not been analyzed previously and will not alter or impede the function of these valves. Any cable or relay fault or open circuit will remove power to the valve supporting the close function of the valve.  ;

= Attachment 1 to TXX-99182 TU El:ctric Page 12 of 85 Unit: NN2 Evaluation Nurr.ber SE-97-033 Revision 0 Activity

Title:

Temporary Modification: Plug the Local Floor Drains in the Main Steam FW Piping Penetration Area Outside Containment Rooms 1-100A/1-110 ,

' Description of Change (s):

This activity involves a Temporary Modification to plug the local floor drains in the Main Steam and Feedwater Piping Penetration areas outside containment. A Main Steam Line or Feedwater Line break in these areas creates the potential for environmental conditions to become unacceptable in other rooms of the Safeguards Building which j '

could impair the function of safety related equipment. The installation of the drain plugs will satisfy the environmental concems because the parameters of pressure, temperature, flooding, and humidity will be maintained within acceptable limits should the described pipe break occur. In addition, no credit was taken for function of these non-safety drains in the flooding analyses. The plugging of the drains therefore does not affect the flooding analyses.

Summary of Evaluation:

- Consideration has been given for all potential failure modes for this activity, and it has been determined that there are no credible failure modes that could adversely affect i sytems, structures, or components resulting in an increase in the probability, severity, or consequences of any accident analyzed in LBDs.' The activity does not involve an ,

Unreviewed Safety Question or require an amendment to the Technical Specifications.

This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an upset, emergency, or faulted condition.

l to TXX-99182 TU El:ctric Page 13 of 85 Unit: NN2 Evaluation Number SE-97-034 Revision 0 Activity

Title:

Temporary Modification: Plug the Local Floor Drains in the Main Steam FW Piping Penetration Area Outside Containment Rooms 2-100A /2-108 Descript!on of Change (s):

This activity involves a Temporary Modification to plug the local floor drains in the Main Steam and Feedwater Piping Penetration areas outside containment. A Main Steam

. Line or Feedwater Line break in these areas creates the potential for environmental conditions to become unacceptable in other rooms of the Safeguards Building which could impair the function of safety related equipment. The installation of the drain plugs will satisfy the environmental concerns because the parameters of pressure, temperature, flooding, and humidity will be maintained within acceptable limits should -

the described pipe break occur, in addition, no credit was taken for function of these non-safety drains in the flooding analyses. The plugging of the drains therefore does not affect the flooding analyses.

4 Summary of Evaluation:

Consideration has been given for all potential failure modes for this activity, and it has been determined that there are no credible failure modes that could adversely affect i sytems, structures, or components resulting in an increase in the probability, severity, or consequences of any accident analyzed in LBDs. The activity does not involve an Unreviewed Safety Question or require an amendment to the Technical Specifications.

This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an upset, emergency, or faulted condition. I 1

1 i

Attachment 1 to TXX-99182 TU Elactric Page 14 of 85 Unit: NN2 l Evaluation Number SE-97-045 Revision 0 Activity

Title:

Unit 1 instrument Air Compressor Manual Sequencers Description of Change (s): l l For each Unit 1 Instrument Air Compressor (1-01 & 1-02) a local manual sequencer consisth; of adding a second pressure switch and providing a manual selector switch l

to choc v2 lead or backup operating range will be provided. The second pressure

- switch will be set to the current setpoint of the other corppressor. For example, Compressor 1-01 is currently the lead compressor with a pressure switch on the outlet of the compressor set to load the compressor when pressure drops to 105 psig and i unload at 115 psig. The second switch will be set at 100/115 to load / unload, respectively. This will give Operations the ability to place Compressor 1-01 in the backup mode and place Compressor 1-02 in the lead mode. Similiarly, Compressor 1-02, will have a second pressure switch / selector switch added and set to load / unload at 105/115 psig.

Summary of Evaluation:

This change to the load / unload control circuit of the Unit 1 instrument Air Compressors will result in more evenly distributed run time and wear. The Instrument Air Compressors are not safety related, but a reliable source of instrument air is necessary to operate the unit. Without instrument air, air operated components fail to ieir safe condition resulting in a unit shutdown. This modification will result in a more reliable instrument Air System for two (2) major reasons: 1) The Instrument Air Compressors will have more evenly distributed run time and wear. Switching the lead compressor periodically and having less reliance on the backup compressor as the lead compressor becomes less reliable owing to excessive use, and 2) Ensure equipment reliability, confidence and readiness by eliminating potential problems associated with standy equipment, e.g., bearing failures, lubricant deprivation, etc. The implementation of this activity will not increase the probability of a licensing basis accident / malfunction of a different type than previously evaluated.

l I

I i

o a Attachment 1 to TXX-99182 TU El:ctric Page 15 of 85 Unit: NN2 Evaluation Number SE-97-047 Revision 0 l Activity

Title:

l The temporary removal of tornado dampers and floor hatch plugs to facilitate sludge removal from el. 773'-0" Description of Change (s):

This activity involves the temporary removel of tomado dampers CP1-TVSGTD-10, CP2-TVSGTD-10 located in the floor at elevation 810'-6" and the floor plugs in rooms 1-70 and 2-70 at elevation 790*-6". This activity will facilitate the removal of sludge  ;

from the floor drain tanks (Work Orders 3-97138184-01, 3-97-318183-01) at elevation 773'-0" and if required the sludge from the laundry hold up tanks and floor drain tank No. 3 at elevation 790'-6" by using the hoist at elevation 810'-6". The removal of these barriers create new flow paths resulting from postulated pipe breaks not previously evaluated. For example, the floor plugs serve as a flooding and an environmental barrier, while the tornado dampers serve as an environmental barrier.

Summary of Evaluation:

The removal of the floor plugs created a new flow path for flooding at elevation 773'-0".

The resulting flood levels were below the elevation of equipment necessary to perform i a safety function. The removal of the tomado dampers did not cause the propagation j of harsh environments resulting from pipe breaks to the lower elevations. There are no previously unreviewed High Energy Line Break interactions created by the removal of these barriers. The removal of the tornado dampers and floor plugs do not have a negative impact on the tornado venting analyses. There are no credible failure modes i that could be inta;duced by implementation of this activity.

1

Att:chment 1 to TXX-99182 TU El:ctric l Page 16 of 85 Unit: NN2 l

l .

Evaluation Number SE-97-050 L Revision 0 1>

Activity

Title:

Water Hammer issues Related to Heater Drain for Unit 1 Description of Change (s):

The Unit 1 Hester Drains System is modified to reduce water hammer events. The Heater Drain Pump recirculation lines are extended inside the Heater Drains Tanks to i below water level. The pump discharge valve is resized and isolation valves are added.

The tank alternate drain valve is resized and its isolated valves are added. The tank attemate drain valve is resized and its isolation valves are replaced. The Heater Drain {

' Pump isolation valves and discharge check valves are replaced. Warm up lines are 1 l added where appropriate. New nozzle check valves are added in the drain lines of l Feedwater Heaters 2A and 28. Bypass lines are added around valves 1HD-0617 and 1HD-0718.

Summary of Evaluation:

The modifications will reduce the frequency and severity of water hammer events in the Heater Drains System. All the systems involved in the modification are not required for safety, have no protective functions and can not impair the ability of protection systems to function. The only accidents in Chapter 15 that could be impacted by the SSCs associated with this proposed activity are those described in Chpater 15.1, " Increase in Heat Removal by the Secondary System" and Chapter 15.2, " Decrease in Heat Removal by the Secondary Systems". The probability of occurrence of these accidents is expected to decrease due to this activity. There is no unreviewed safety question.

I I

l I

1 j

o

' Attachment 1 to TXX-99182 TU El:ctric Page 17 of 85 Unit: NN2 I

Evaluation Number SE-97-051 Revision 0 Activity

Title:

SEPERATION REQUIREMENTS FOR NUCLEAR INSTRUMENTATION SYSTEM (NIS) CIRCUlTS.

L Description of Change (s):

Add the following clarification to separation requirements for Nuclear Instrumentation l System (NIS) circuits (FSAR Section 8.3.1.4.5): " Any deviations are justified on a case by case basis to ensure that unacceptable noise is not induced onto the NIS signal cable".

Summary of Evaluation:

The NIS seperation requirements are based on the recommendations of Westinghouse standards for installation of protection system signal cables. Complying with this  !

criteria implies that the voltage levels and relative length of parallel cable runs will not produce unacceptable level of electromagnetic interferences (EMI). Specific installations can be evaluated for spacial requirements on a case by case basis and i provide alternate engineering solutions. The use of additional shielding materials reduce the noise level equivalent to the level resulting from the minimum of 2 feet seperation requirements. This evaluation determines that there is no impact to plant safety as a result of providing alternate separation techniques for NIS components.

l l

I i

i

, Attachment 1 to TXX-99182 TU El:ctric Page 18 of 85 Unit: NN2 Evaluation Number SE-97-055 Revision 0 Activity

Title:

Service Water intake Structure Chemical Injection Lines Description of Change (s):

In order to enhance the ability to deliver chemicals to each service water train, new lines for the introduction of chemicals into the Service Water intake Structure (SWIS) will be added. Chlorine / Bromine and corrosion inhibitor lines will be routed along the floor of the 796 elevation of the SWIS to the east side of each SW pump. The lines will drop down to the grating (Elevation 777'). The lines for two pumps will then be extended to the bottom of the pump bay thru a support structure to be installed at grating level. For the other two pumps the lines will terminate just below the normal water level. The Clamicide lines will be replaced with a new line above the 796' floor, passing through new holes, allowing three flexible lines to extend to the bottom of the SWIS intake bay to calm areas where clams tend to migrate. Also, a flow balancing valve will be added to the corrosion inhibitor line. Service Water pump seal leakoff lines will be rerouted to a new third hole in the floor. The increased line size will help prevent clogging.

Summary of Evaluation:

The relocation of the points of chemical injection into the SWIS is intended to improve the plant's ability to control fouling and corrosion of components served by the service water system. Also, changes to the system are intended to provide the ability to better regulate and repeat chemical injection flow rates to the desired locations. Clogging of this service water pump seal leakoff line should be greatly reduced by rerouting and 4 increasing the size of the lines. The ebility to monitor seal leakoff flow and easily clean the lines will also be improved. This change does not revise any existing regulatory commitments.

to TXX-99182 TU El:ctric Page 19 of 85 Unit: NN2 Evaluation Number SE-97-058 Revision 0 Activity

Title:

The temporary blocking open of Safeguards El. 810'-6" door, S1-29CX to facilitate implementation of door maintenance / repair Description of Change (s):

This activity involves the temporary blocking open of normally closed door S1-29CX which is located in the 810'-6" elevation of the Safeguards Building and separates corridor room 1-082 from Train A electrical switchgear room 1-083. This activity will require that normally closed door S1-29CX be blocked open to repair the doors flushbolt and astragal / cap assembly. The blocking open of this door will create a new flow path for various hazard types not previously evaluated.

Summary of Evaluation:

Consideration has been given for all potential failure modes regarding the breach of a barrier to various hazard types which include fire, security, tornado, ventilation, internally generated missiles, radiological, HELB, MELB, flooding and EQ. For barrier controls not covered under existing administrative controls, it has been determined that by implementing compensatory measures, no credible failure modes exist which could adversely affect systems, structures, or components resulting in the increase in the probability, severity, or consequences of any accident analyzed in the LBDs.

p..

l l Attachment 1 to TXX-99182 TU El:ctric l Page 20 of 85 Unit: NN2 1

Evaluation Number SE-97-060 Revision 0 l

Activity

Title:

Add isolation flange to an equalization valve on the personal airlock.

Description of Change (s): ,

The equalization valve on the Unit 1 personal airlock was modified to include a flange j to restore the isolation boundary between the inside of the personal airlock and the i Safeguards building. 1 Summary of Evaluation:

)

There were no credible potential failures from adding an additional isolation flanges to the equalization valve and continue using the personal airlock manually. No additional {

fire loading to the area, no excessive pipe stress that would significantly effect the  !

piping Seismically, new radiological events would not occur, mitigation of radiological events were unaffected, nor could new accidents or malfunctions be created by this modification.

1 i

a

' Attachment 1 to TXX-99182 TU El:ctric Page 21 of 85 Unit: NN2

' Evaluation Number SE-97-062 Revision 0 Activity

Title:

Steam Generator inspection Port installation for Unit 1

~ Description of Change (s):

Additional inspection ports will be installed in ths lower shell and stub barrel portion of each of the steam generators at Comanche Peak Unit 1. These inspection ports will facilitate inspection of the tubesheet and support plate regions to inspect for sludge or corrosion particles, and also to facilitate sludge lance cleaning and other maintenance activities. The inspection ports are 2.5 inches in diameter. The penetrations are closed with a gasketed closure using bolts. Companion holes in the wrapper are blocked with removable wrapper plugs.

Summary of Evaluation:

The cover plates and closure bolts are designed and constructed in accordance with the ASME Code. Stresses and fatigue usage in the penetrations and in the closure hardware are within the ASME Code allowable values. The pressure boundary of the steam generator is maintained. The modification does not change inspection i requirements, nor does it prevent inspections currently required. Design features and procedural precations minimize the possibility of loose parts. The integrity and performance of the steam generators are unaffeted. No other safety related equipment is affected.

i I

1 i

L

p 1

Attachment 1 to TXX-99182 TU El:ctric Page 22 of 85 Unit: NN2 1

Evaluation Number SE-97-063 Revision 0

, Activity

Title:

Removal of the Unit 1 and 2 Service Air Ccmpressors including the Associated Equipment Description of Change (s):

The no longer useable Service Air Compressors are removed from the EC Building, 1 778' elevation, room X-113, along with associated mechanical equipment, electrical control and power feeds, instrumentation, and civil supports and hangers. This SE also i evaluates changes to the Fire Protection Report.

Summary of Evaluation:

The Service Air Compressors are non-safety related, with no impact upon any safety function required by accident analysis. Verification of component removal and testing of connections removed from service will ensure a new failure mode is not created.

Changes to the Fire Protection Report indicate that the combustible loading is decreased as a result of the implementation of these activities.

l l

l l

F Attachment 1 to TXX-99182 TU El:ctric Page 23 of 85 Unit: NN2 f

Evaluation Number SE-97-064 Revision 0 Activity

Title:

DM 97-038 with LDCRs SA 97-097 & -098," Containment Hot Tool Room Relocation" Description of Change (s):

This modification provides a controlled area outside of the containment buildings for the issuance and return of tools used inside of the containments during refueling outages.

This modification is being implemented on both units. The tool room itself will be located in room 96 of the Safeguards Building at EL 832'. For Unit 1, the existing wire mesh cage in room I-096 will be utilized. For Unit 2, a wire mesh cage similar to the one for Unit 1 will be provided for this modification. The tools will be passed between rooms 96 and 95B by way of a pass window to be added in the partition wall. The wall in which the pass window is located will be provided with suitable compensatory measures to restore the Fire Barrier, Equipment Q Jalification (EQ) Barrier, and Negative Pressure Boundary. Security also uses the wall to control access to the containment. Compensatory shielding to be installed over the window opening during plant modes 1,2,3 and 4 were not equal to the 3 feet of concrete removed, and resulted in a change to the postulated operator doses reported in the FSAR.

Summary of Evaluation:

The relocation of the containment hot tool room to the Safeguard Building requires a penetration through a partition wall that serves as an EQ barrier, Fire barrier, Tornado Differential Pressure boundary, Negative Pressure Boundary, and during a brief time period pre-outage it is a Security barrier, and it is a post-LOCA radiation shield. The ,

design features of the modification were able to retain the full function of all of the  !

barriers and boundaries with the exception of the post-LOCA shielding. The addition of the pass window in the wall, coupled with refined analyses for the postulated dose, will J result in a slight increase to the personnel vital area access dose rates previously i reported in the FSAR but is below the dose limits specified in 10CFP50, Appendix A. )

GDC 19. In addition, the one year post-LOCA equipment qualificatiori dose results for  !

impacted equipment changed slightly but did not exceed the existing qualified dose.

l 1

l- Attachment 1 to TXX-99182 TU Elactric Page 24 of 85 Unit: NN2 Evaluation Number SE-97-065 Revision 1 l Activity

Title:

L <

. EVALUATION OF THE USE OF AN AVERAGE Tavg FUNCTION IN THE CPSES NSSS CONTROL SYSTEM Description of Change (s):

This activity is the replacement of the auctioneered high Tavg unit with an average Tavg unit. The output signal of the auctioneering/ averaging unit provides an input to the Reactor Coolant System, the Pressurizer Water level Control System, and the Steam Dump System. This activity is expected to have negligible effects on the operation of the Pressurizer Water Level Control System and the Steam Dump Control System, result in reduced stepping of the control rods when in the Reactor Control System is in the automatic mode of operation, and allow the plant to be operated at a l slightly higher temperature, consistent with the safe'- Wyses.

Summary of Evaluation:

For CPSES Unit 2, which has no significant loop to loop asymmetrics, the replacement of the auctioneering unit with an averaging unit is relatively transparent during normal operation. For CPSES Unit 1, the effects of the upper plenum flow anomaly cause continuous control rod position changes, when in the automatic mode of operation, due to the step changes in the one loop's (and auctioneered high) Tavg induced by the present and subsequent absence of the upper plenum flow anomaly. Because another loop Tavg is complementary to the affected loop Tavg, the m .Mge Tavg is relatively unatfected by the upper plenum flow anomaly. The use d au merage Tavg signal l

allows the bulk RCS temperature to be closer to the value assumed in the safety analysis. Even though the resulting temperature is higher than if the auctioneering unit ,

is used, the value remains within the assumptions of the accident analyses. All I relevant event acceptance criteria remain satisfied. The effects of failures in single l Tavg loops are different and result in different magnitudes of ensuing transients; however, all failure modes are within the bounds of the original failure analysis and within the baunds of the accident analyses. Because none of the safety analyses are adversely affected by the proposed activity, and the proposed activity does not result in  !

the reduction of any failure points, it is concluded that the margin of safety is unaffected by the proposed activity.

l l-

.~

J

p, j r

i

~

Attachment 1 to TXX-99182 TU Elactric Page 25 of 85 Unit: NN2 l Evaluation Number SE-97-068 Revision 0 -

Activity

Title:

l lPO REVISIONS TO PLACE PLANT WATER SOLID IN MODE 4 i

Description of Change (s):

Procedura revisions are planned to place the RCS in a water solid condition in MODE

4. This change is being made to reduce the time to cool down and add hydrogen

peroxide to the RCS. This change will allow the pressurizer to be taken water-solid l

while maintaining RCS temperature steady for crud layer decomposition. The result of placing the plant water-solid in MODE 4 will be less time required to cool down the l pressurizer since the differential temperature is smaller with the RCS at 325F vice the current method of RCS temperature at 180F. Additionally, SGs will still be pressurized and steaming in MODE 4 which would aid the operator in controlling temperature upon a loss of RHR. Outage critical path time of 6 to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would be gained since the current practice would require a separate hold to place the RCS in a water-solid condition.

i' Summary of Evaluation:

There are no licensing basis accidents affected and no new failure or failure mode is L introduced. The entry into water solid conditions in MODE 4 is currently allowed by the design and licensing (FSAR and Tech Spec) basis. The only change is to enter water .

solid conditions at a higher temperature where the system is less susceptible to failure.

L Based on Generic Letter 90-06, minimizing the time in MODE 5 and 6 water solid l conditions by going water solid in MODE 4 is safer, Therefore, the margin of safety is I

not reduced and the change is not an unreviewed safety question. i f

l

)

l l

j l i l

s L

Attachment 1 to TXX-99182 TU Elsctric Page 26 of 85 Unit: NN2 Evaluation ' Number SE-97-070 Revision 0 Activity Title!

Replacement of Instrument Air Compressor CP2-C! CACO-01 & Instrument Air Dryer CP2-CIDYlA-01 Description of Change (s):

This activity: 1. Replaces the existing reciprocating instrument air compressor (CP2-CICACO-01) with a higher capacity, more efficient Atlas Copco rotary type compressor.

2.~ Replaces existing Kemp dryer skid (CP2-CIDYlA-01) with a higher capacity VAN AIR model. 3. Makes other Instrument Air enhancements as follows: Addition of new air flow meters to discharge of dryer 2-01 and 2-02, addition of solenoid valves to CCW lines for compressors 2-01,2-02, and X-02, addition of "i.EAD - BACKUP" circuitry for compressors 2-01 and 2-02 to automate configuration changes and removal of unused Carbon Monoxide monitors.

Summary of Evaluation:

The safety evaluation concludes that the installation of the larger capacity, more efficient compressor and dryer as well as the other system improvements will' enhance the operation and reliability of the Unit 2 instrument air system. Regulatory commitments are unchanged by this modification. The larger compressor will impose a slightly larger load on the Class 1E electrical system during normal operations and the Emergency Diesel Generator during a loss of offsite power load sequence. The load increase is analyzed in electrical system calculations and EDG loading calculations and is found to be acceptable..

l f

((

l i

Attachment 1 to TXX-99182 TU El:ctric Page 27 of 85 Unit: NN2 Evaluation Number SE-97-072 Revision 0 Activity

Title:

DM 97-035, Unit 2, Turbine Building Ventilation System Modification Description of Change (s):

The Unit 2 Turbine Building Ventilation System is modified to improve cooling and ventilation in Heater Drain Pump and Condensate Pump areas. Two motor operated centrifugal fans will be installed outdoors to bring outside air, through new ductwork (complete with dampers), to the Heater Drain pump pit area, located at El. 755' in the Turbine Building. These new fan motors will be fed from existing 480 V MCCs. i Additionally, a new branch extension duct will be added to an existing supply duct to deliver air down to the Condensate Pump area. The power for these fans are supplied from existing 480 V MCCs.  ;

l Summary of Evaluation:  :

The modification will result in improved cooling and ventilation effects in the Heater  !

Drain Pump and Condensate Pump areas. All systems involved in this modification are l not required for safety, have no protective functions and will not impair the ability of a protection systems to function. There is no unreviewed safety question. I i

l l

l l

Attachment 1 to TXX-99182 TU Elactric

. Page 28 of 85 Unit: NN2 Evaluation Number SE-97-082 Revision 0 Activity

Title:

MANOMETER EFFECTS AND RELIABILITY ISSUEG RELATED TO UNIT 1 HEATER

' DRAIN SYSTEM Description of Change (s):

The Unit 1 Heater Drains System is modified to improve system reliability and to eliminate manometer effects as experienced in the Heater Drain Tanks (HDTs) during transients.- HDT 01 is to receive normal drains from MSR Shell Drain Tanks, MSR

. Separator Drain Tanks and SG Biwodown flow. HDT 02 is to receive normal drains from Heaters 2 A/B and Heaters 3 NB. An 18" vapor spaces equalizing header and a 30" liquid spaces equalizing header are added between HDTs 01 and 02. A 24" nozzle check valve is added in the alternate drain line from the HDTs. The check valve is provided with a 2" bypass line with isolation valve and orifice plate. The HD Pumps will take suction only from HDT 02. The HD Pumps discharge control valve 1-LV-2592 is upsized from 16" to 20", as it will improve system response during various transients.

All Instruments with control function are located on HDT 02. Only level guage and high tank level alarm instrument will remain in HDT 01. Two 8" vent control valves are added on the vent lines fromt he HDTs to Heaters 3A and 3B, one on each vent line to the heater and to be interlocked with the extraction steam valve to the same heater.

The vent control valve opens after the associated extraction steam valve is opened, and closes when the extraction steam valve is closed. Both vent control valves are designed to fail in the open position, in order to protect the HDTs from overpressurization.

Summary of Evaluation:

~ The modifications will improve system reliability and eliminate HDTs manometer effects j in the Heater Drains System. All the systems involved in the modification are not i required for safety, have no protective functions and can not impair the ability of  !

protection systems to function. The only accidents in Chapter 15 that could be impacted by the SSCs associated with this proposed activity are those described in Chapter 15.1, " Increase in Heat Removal by the Secondary System" and Chapter 15.2,

" Decrease in Heat Removal by the secondary Systems". The probability of occurrence of these accidents is expected to decrease due to this activity. There is no unreviewed safety question.

Attachment 1 to TXX-99182 TU El:ctric Page 29 of 85 Unit: NN2 Evaluation Number SE-97-083 Revision 0 Activity

Title:

Steam Generator 1 Shell Penetration Description of Change (s):

A foreign object was found on the hot leg side on top of support plate "L"in steam generator 1 of Unit 2. The object was located on the periphery of the tube bundle next to tubes R49C53 and R49C54. The object wore into these two tubes; one to approximately 70% depth. A video probe inspection of the part was performed, however, retrieval of the object was not considered feasible from the existing 2.5 inch Access Port #1, which is located approximately 90 degrees away from the foreign object. An inspection port nominally 2.5 inches in diameter was installed in steam generator TCX-RCPCSG-01 to facilitate removal of this object.

Summary of Evaluation:

The steam generator shell penetration and closure hardware are designed, analyzed and constructed in accordance with the ASME Code. Stresses and fatigue usage in the shell penetration and in the closure hardware are within the ASME Code allowable values. The pressure boundary of the steam generators is maintained. The modification does not change inspection requirements, nor does it prevent inspections currently required. Design features and procedural precautions minimize the possibility of loose parts. The integrity and performance of the steam generators are unaffected.

No other safety related equipment is affected.

l i

l l

Attachment 1 to TXX-99182 TU Elsctric L Page 30 of 85 Unit: NN2 L

l Evaluation Number SE-97-089 l Revision 0 l

l Activity

Title:

L Update the FSAR to reflect that the Refueling Cavity Skimmer Systems are no longer used. (LDCR-SA-97-158)

! Description of Change (s):

This activity deletes references to the Refueling Cavity Skimmer Systems from the FSAR and reflects that the equipment is no longer used. Future plans call for

, abandoning and removing selected equipment from the plant but there is no physical l change to the plant resulting from this activity. Start up testing of the Unit 2 system l was deferred when Unit 2 was licensed. A commitment was made to test the system when the cavity was flooded at the first refueling outage. The test and commitment were deferred and remain open. The test is no longer necessary because the system will not be used. Upon completion of the FSAR change commitment 26325 may be deleted.

l l Summary of Evaluation:

The systems are part of the cleanup portion of the Spent Fuel Pool Cooling and Cleanup System. The systems are non-safety related and were orignially intended to l

be operated only during refueling outages to assist in the cleanup of the water in the Refueling Cavities. This cleanup function is currently performed by the Spent Fuel Pool l Purification pumps, skimmer, and demineralizer. Temporary submersible filtration units may be used to assist in the cleanup. No physical changes are made to the plant i under this current activity. The portions of the systems that penetrate containment are l not affected by this change. This change introduces no new failure modes for the plant or any plant equipment or systems.

l I

e

Attachment 1 to TXX-99182 TU El ctric Page 31 of 85 Unit: NN2 Evaluation Number SE-98-001 Revision 0 Activity

Title:

SGTR OVERFILL SCENARIO SINGLE ACTIVE FAILURE SCENARIO, REVISE BASES FOR TS 3/4.7.1.7 TO REFLECT SINGLE ACTIVE FAILURE SCENARIO Description of Change (s):

The proposed activity is the revision, in the FSAR, of the limiting single active failure for the steam generator tube rupture analysis - overfill scenario. The formerly assumed failure of a feedwater control valve in its "as-is" position is replaced by the assumed failure of a vital de bus, which, when considered with a loss of offsite power, results in the loss of control power to 2 steam generator atmospheric relief valves. This assumed failure extends the time required to cool the RCS to the point that the RCS can be depressurized, thereby terminating the break flow.

Summary of Evaluation:

The analysis of the steam generatore tube rupture (SGTR) event is analyzed to demonstrate that the radiological consequences are within the guidelines of 10 CFR 100. The limiting single active failure is the failure of the atmospheric relief valve on the ruptured SG to close after it opens following the turbine trip. However, the event is first analyzed to ensure that no single failure will result in the flooding of the main steam lines (SG overfill) and water relief through the main steam safety valves. Such a release could be more severe with respect to the radiological consequences. For the SG overfill scenario, a new limiting failure, the failure of a vital de bus, has been identified. When considered with a loss of offsite power, this failure results in the loss of control power to 2 steam generator atmospheric relief valves. This assumed failure extends the time required to cool the RCS to the point that the RCS can be depressurized, thereby terminating the break flow. However, the analysis of this scenario has confirmed that the ruptured steam generator does not result in more severe radiological consequences than the assumed failure of the ARV on the affected steam generator to close. Therefore, the radiological consequences of this event are unchanged and the proposed activity does not represent an unreviewed safety question.

l l

L l to TXX-99182 TU El:ctric Page 32 of 85 Unit: NN2 Evaluation Number SE-98-005 Revision 0 Activity

Title:

LDCR FP-009: Revise CPSES Fire Protection Report (FPR) to consider Thermo-Lag fire barrier materials as combustible.

Description of Change (s):

Revise FPR Section 1, "Introductio," Section 11," Fire Hazards Analysis Report" (FSAR) and Appendix C " Deviations" in Section V " Appendices" to consider Therno-Lag fire barrier materials and combustible. Also, revise Section 11 and Appendix C to provide (new) combustible loading classifications for plant fire areas / zones, in liew of existing '

Btu /sq. ft. values and corresponding postulated fire durations (currently expressed in minutes).

Summary of Evaluation:

Thermo-Lag fire barriers are used at CPSES to satisify FSAR Section 9.5. (FPR Section 11.4.5) requirements for separation of cables or equipment of redundant sets of systems required to achieve required to achieve and maintain hot standby conditions in the event of a fire. TU Electric has performed full scale fire testing to demonstrate i that installed Thermo-Lag fire barriers are capable of providing the required one hour fire endurance rating. However, as described by IN 92-82, the NRC staff has determined that Thermo-Lag materials shoulld be classified and evaluated as  !

combustibile. Specifically, while properly constructed Thermo-Lag barriers adequately l mitigate excessive thermal transfer from exposure fire conditions to enclosed cables i and raceways, the materialitself contributes added heat in the presence of an external heat sorurce of sufficient temperature to cause it to sublime and ignite. Therefore, since Thrmo-Lag materials contribute to the overall combustible loading content of a given fire area or zone, the effects of the additional heat of combustion of installed Thermo-Lag configurations have been include and assessed in the appropiate FPR sections and supporting fire protection program calculations and analyses.

l l

to TXX-99182 TU Electric Page 33 of 85 Unit: NN2 Evaluation Number SE-98-007 Revision 0 l l

Activity

Title:

)

DM 98-26 R0, Fuel Building Bridge Crane Hoist / Trolley updated to provide variable speed for hoist and trolley motions. LDCR SA 98-7 Description of Change (s): )

DM 98-26 Revision 0 is a design modification installing a tractor drive assembly to the j trolley motion, digital variable-frequency drive units to control speeds for the tractor

]

' drive assembly drive unit for the trolley and the up/down hoist motion, and modifies the -

pushbutton station to allow slower, variable speed selection to hoist and trolley motions, permitting greater operator control of the motions of the bridge crane boist in 1 order to address a contributing factor to the handling of the damaged Unit 2 fuel element during the third refueling outage for Unit 2. LDCR SA-98-07 makes changes to FSAR Section 9.1.4 describing effects of the hardware changes.

Summary of Evaluation:

Interlocks prevent simultaneous movement of either the bridge and trolley, the bridge and hoist, or the hoist and trolley while handling a fuel assembly. This is more conservative since there is no interlock with the existing chain-driven trolley. Therefore, i this modification will not result in an increase of fuel assembly speed higher than the 40 feet per minute as previously analyzed. The weight added to the Fuel Building Bridge Crane assembly has been considered and the stresses remain within the allowable limits. The circuit breaker remains adequate for this application and the new cable meets FSAR requirements.

)

1 I

j

l l

Attachment 1 to TXX-99182 TU El:ctric

- Page 34 of 85 Unit: NN2 Evaluation Number SE-98-008 Revision 0 Activity

Title:

INSTALL " BALL FLOATS" IN FLOOR DRAINS IN THE FEEDWATER & MAIN STEAM PENETRATION ROOMS (ROOM 1,2-100A,1-110,2-108)

Description of Change (s):

This activity involves installation of " Ball Floats" in the floor drains in the Feedwater and Main Steam penetration rooms. Backwater valves, if any, previously installed will be removed to accommodate installation of the Ball Floats. The Ball Floats will be included in the Preventative Maintenance program. In modes 1 through 4, a Main steam line break in this area would create the potential for worst case environmental conditions with temperature up to approximately 400 deg. F. humidity 100%, and differential pressure 17 psi with respect to other rooms in the Safeguards Building.

Due to interconnection of these drains with other rooms of Safeguards Building, propagation of the harsh environment from the FW/MS penetration rooms could impair the function of safety related equipment in other rooms of the Safeguards Building.

The " Ball Floats" will keep the drains covered, as in the normal condition, to prevent steam from propagating to the other rooms and impairing the function of the safety related equipment. In the event of water leakage in the rooms, flow of water into the drain cavity will cause the ball to lift from the seat due to boyancy allowing the water to drain thru the floor drains. The Ball Float device has been sized and tested to verify the functionality. I Summary of Evaluation:

Consideration has been given for all potential failure modes for this activity, and it has been determined that there are no credible failure modes that could adversely affect systems, structures, or components resulting in an increase in the probablity, severity, or consequences of any accident analyzed in LBDs. This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an upset, emergency, or faulted condition.

l l

i i

to TXX-99182 TU El:ctric Page 35 of 85 Unit: NN2 Evaluation Number SE-98-010 Revision 0 Activity

Title:

FSAR CLARIFICATION ON HYDROGEN MIXING IN CONTAINMENT i Description of Change (s):

Modify FSAR Section 6.2.5 to clarify that passive mechanisms are capable of ensuring adequate mixing of hydrogen in containment after a LOCA. As currently written, FSAR Section 6.2.5 places emphasis on the function of the containment spray system to ensure mixing of hydrogen in containment after a LOCA. While the current wording stresses the conclusiveness with which research has shown that containment spray can do this, it should provide additional clarification that solutions in containment spray can produce hydrogen and that other passive mechanisms alone are also effective for mixing hydrogen. The purpose of the change is to clarify that using containment spray to ensure adequte hydrogen mixing post LOCA, while effective, should be procedurally managed and existing passive mechanisms should be fully credited.

Summary of Evaluation:

The FSAR, Section 6.2.5.3.2, already identifies that a stack effect is capable of ensuring that hydrogen concentrations within subcompartments are adequately mixed to ensure that the hydrogen stratification does not occur. Other passive mechanisms, such as the thermal /bouyancy plume, along with the stack effect, are capable of ensuring adequate mixing in containment for all analyzed LOCA accidents, even in the absence of containment spray. Spray actuation is a sufficient, but not necessary, condition to mix the atmosphere, because of the stack effect alone. The effectiveness of the thermal /bouyancy plume natural circulation mechanism, provides additional i l

reassurance that the atmosphere inside containment is adequately mixed.

Containment spray is effective for hydrogen mixing as stated in the FSAR. However, its use should be procedurally limited to ensure that mixing is accomplished whenever necessary and hydrogen production inside containment is minimized. Procedures provide for post LOCA monitoring of containment hydrogen and operation of containment spray for hydrogen mixing is accomplished on an "as needed" basis.

Therefore, FSAR Section 6.2.5 is clarified that these passive mechanisms are capable of providing adequate mixing of hydrogen in containment after a LOCA and '

procedurally allowing reactor operators to use containment spray 'as needed' for i hydrogen mixing.

Attachment 1 to TXX-99182 TU El:ctric p Page 36 of 85 Unit: NN2 Evaluation Number SE-98-011 l Revision 0

' Activity

Title:

ENF. DISCRETION TO CONTINUE OPERATION W/O HAVING PERFORMED A RQD SURVEILLANCE TO DEMONSTRATE LOAD SHED ON UNDERVOLTAGE Description of Change (s):

Tech Spec Surveillance for EDG load shedding (4.8.1.2.f.4 and 4.8.1.1.2.f.6) has not been completely performed. ONE FORM 98-182 was generated and ONE-QTE 182 determined that the EDG would carry the additionalload of bus XEB4-3. The Tech Spec. Surveillance issue was not addressed in the QTE. This evaluation shall determine if it is acceptable to operate the plant until the next refueling outage on both units prior to testing the load shed of this bus.

l Summary of Evaluation:

The purpose of the surveillance is to demonstrate by test that emergency bus loads are properly removed prior to the engine breaker closure for LOOP and LOOP +Si signals.

XEB4-3 is supposed to load shed to avoid this unnecessary loading onto the EDG.

Evaluation of the bus load and EDG loading shows that the maximum possible loading does not prevent the EDG from carrying the load.

I i

l l

l l

l I

I

Attachment 1 to TXX-99182 TU El2ctric Page 37 of 85 Unit: NN2 Evaluation Number SE-98-012 Revision 0 Activity

Title:

LDCR SA-98-014. REVISE FSAR TO CHANGE CHANNEL CAllBRATION FREQUENCY OF NON TS, NON SAFETY, AND NON ODCM RAD. MONITORS Description of Change (s):

This activity revises FSAR Sections 11.5 and 12.3 which currently limit the Channel Calibration (CCAL) for all CPSES process and area radiaiton monitors to a frequency of 18 months or less. The activity modifies the FSAR description to remove the 18 month limitation for the Non-Technical Specification, Non-Safety related, and Non-ODCM radiaton monitors.

Summary of Eva!uation:

This activity allows the CCAL for the Non-Technical Specification, Non-Safety related, and Non-ODCM radiation monitors to be performed , in lieu of every 18 months, at a frequency established in accordance with the CPSES Preventive Maintenace Program based on monitor performance and function. The subject radiaiton monitors do not control nor are they required to support any CPSES programs to monitor effluent releases to the environment. Historical calibration data, regulatory guidance documents, and industry calibration practices were reviewed. It was concluded that an 18 month CCAL frequency limitation is not warranted or required for these monitors.

Historical "as found" CCAL data for the subject monitors over periods up to 30-36 months showed a high degree of confidence that a given monitor would sustain a satisfactory (within tolerence) calibration. This activity does not impact any safety related, Technical Specification or ODCM required radiation monitors; hence it does not involve an unreviewed saftey question.

i l

I i

I 4

Attachment 1 to TXX-99182 TU El:ctric Page 38 of 85 Unit: NN2 Evaluation Number SE-98-013 Revision 0

. Activity

Title:

UNIT 1 CONTAINMENT PERSONNEL AIRLOCK HYDRAULIC TUBING THERMAL OVERPRESSURE PROTECTION (GL 96-06)

Description of Change (s):

This activity adds thermal overpressure protection to isolable portions of the hydraulic system of the Unit 1 containment building personnel airlock. This modification is in response to a review performed to address the concerns noted in Generic Letter 96-06.

Six potentially isolable tubing sections within the hydraulic system of the airlock have

, been identified as requiring thermal overpessure protection in accordance with design and licensing basis requirements. This activity added relief valves to these tubing sections.

Summary of Evaluation:

This evaluation assess the adequacy of design changes proposed to provide thermal overpressure protection for isolable sections of the hydraulic system of Unit 1 I

personnel airlock. The evaluation concludes that addition of the relief valves ensures the personnel airlock hydraulic system is capable of performing its intended safety function and that any thermally induced over pressure will be safety relieved thereby ensuring the integrity of the containment pressure boundary provided by these lines.

l l

p b

Attachment 1 to TXX-99182 TU Electric Page 39 of 85' Unit: NN2 Evaluation Number SE-98-014

, Revision 0 l

Activity

Title:

ALTERNATE METHOD OF COMPLIANCE WITH TECHNICAL SPECIFICATIONS I SURVEILLANCE REQUIREMENTS Description of Change (s):

Technical Specification Instrument Surveillance Requirements 4.3.2.1 requires that

each ESFAS undervoltage circuit be demonstrated at regular intervals. It has been determined that a timer contact in the trip circuit of the preferred and alternate offsite power source breakers has not been previously verified to be closed as required.

Table 4.3-2 requires that the plant be in " COLD SHUTDOWN" to perform the terst of these contacts hower, CPSES has determined that they can be tested safely with the unit in Mode 1. SE 98-00014 evaluates the impact on safety of waiving the cold shutdown requirement for this test.

1 l Summary of Evaluation:

l The evaluation assesses the impact of crediting certain tests performed at power l l versus the same test performed when the plant is in cold shutdown. The evaluation l . determines that there is no impact to safety by performing a portion of the related Trip i Actuation Device Operational Test (TADOT) at power and that credit may be taken for the "at Power" portion of the testing to partially satisfy the surveillance of TS 4.3.2.1, .

Table 4.3-2, Channel Functional Unit 8d, e and f. Reference TXX-98062, request for enforcement discretion. 1 1

i l

i

L

! Attachment 1 to TXX-99182 TU Elzetric Page 40 of 85 Unit: NN2

. Evaluation Number SE-98-015 Revision 0 Activity

Title:

EVALUATE THE EFFECTS OF TURBINE EXHAUST HOOD SPRAYS ON LP TURBINE BLADE VIBRATION Description of Change (s):

Recent refueling outages have revealed cracking of last stage low pressure (LP) blading on the Unit 2 main turbine. The installation of a blade vibration monitoring system indicates that the blades are experiencing undue stress when condenser backpressure rises during warmer periods of the year. This activity described herein simulates those conditions which are normally seen during the summer months. As the temperature of the cooling reservoir rises, there results in increased backpressure at the turbine LP exhaust. By reducing cooling water flow to the condenser, and reducing vacuum pump suction flow, the shell side pressure in the condenser wi;l rise. This will be done in a controlled fashion to observe its effects on turbine blade vibration. When

, a predetermined vibration level is attained, the exhaust hood sprays will be placed in service. It is anticipated that the use of hood sprays could alter the flow regmine in the exhaust annulus to change flow pulsations, if a favorable effect is observed, then condenser vacuum will be further reduced until one of several termination criteria has been achieved. If the use of sprays is observed to increase blade vibration levels, the experiment will immediately be terminated, and the plant restored to normal operating condition.

Summary of Evaluation:

This activity is being performed in the secondary plant, and is currently bounded by Chapter 15 analyses for a turbine trip; this activity will not result in a new or unanlyzed event. The probability of experiencing a turbine trip will not be increased by performance of this activity, as the activity will be conducted within tightly controlled parameters, with rate and endpoint limits established to ensure no manual or automatic trip occurs, and no equipment limits are exceeded. The margin of safety is not l

impacted by this experiment, as the equipment involved is not governed by Technical Specifications. Performance of this activity does not impact or change any commitment to the NRC.

l t

L..

Attachment 1 to TXX 99182 TU Elactric

' Page 41 of 85 Unit: NN2 t

Evaluation Number SE-98-016 Revision 0 Activity

Title:

PCN ABN 907-R8-02, " ACTS OF NATURE"

. Description of Change (s):

The activity will defeat the OT N-16 runbacks during periods of severe weather to preclude challenges to the plant (e.g., spurious turbine runbacks) until such time as the Interference from lightening can be eliminated or otherwise mitigated. The activity is compensatory actions taken in accordance with the FSAR Section 13.5, Table 13.5-3, 4

Acts of Nature. The expected effects are improved plant reliability with minimal impact on the ability of the control system to mitigate overpower events that otherwise would be terminated via OT N-16 runback. Removal / reinstallation of the fuses will be procedurally controlled and triggered by the entry into severe weather conditions when lightening is expected. Adequate verification steps are provided to ensure the proper fuses are removed and replaced upon cessation of the period of vulnerability.

Summary of Evaluation:

No accident mitigation is affected. No new failure modes are introduced. The Tech

! Specs are not affected and the margin of safety as defined in the basis of the Tech Specs is not reduced.

1 i

1 l

Attachment 1 to TXX-99182 TU Electric l Page 42 of 85 Unit: NN2 t

Evaluation Number SE-98-017 Revision 0 Activity

Title:

ALTERNATE METHOD OF COMPLIANCE WITH TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS Description of Change (s):

Technical Specification Surveillance Requirements,4.8.1.1.2f.4)b) and 4.8.1.1.2f.6)b) require in part the verification of operability of the auto load sequencing equipment for i the Emergency Diesel Generators. It has been determined that certain contacts in the loading circuits have not been previously verified operable au required. Surveillance Requirement 4.1.1.2f requires the plant be " SHUTDOWN" to perform this test however, CPSES has determined that they can be tested safely with the unit in Mode 1. SE 98-00017 evaluates the impact on safety of waiving the shutdown requirement for this test.

Summary of Evaluation:

The evaluation assesses the impact of crediting certain tests performed at power la Mode 1 versus the same tes,t performed when the plant is shutdown. The evaluation I determines that there is no impact to safety by performing a portion of the required l surveillance tests with the plant in Mode 1 and that credit may taken for the "at power" portion of the testing to partially satisfy the surveillance requirements of TS 4.8.1,1.2f.

Reference TXX-98074, request for enforcement discretion.

l l

I l

Attachment 1 to TXX-99182 TU El:ctric

l. Page 43 of 85 Unit: NN2 Evaluation Number SE-98-018 Revision 0 Activity

Title:

ALTERNATE METHOD OF COMPLIANCE WITH TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS Description of Change (s):

SE 98-00018 evaluates the impact on safety of: 1. Waiving the requirements for performing a portion of surveillance 4.8.1.1.2f in " SHUTDOWN" conditions and,2.

Extending the allowable time limit of 4.0.3 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Technical Specification Surveillance Requirements 4.8.1.1.2f.4)a) and 4.8.1.1.2f.6)a) require, in part, the verification of load shedding from the emergency buses following a loss of offsite power l or a loss of offsite power coincident with a safety injection actuation signal. It has been determined that certain contacts in the load shedding circuits have not been previously verified operable as required. Surveillance Requirement 4.8.1.1.2f requires that the pitat be " SHUTDOWN" to perform this test however, CPSES has dettsrmined that appropriate surveillance testing can be safely performed with the unit operating in Mode 1. However, the appropriate testing required to fully satisfy TS 4.8.1.1.2f will require an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> beyond the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit of TS 4.0.3.

Summary of Evaluation:

This evaluation assesses the insact of crediting certain tests performed at Mode 1 versus the same test performed .vhen the plant is shutdown and extending the TS 4.0.3 allowable limit of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to e '.otal 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The evaluation determines that there is no impact to safety by perforining a portion of the required surveillance tests with the plant in Mode 1, within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of identificaaon and that credit may be taken for the "at power" portion of the testing to partially satisfy the surveillance requirements of TS 4.8.1.1.2f. Reference TXX-98077, request for enforcement discretion.

i to TXX-99182 TU El:etric Page.44 of 85- Unit: NN2 4

Evaluation Number SE-98-019 Revision 0 Activity

Title:

CPSES-1, CYCLE 7 CORE CONFIGURATION Description of Change (s):

During the next refueling outage for CPSES Unit 1 (1RF06), prior to operation of Cycle 7, seventy-two fresh Region 9A and twenty fresh Region 9B fuel assemblies and one once-burned Region 3 assembly will replace eighty Region 7 assemblies, twelve Region 6 assemblies, and one Region 3 assembly. For the CPSES Unit 1, Cycle 7 core configuration,92 fresh fuel assemblies manufactured by Siemens Power

. Corporation and 1 partially bumed standard fuel assembly manufactured by Westinghouse.

Summary of Evaluation: '

This mixed core configuration has been evaluated for mechanical and thermal- l hydraulic compatibility between the Siemens Power Corporation and Westinghouse fuel assemblies. All applicable design criteria were determined to be satisfied. The neutronic characteristics of the Cycle 7 core configuration have been evaluated for their )

effect on the accident analyses. In all cases, it was determined that the applicable event acceptance criteria are satisfied. Because all mechanical design criteria continue to be satisfied, there is no reduction in any failure point introduced by the Cycle 7 core configuration. All acceptance criteria of the accident analyses continue to be satisfied; therefore, there is no increase in the consequences of any accident previously .

anaylzed. . Based on the foregoing, it is concluded that the Cycle 7 core cofiguration does not reduce any margin of safety as defined by the plant Technical Specifications; therefore, the proposed change does not involve an unreviewed safety question.

I I

l i

I

-)

Attachment 1 to TXX-99182 TU Elactric Page 45 of 85 Unit: NN2 Evaluation Number SE-98-020 Revision 0

' Activity

Title:

MANOMETER EFFECTS AND RELIABILITY ISSUES RELATED TO UNIT 2 HEATER DRAIN SYSTEM (DM 97-044/2RF04)  ;

Description of Change (s):

The Unit 2 Heater Drain System is modifed to improve system reliability and to eliminate manometer effects as experienced in the Heater Drain Tanks (HDTs) during transients. HDT 01 is to receive normal drains from MSR Shell Drain Tanks, MSR Separator Drain Tanks and SG Blowdown flow. HDT 02 is to receive normal drains from heaters 2 A/B and Heaters 3 A/B. An 18" vapor space equalizing header and a 30" liquid space equalizing header are added between HDTs 01 and 02. A 24" nozzle check valve is added in the attemate drain line from the HDTs. Tiie check valve is provided with a 2" bypass line with isolation valve and orifice plante. The HD Pumps will take suction only from HDT 02. The HD Pumps discharge control valve 2-LV-2592

. is upsized from 16" to 20", to improve system response during various transients. All instruments with control functions are located on HDT 02. Only a level gauge, pressue transmitter, and high tank level alarm instrument will remain in HDT 01. Two 8" vent control valves are added on the vent lines from the HDTs to Heaters 3A and 3B, one on each vent line to the heater and to be interlocked with the extraction steam valve to the same heater. The vent control valve opens after the associated extraction steam valve is opened, and closes when the extraction steam valve is closed, Both vent control valves are designed to fail in the open position, in order to protect the HDTs from overpressurization. The HD pump recirculation valves are relocated near the HD pump discharge header The two recirculation lines are combined into one 16" header after the recirculation control valves. This 16" recirculation header discharges flow into the 30" HDT equalizing line. A new sampling point with isolation valve, is added on the 30" HDT equalizing line to monitor water chemistry from HDT 01.

Summary of Evaluation: 1 The modifications will improve system reliability and eliminate HDT manometer effects in the Heater Drain System. None of the Systems involved in the modifications are required for safety, have protective functions and/or could impair the ability of protection systems to function. The only accidents in Chapter 15 that could be impacted by the SSCs associated with this proposed activity are those described in

- Chapter 15.1, " Increase in Heat Removal by the Secondary System" and Chapter 15.2,  ;

" Decrease in Heat Removal by the Secondary Systems". The probabihty of occurrence of these accidents is expected to decrease due to this activity. There is no unreviewed safety question.

l.

l v

f

, Attachment 1 to TXX-99182 TU Elsctric l : Page 46 of 85 Unit: NN2 Evaluation Number SE-98-021 Revision 0 l

Activity

Title:

j DM 97-034, UNIT 1, TURBINE BUILDING VENTILATION SYSTEM MODIFICATION Description of Change (s):

i Additional ventilation is being added to the area where the Heater Drain Pumps (HDP) l are located. Currently there is very little ventilation provided in the area of the pumps.

This modification will install two centrifugal fans and ductwork to supply outside air to this area. The fans will be sized to supply air to the pump area, disperse heat from the area and increase the circulation in the area. In addition, there will be new branch ductwork added to an existing main duct to supply outside air directly to the L Condensate Pumps, located in the vicinity of the Heater Drain Pumps. Since these l pumps are located in the basement of the Turbine Building, the additional air supplied l

will force the warmer air to be exhausted via the existing " oversized" roof ventilators providing better air circulation in the area. None of these improvements will create a new test or experiment or an unanalyzed condition in the plant. The HVAC system in i

the Turbine Building is all non-safety and these improvements will be an overall l enhancement to the existing condition in the Turbine Building. Two new 30 HP 460 V motor driven centrifugal fans, CP1-VAFNCB-10 and -11 are added to supply outside cooling air to HDP the area. The power for these fan motors are fed from 480V MCCs 1B3-1 and 183-3.. Existing fire protection lines will be rerouted to avoid interferences with new ductwork. The suppression system piping relocation maintains the effectiveness and coverage of the existing system. The amount of combustibles added to the fire zones is not a significant increase to the fire loading.

Summary of Evaluation:

l The modification will result in improved cooling and ventilation effects in the Heater Drain Pump and Condensate Pump areas. All systems involved in this modification are not required for safety, have no protective functions and will not impair the ability of a protection systems to function.. There is no unreviewed safety question.

l l

1 e

7 i

l Attachment 1 to TXX-99182 TU El:ctric

! Page 47 of 85 Unit: NN2 i-Evaluation Number SE-98-022 Revision 0 Activity

Title:

ALTERNATE METHOD OF COMPLIANCE WITH TECHNIC AL SPECIFICATION REQUIREMENTS, ENFORCEMENT DISCRETION TXX-98091 Description of Change (s):

This evaluation is performed to determine the impact on safety to allowing Unit 2 to continue to operate and Unit 1 to continue with refueling activities without having performed portions of Surveillance Requirement (SR) 4.8.1.1.2f.4)a),4.8.1.1.2f.4)b),

4.8.1.1.2f.6)a),4.8.1.1.2f.6)b),4.8.1.1.2f.6)c) and 4.8.1.2 and extending the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit of surveillance requirement (S.R.) 4.0.3 to 15 days. This enforcement discretion to allow CPSES Unit 2 to continue to operate and to allow the refueling outage activities for CPSES Unit 1 to continue in accordance with the guidance of SR 4.0.3 for an additional 14 days beyond the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowable. Without the requested enforcement l discretion, compliance with CPSES SR 4.0.3 would require that 4.8.1.1.2f.4)a), j 4.8.1.1.2f.4)b),4.8.1.1.2f.6)a),4.8.1.1.2f.6)b),4.8.1.1.2f.6)c) and 4.8.1.2, be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following identification that the SR was incomplete or perform the applicable ACTIONS. Without the requested enforcement discretion, compliance with CPSES LCO 3.8.1.1 and LCO 3.8.1.2 would require a reactor shutdown for Unit 2 and significant disruption in the in progress Unit i refueling outage.

Summary of Evaluation:

This evaluation asses the impact of extending the T.S. 4.0.3 time limit from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to i 15 days. This evaluation determine that there is no impact to safety by delaying the j missed surveillance test.

I i

i l

' Attachment 1 to TXX-99182 TU Elsctric Page 48 of 85 Unit: NN2 Evaluation Number SE-98-023 Revision 0

' Activity

Title:

ADDITION OF TIME DELAY TO INITIATION OF N16 OVERTEMPERATURE  !

TURBINE RUNBACK FUNCTION Description of Change (s): l This Safety Evaluation is applicable to similar modifications for both Units 1 and 2. Unit 1 and Unit 2 design modifications each replace an instantaneous relay which initiates turbine runback when an approach to the overtemperature reactor trip setpoint is sensed on two out of four channels. The replacement is a one-second time-delay installed in order to prevent turbine runbacks from momentary spikes in the overtemperature sensing loop caused by lightning strikes. This Safety Evaluation supports changes to FSAR Figure 7.2-1 Sheet 16 which depicts the functional diagram for the turbine runback circuitry.

Summary of Evaluation:

Time delays have bee 1 incorporated into the overtemperature N-16 reactor trip function to absorb the effects of lightning spikes. These features provide the same level of protection to the overtemperature turbine runback function. The overtemperature turbine runback is not a safety-related reactor protection system, is not credited in any safety analysis, and is not required for operation of the reactor trip system. Therefore, it is concluded that this activity does not comprise an unreviewed safety question.

3. -

Attachment 1 to TXX-99182 TU El:ctric Page 49 of 85 Unit: NN2 Evaluation Number SE-98-025 Revision 0 Activity

Title:

DEFERRAL OF UNT 2 TECHNICAL SPECIFICATION SURVEILLANCE ROMT SR

' TESTING, ENF, DISCRETION REQUEST, GL 96-01 Description of Change (s):

TS Surveillance Requirements,4.8.1.1.2f.4)a),4.8.1.1.2f.4)b),4.8.1.1.2f.6)a),

4.8.1.1.2f.6)b) and 4.8.1.1.2f.6)c) require in part, the verification of operability of the auto load sequencing equipment for the Emergency Diesel Generators. It has been determined that the performance of certain contacts in these circuits has not been previously verified, by documented test results, to be operable as required. Also, the associated Surveillance Requirements require the plant be " SHUTDOWN" to perform these tests however, CPSES has determined that selected tests can be performed safely with the unit in Mode 1. This activitiy evaluates the impact on safety of delaying certain Unit 2 TS required surveillances until the next outage of sufficient duration and taking credit for certain tests performed at power.

1 Summary of Evaluation:

The deferral of testing and crediting of "at power" testing for certain SR tests will not present a new failure mode for plant equipment or systems. The effect of test deferral on the ability of CPSES to operate or shutdown safely,is not discernable. The untested components have been evaluated and are expected to operate per design i based on objective evidence from a reasonable sample of tests performed recently on similar components in other applications in Unit 2, preoperational testing performed prior to Unit 2 commercial operation, recently completed tests performed on the same components on Unit 1 and from results of repeated successful surveillance tests performed over the life of the plant.

_.At-

r. --

' Attachment 1 to TXX-99182 TU Electric Page 50 of 85 Unit: NN2 l

Evaluation Number SE-98-027 Revision 0

' Activity

Title:

INCLUSION OF ELECTRIC HYDROGEN COMBINERS AS A LOAD ON DIESEL GENERATORS ON RESTORATION OF POWER Description of Change (s):

Electric hydrogen recombiners do not have a load shed feature. Thus, if they are ON when a loss of offsite power were to occur, the recombiners will be a load or ne diesel generator (DG) when the power is restored by the DG. Therefore, the reconoiners are considered a load on DG on restoration of power. Addition of this first step load to DG results in an accumulative load addition of 51KW for Blackout only loading condition. It does not result in a DG accumulative load change for LOCA coincident with Blackout loading condition, because this load is already considered as a post accident load for this condition. With the additional load, the DG load is still below the technical specification limit of 6300 KW. The increased load will have no adverse affect on DG's ability to perform its function and it will continue to deliver adequate power to its load.

Summary of Evaluation:

Electric hydrogen recombiners do not have a load shed feature. Thurs, if they are ON when a loss of offsite power is restored by the DG. Therefore, the recombiners are considred a load on DG on restoration of power. Addition of this first step load to DG results in an accumulative load addition of 51KW for Blackout only loading condiiton. It does not result in a DG accumulative load change for LOCA coincident with Blackout loading condition, because this load is already considered as a post accident load for this condition. With the additional load, the DG load is still below the technical specification limit of 6300 KW. The increased load will have no adverse affect on DG's ability to perform its function and it will continue to deliver adequate power to its load.

u i

to TXX-99182 TU El:ctric Page 51 of 85 Unit: NN2 Evaluation Number SE-98-028 Revision 0 Activity

Title:

UNITS 1 AND 2 CONDENSATE PUMPS INTERLOCK WITH CONDENSATE REJECT VALVE (DM97-020,2RF04/1RF07,LDCR-SA-98-049)

Description of Change (s):

This activity adds an interlock so that the condensate reject valve closes when both the condensate pumps trip. This is required to prevent over filling of the hot well from Condensate Storage Tank via the open reject valve and the open condensate recirculation valve.

Summary of Evaluation:

The safety evaluation concludes that the installation of this modification 97-020 will enhance the condensate system operation by eliminating Operation Work Around and reduce operator action during plant transient. This change is safe, it does not increase the risk to the public and does not create any unreviewed safety question.

l l

1 1

l j Attachment 1 to TXX-99182 TU El:ctric Page 52 of 85 Unit: NN2 Evaluation Number SE-98-029 Revision 0 Activity

Title:

DAMAGED FUEL RECOVERY AT CPSES j Description of Change (s):

An upper tie plate for damaged fuel assembly FF-63 will be reattached utilizing anchor i bolts installed in the guide tubes of FF-63. The assembly will then be lifted, decontaminated and packed for re-shipment to Siemens Power Corporation for uranium recovery and permanent disposal of the cage and fuel rod clad by Siemens

. Power Corporation.

Summary of Evaluation:

Re-attachment will be accomplished by qualified Siemens Power Corporation personnel, with coordination from TU Electric Reactor Engineering personnel, using expanding bolts placed in the assembly guide tubes. The installation and load testing of the expanding bolt connection was qualified in Siemens Power Corporation acceptance test. In this acceptance testing, the upper tie plate to guide tube connection withstood loads in excess of those credible for the fuel handling activities planned and resulted in a connection at least as strong, if not stronger, than the standard Siemens Power Corporation fuel assembly attachment mechanism. The fuel assembly is un-irradiated and when the upper tie plate is re-attached, all subsequent fuel handling activities are unchanged from normal new fuel handling. The new fuel handling grappling interface is unchanged by the upper tie plate reattachment technique. Fuel assembly FF-63 with the re-attached upper tie plate will not be used at Comanche Peak, but will be shipped to the Siemens Power Corporation fuel fabrication facility in Richland, Washington for uranium recovery. There are no plans to re-use any the components of FF-63 once the uranium pellets are removed.

1 l

Attachment 1 to TXX-99182 TU Elactric Page 53 of 85 - Unit: NN2 1

Evaluation Number SE-98-030 Revision 1 Activity

Title:

UNIT 2 STEAM GENERATOR ATMOSHPERIC RELIEF VALVE RETROFIT; DM 1 060, DCN-12210,REV.1 Description of Change (s):

This activity will retrofit the existing Unit 2 Steam Generator Atmospheric Relief Valves ,

(ARVs), utilizing CCI DRAG velocity control trim and new actuators. Steam Traps are replacing orifices in the drain piping, providing drainage from the drip pans and valve discharge piping. Isolation and bypass valves are being provided in the drain lines to allow on-line maintenance of the steam traps. A fire protection line is being rerouted to avoid an interference. I I

Summary of Evaluation:

The ARV retrofit will provide tighter valve shutoff, which will reduce steam loss and seat damage to the valves. The retrofit willimprove controllability and noise-induced vibration will be no greater than that experienced prior to the CCI retrofit. This change will also preclude the need for routine stroke length checks. The fire protection line being rerouted will have no adverse effect on the fire suppression coverage in the affected room. Since the ARV retrofit is being designed and installed to the existing design requirements as delineated in the LBDs, thb activity will have no adverse impact on any existing structures, systems or comporents. This activity will not have any affect on accidents, malfunctions or the margin of safety as described in the LBDs.

l 1

to TXX-99182 TU Elactric Page 54 of 85 Unit: NN2 Evaluation Number SE-98-032 Revision 0 Activity

Title:

DELETE THE ENGINEERED SAFETY FEATURE INTERLOCKS FOR ELECTRICAL AREA EMERGENCY FAN COIL UNITS. 1 Description of Change (s):

The activity involves deletion of the engineered safety feature interlocks for the Electrical Area Emergency Fan Coil Units (FSAR Section 7.3.1.1.4 item 10.d).

Summary of Evaluation:

The impact of deletion of the above engineered safety feature interlocks on the performance of the plant electrical distribution systems and emergency diesel l

generators (EDGs) were reviewed. It was determined that this activity has no adverse  !

Impact on the above systems. This activity does not affect any other plant system, I structure or equipment. The safety evaluation concludes that it is acceptable to delete )

the above interlocks from the FSAR. Based on this evaluation it is concluded that implementation of the proposed activity does not result in an unreviewed safety question.

i i

i

Attachment 1 to TXX-99182 TU El:ctric Page 55 of 85 Unit: NN2 Evaluation Number SE-98-033 Revision 0 Activity

Title:

Installation of Telescopic Jib Crane in Unit 2 containment to perform misc. load handling activities during plant outages (DM 96-096) 1

! Description of Change (s):

L This activity installs a Telascopic Jib Crane in Unit 2 containment. It is supported by structural steel support, mounted on east-west divider wall between S.G. compartments at El. 905'-9". - Two such supports are provided, one each between S.G compartments 1 & 4 and 2 & 3. Crane can be located as required, at either of these two supports.

Th'is crane will only be used during plant outages, modes 5,6, and defueled. Jib Crane and it's support are non-nuclear safety related, Seismic Category ll. Non-Safety Outage Power Supply (non-plant power from 25KV loop) will be used to provide electrical power to the crane. Plant support power panel Tag no. CP2-EPDPNB-26 will be the power source. LDCRs SA-98-060 and TR-98-004 have been issued.

Summary of Evaluation:

The modification installs new load handling equipment in Unit 2 Containment in the form of Telescopic Jib Crane. This will help to reduce demand on Polar Crane during Outages and this crane will be available as a back-up to polar crane in the event of temporary failure of the polar crane. The jib crane, it's support and platform around the crane at El. 905'-9" are designed Seismic Category ll and therefore moet the requirements of current design licensing bases of CPSES. Also the east-west divider wall of S.G. compartments has been evaluated for additinoal loads due to jib crane and the wall is determined to be structurally adequate to support the additional loads.

Hence this activity does not introduce any new credible potential failure modes. The electrical power addition is designed such that all requirements pertaining to cable sizing, protection and penetration protection are met ir, accordance with existing design .

bases and no new credible potential failure modes are introduced. Heavy load movements performed by this crane will be in accor.iance with the heavy load program requirements.

I l

l l

Att:chment 1 to TXX-99182 TU El:ctric Page 56 of 85 Unit: NN2 Evaluation Number SE-98-035 Revision 0 .

Activity

Title:

Installation of a new pump skid to split the Condenser Vacuum and Water Box Priming Functions (DM96-039/2RF04)

. Description of Change (s):

This activity entails installing a new vacuum pump skid in Unit 2 to improve the existing Condenser Vacuum (CV) and Waterbox Priming System. This will reduce maintenance activities associated with the existing condenser exhausters. There is a continuous problem stemming from water carryover from the waterbox priming portion of the system and biological growth in the system. Piping from the main and auxiliary condenser waterboxes and the Turbine Plant Cooling Water (TPCW) heat exchanger ,

will be disconnected from the respective condenser shell exhaust piping and run separately to a new duplex vacuum priming pump skid. This willleave the existing condenser exhausters for the main condenser side air removal process. There is no I new regulatory commitments changed due to the installation of this new vacuum pump skid.

Summary of Evaluation:

All credible failure modes have been previously analyzed and no new failure modes are 3

introduced by the implementation of this activity. There is no uffect on accidents and malfunctions evaluated in the ' icensing Basis Documents. There is no potential for creating a new type of unanalyzed event. There is no impact on the Techaical Specifications or their bases, nor is there any affect on the margin of safety as a result of this activity or its implementation.

i l

E Attachment .1 to TXX-99182 TU El:ctric Page 57 of 85' Unit: NN2 Evaluation Number SE-98-036 Revision 0 i

i, Activity

Title:

l PROCEDURE CHANGES TO CLOSE VALVE 1DD-0030 EXCEPT WHEN FILLING

[ THE CST OR THE RMUWST l

Description of Change (s):

This activity defeats the Demin Water automatic fill feature for the CST by procedurally closing valve 1DD-0030 when not filling the CST or the RMUWST. Valve 1DD-0005 leaks by its seat and if 1DD-0030 is not closed as proposed in this activity, the RMUWST continually fills with the leak-by of 1DD-0005. Valve 1DD-0005 is to be reworked, however, for this evolution to take place it will require draining the RMUWST.

Therefore, in the interim, valve 1DD-0030 will be procedurally controlled as proposed.

The automatic fill, if not defeated, occurs when the Unit 1 CST level reaches 58,4%.

Operations presently monitors the level of the CST at least once per shift as required by OPT-102A and as good operating practice they maintain the level approximately between 70% and 90%. When the level apprmches 70%, they have Chemistry check the makeup water supply chemistry to confirm it is acceptable before manually filling the CST. This process will be continued and it ensures that the CST is filled with the proper water chemistry before the automatic fill occurs. Until 1DD-0005 is reworked Operations will continue to function as in the past, however, the backup automatic fill function will not be available.

Summary of Evaluation:

Consideration has been given for all potential failure modes for this activity, and it has been determined that there are no credible failure modes that could adversely affect systems, structures, or components resulting in an increase in the probability, severity, or consequences of any accident analyzed in LBDs. This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an upset, emergency, or faulted condition. This activity does not affect the Design Basis of Condensate Storage Facilities as described in Section 9.2.6.1 of the FSAR.

l i

l- I l

Attachment 1 to TXX-99182 - TU El ctric Page 58 of 85 - Unit: NN2 Evaluation Number SE-98-037 Revision 0

~

l Activity

Title:

l- UPDATE FASR SWITCHYARD DETAILS TO REFLECT THIS CHANGE AND

! COMMITMENTS 24895 AND 18863 DELETION 1

Description of Change (s):

LDCR SA 98-16 Switchyard FSAR change to details. The FSAR presently states that

' the Switchyard Circuit Breakers have three (3) close-open operations without external power. This is true only for those Circuit Breaker that use Compressed Gas for an Energy. Source. Others use a Hydraulic Mechanism that allows for only two (2) close-open operations without an extemal source of power. The LDCR is to (a) delete the i,

types of energy storage mechanism and (b) remove the detail of the number of close-open operations. This meets the requirements for Reg. Guide 1.70 and is more detail than is covered in the Standard Review Plan (NUREG-0800) Section 8.2. Both are met by providing energy storage means for circuit breaker operations without electrical l power source c) trivial change to the FSAR in regard to the Venus transmission line I

~ distance Page 8.2-2, from 48 miles to 47 miles. This is to make the more correct round off from data on Page 8.2-i1 where the Venus line conductor is broken into two sections of 22.4 and 24.62 miles. The sum is 47.02 miles and is considered to be a trivici change of an editorial or clarification nature.

Summary of Evaluation:

! The Reg. Guide 1.70 Rev. 2 and Standard Review Plan are not concerned with the l number of close-open operations available to Switchyard Circuit Breakers. The review is limited to the ability of restoring offsite power after a complete loss of power. CPSES Switchyard Circuit Breakers provide this ability with Circuit Breakers that can reclose j without external power.The LDCR is to delete the means of energy storage, and detail  !

of number of close-open operations available. It also add description that the breakers I

~are provided with energy storage mechanism, which allow operation of breakers l without external source of electrical power. The Venus Line length is a Trivial correction

l. of information.

i l

l

. I Li

Attachment 1 to TXX-99182 TU El:ctric Page 59 of 85 Unit: NN2 Evaluation Number SE-98-038 Revision 0 Activity

Title:

CLOSURE ACTIVITIES REQUIRED TO ABANDON THE CLEAN LUBRICATING OIL STORAGE TANKS IN U1/2 TURBINE PURIFICATION SYSTEM Description of Change (s):

This activity will address the official abandonment of the Unit 1 and 2 clean Lubricating oil storage Tanks (CLOSTs). The abandonment was initiated by recent regulatory changes to sampling requirements for underground storage tanks and will be conducted per regulatory guidance from the Texas Natural Resource Conservation Commission (TNRCC). The CLOSTs will be drained, cleaned, and filled with an inert material to preclude further use. The outlet lines from the tanks will be cut and capped and the tank instrumentation and alarms will be deleted.

Summary of Evaluation:

Consideration has been given for all potential failure modes for this activity, and it has been determined that there are no credible failure modes that could adversely affect systems, structures, or components resulting in an increase in the probability, severity, or consequences of any accident analyzed in the Licensing Basis Documents. This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an upset, emergency, or faulted condition.

- to TXX-99182 TU Elsctric Page 60 of 85 Unit: NN2 Evaluation Number SE-98-039 Revision 1 Activity

Title:

STARTING OF EDGs AS AN " EMERGENCY START" DUE TO ASSOCIATED BUS UNDER VOLTAGE CONDITION.

Description of Change (s):

DM 98-053 and LDCR SA 98-118. The DM makes starting of EDGs as an " emergency start" due to associated bus undervoltage condition, automatically repositions the machine frequency to 60 Hz on receipt of emergency start signal. The DM also replaces the existing control switch to pull to lock type on CB-11 to enable the operator to manually stop the engine. The us of this switch to stop the engine under normal plant operating conditions is not restricted. However, its use to stope the engine during

- off normal conditions shall be administratively controlled. The DM also makes modifications to the EDGs starting circuitry (150 psi interlock) so that the EDG trips (with the exception is over speed and differential protection) are not reinstated when the starting air pressure falls below 150 psi and the EDG is already running in an emergency mode. DM 98-053 makes the following changes in the Unit 2 Emergency Diesel Generators (EDGs) installation: 1. Makes changes to the EDGs starting circuit. These changes make the starting of the EDGs as an " emergency start" on the associated bus under voltage condition. 2. Adds a timing relay and an auxiliary relay in each EDGs govemor control circuit. If the EDG is already running with the output breaker open and an emergency start signal is present, this modification will i' momentarily open and then reclose the 701's digital speed control (DSC) " idle / rated" contact. Opening and reclosing of this contact will cause a short speed transient as the fuel supply is reduced momentarily and then restored to 100% fuel. This modification to tas circuitry automatically repositions the frequency of EDGs to 60 Hz. 3. Deleted.

4. Makes changes in the 150 psi interl@ in the EDGs starting circuits. This change assures reinstated when the starting ai, p.= essure falls below 150 psi and the EDG is running in the emergency mode. - 5. Modifies the engine emergency stopping circuit to enable the operator to stop the engine from the control room. 6. Makes minor wiring changes in the Control Relay Cabinets CP2-ECPRCR-03, CP2-ECPRCR-04 and in the termination cabinets CP2-ECPRTC-19 and CP2-ECPRTC-20.

. Summary of Evaluation: ,

The impact of this DM on the performance of EDGs,125 V DC system,118 V AC l system and seismic qualification of EDGs control panels were reviewed. It has been determined that there are no credible failure modes associated with the implementation of DM 98-053 activities. The modifications make the EDG installation compliant with IEEE 387-1977, Reg. Guide 1.9, FSAR and CPSES Design Basis documents. Engine emergency start /stop switch use is not restricted under plant normal operating  ;

conditions. However, its use to stop the engine under off normal conditions shall be administratively controlled. Unwanted stopping of the engine is precluded by changing i the existing " Emergency start /stop switch" to " Pull to lock" stop type. This switch {

retums to the normal position if it is not in the pulled to lock position. Based on the I above evaluation, it is concluded that the implementation of DM 98-053 does not I involve an unreviewed safety question.  !

I

I Attachment 1 to TXX-99182 - TU Elsctric Page 61 of 85 - Unit: NN2 Evaluation Number SE-98-040 Revision 0 Activity

Title:

1 PROCEDURE CHANGE TO RFO-106 WHICH PROHIBITS THE USE OF THE DAMAGED FUEL CONTAINER CURRENT INSTALLED IN SFP-01 (LDCR-SA-98-124)

Description of Change (s):' ..

.The proposed activity would eliminate the use of the Damaged Fuel Container which is currently installed in Unit 1 Spent Fuel Pool. The activity is to support the resolution of

~ ONE 97-1554 which determined the Damaged Fuel Container could not be utilized in a i safe manner. This activity will administratively prevent use of the Damanged Fuel Container until such a time when it is feasible to replace the modified storage rack and damaged fuel container with an unmodified storage rack which will not accomodate a Damaged Fuel Container. '

Summary of Evaluation:

This activity determined that the Damaged Fuel Container is not required to maintain accident or occupational exposure below allowable limits. Furthermore, th , activity .

does not compromise any system design characteristic or the safe handl, i if fuel.

The Damaged Fuel Container, if it could be used with confidence, would be vnly a minor enhancement; This evaluaiton determined that there are no unreviewed safety questions and that there is no reduction in the margin of safety.

l l

i i

Attachment i to TXX-99182 TU Elsctric Page 62 of 85 Unit: NN2 I

Evaluation Number SE-98-041 Revision 0 Activity

Title:

SPENT RESIN STORAGE TANK SET POINT CHANGE AND OVERFLOW l

' PROTECTION Description of Change (s):

This activity implemented design changes to enhance the containment of radioactive ,

water and resin inside the Spent Resin Storate Tank (SRST), prevent contamination of l the Plant Primary Ventilation System (PPVS), reduce potential radiological exposure to l plant personnel, allow Radweste Operations to control and optimize the set points for i the SRST high alarm and the SRST vent isolation valve auto-closure, and provide for i better control of any water that may be introduced in the vent line of the SRST. The l SRST is vented to the PPVS and was only isolatable manually. The alarm for the  !

SRST was so high that once it came in Radwaste Operations could not respond and l isolate the SRST vent before radioactive water and resin fines entered the PPVS.  !

Once SRST water and/or resin entered the vent pipe there was no way to remove it.

During two past plant events, radioactive water and resin fines escaping from the SRST contaminated the PPVS and increased personnel exposure with respect to subsequent required decontamination activities and exposure to contaminated areas. A plant

- design modification was installed to enhance Radwaste Operation's control of spent resin / water inside the SRST and prevent this water and/or resin fines from entering the PPVS when levels incide the SRST are excessive. The modification added an auto-close to the existing SRST vent isolation valve by interlocking this valve to the existing SRST high level alarm instrumentation. The modification now allows Radwaste Operation's to control two SRST set points (high alarm and vent valve closure) on the Liquid Waste Processing System control panel. Both set points have a maximum setting of 97% of the scale on the associaed SRST liquid level control instrumentation loop. This activity also added a drain valve to a segment of the vent line between the SRST and SRST vent isolation valve.

Summary of Evaluation:

This modification involves components of the Liquid Waste Processing System which is a non-nuclear safety-related system. The interconnection of the high level alarm into the close logic for the SRST vent isolation valve does not change the intended functions during normal operations as described in the Licensing Basis Documents.

Evaluation of this modification found that there is no accident or equipment important to safety that could be effected by a malfunction of any of the new equipment or credible potential failures. Credible failures identified for this modification tend to place the plant in its pre-modification configuration'. Potential plant radiological consequences due to a malfunction are not increased; they are bounded by the consequences of the current analyzed event of the SRST safety relief valve opening. The addition of an auto-isolation on a highly radioactive tank vent due to high water levels, optimizing the alarm set point and addition of a drain to remove water that does enter the SRST vent are all modifications to reduce the affects of the radiological consequences that could occur if the SRST over filled. This modification has no effect on any safety related equipment, design basis event, or safe shutdown of the plant. The modification does not change any safety related equipment, nor does it affect the radiological consequences of

_ equipment that supports safety related equipment that is used to mitigate the consequences of a licensing basis event. Failure of the new vent drain valve could

_possibly result in a higher radioactive gas release to local room X-191, but this excess

' gas would be processed by the PPVS in the same way it it processed now. The only

Attachm:nt 1 to TXX-99182 TU Elsctric Page 63 of 85 Unit: NN2 difference would be contamination of local room X-191 prior to processing. The radiological consequences of this potential failure is bounded by the analyzed release from the SRST safety relief valve opening.

l l

}

\

i l

l I

n

= Attachment 1 to TXX-99182 TU Elactric Page 64 of 85 Unit: NN2 i

' Evaluation Number SE-98-042 l Revision 0 Activity

Title:

DM 98-006, Spent Fuel Pool Cooling Water Pump impeller Replacement and Cheng Rotation Vanes (CRVs) installation in SF System (LDCR-SA-98-129)

Description of Change (s):

The proposed activity pertains to the Spent Fuel Pool Cooling Water Pumps CPX-SFAPSF-01, and -02 and the associated suction and discharge piping. Objective of the activity is to reduce the pump and seal water piping vibration (Ref. ONE-PIR 00506) without adversely affecting the pump flow requirement per the Spent Fuel Pool Flow and Thermal Balance analyzed in calculation ME-CA-0235-3306. The activity will replace the existing four vane impellers with five vane impellers in the pumps. Also, Cheng Rotation Vanes (CRVs) consisting of six longitudinal specially formed vanes welded to the inside wall of the pipe will be installed upstream of the elbow on the pump suction side pipe and between the check valve and the first elbow on the pump discharge side pipe. A test will be performed after installation of the CRVs, but prior to the impeller replacement, in the first train to obtain and evaluate system flow and vibration data. Post work test will be performed to validate the analytical pump performance curve and to verify reduction of the pump and piping vibration.

Summary of Evaluation:

Consideration has been given for all potential failure modes for this activitiy, and it has been determined that there are no credible failure modes that could adversely affect system, structures, or components resulting in an increase in the probability, severity, or consequences of any accident analyzed in LBDs. This activity does not adversely affect any system used for accident mitigation and will not impact plant response to an

. upset, emergency, or faulted condition. Applicable technical and quality assurance requirements will assure the CRVs structural integrity. The piping system has been evaluated and verified that the CRVs configuration and additional weight in the piping system will not adversely affect the piping stress analysis and the seismic qualification.

i 1

);

Attachment 1 to TXX-99182 TU Einctric Page 65 of 85 Unit: NN2 Evaluation Number SE-98-046 Revision 0 -

Activity

Title:

BORON RECYCLE SYSTEM CROSS TIE TO THE SPENT FUEL POOL SYSTEM,

. SAFETY INJECTION SYSTEMS, AND RWSTS Description of Change (s):

This mod provides a system cross tie to more efficiently transfer water from the Recycle Hold-Up Tanks (RHUT) to the Refueling Water Storage Tanks (RWST).

Presently, RHUT water is transferred to the Spent Fuel Pool Transfer Canal from where it is pumped to the RWSTs. This process is time consuming and man-hour intensive. With this mod, the Recycle Evaporator Feed Pumps (REFP) will provide the motive force through the cross tie starting at the common discharge header of the pumps. To permit filling either RWST, the cross tie then branches in two with one branch tying into the SF piping downstream of 1-8800A and the other into the SF piping downstream of 2-8800A. From these locations the flow of water will be through the 8800A & B valves in the reverse direction and on to the RWSTs through the ECCS suction header.

l Summary of Evaluation.

' The Boron Recyle System gains a new function; that being a supply source of water for the RWSTs. The Safety injection Systems and Spent Fuel Pool System gains a new non-safety function of providing a flow path for the transferred water. The 8800A & B valves gain a new non-safety related function of flowing the cross tie water in the reverse direction. The mod is contained in Rooms 171,172, and 174 on the 790' evaluation of the Auxiliary Building. The mod consists mainly of about 90 feet of 3-inch stainless pipe, three ball valves, one check valve, and a couple of vents and drains.

' The piping is Class 5 and supported to Seismic Category ll requirements. There are no new failure modes or unbounded events created by this modification. There is no impact on accidents or malfunctions previously evaluated nor events of a different type created. Tech Specs and their bases are not affected. Reg. Guide 1.143 and 1.21 requirements are satisfied by the mod. Therefore, no unreviewed safety question is created by this activity.

Attachment 1 to TXX-99182 TU El;ctric Page 66 of 85 Unit: NN2 Evaluation Number SE-98-047 Revision 0 Activity

Title:

CPSES LARGE BREAK LOSS-OF-COOLANT ACCIDENT (LBLOCA) ANALYSIS CODE PACKAGE Description of Change (s):

The TU Electric LBLOCA methodology for CPSES is based upon Siemens Power Corporation's (SPC's) EXEM/PWR Evaluation Model (EM), as described in the TU Electric topical report "Large Break Loss of Coolant Accident Analysis Methodology", of April 2,1993. The existing LBLOCA code package for CPSES was replaced with an upgraded set of LBLOCA codes to achieve improved efficiency and productivity. This code package is an adaptation of the SPC's approved source LBLOCA EM.

Summary of Evaluation:

The replacement of the current CPSES LBLOCA analysis code package with an  ;

upgraded version of the code package was evaluated. The proposed code package  !

displays results that are virtually identical to those obtained from the original CPSES l LBLOCA code package. Also, similar comparisons are obtained between the results of the TU Electric and the SPC versions of the upgraded code packages, thus confirming faithful adapatation of SPC's improved LBLOCA method package. The TU Electric upgraded LBLOCA code package satisfies the conditions and adheres to the limitations set forth by the Nuclear Regulatory Commission (NRC) in the Safety Evaluation Report (SER) of the TU Electric LBLOCA methodology, which was approved for the LBLOCA analysis of CPSES. Therefore, the use of the upgraded LBLOCA code package does not reduce any margin of safety ad defined by the plant Technical Specifications, and does not involve an unreviewed safety question.

I 1

Attachment 1 to TXX-99182 TU El:ctric

- Page 67 of 85 Unit: NN2 l

Evaluation Number SE-99-001 Revision 0 Activity

Title:

REVISED TO CLARIFY NON-CLASS 1E LOADS TRIPPING FROM CLASS 1E BUSES, CORRECT 480V SWTGR UNDER VOLTAGE RELAY SETTINGS & LOAD SHEDDING Description of Change (s):

1. Revise the description for non-Class 1E load tripping in the event of safety injection actuation to clarify that: a. Non-Class 1E loads fed from Class 1E 6.9kV buses are i also tripped. b. Non-Class 1E loads which are isolated from Class 1E bus per FSAR I Section 8.3.1.2.1.7.a.3) are not tripped. 2. Revise the description for load shedding system in the event of loss of both offsite sources to clarify that: a. Loads powered from Class 1E 480V AC switchgear are shed by under voltage relays when the bus voltage decays to approximately 70 percent of the rated voltage. b. The shedding of MCC loads occur when circuit holding coil, and not the MCC holding coil, is de-energized due to loss of power.

Summary of Evaluation:

The implementation of this activity will remove the inconsistency between FSAR sections 8.3.1.1.5.3.2,8.3.1.2.1.7.a, and table 8.3-1, correct the 480V switchgear under voltage relay setting, and clarify the load shedding scheme. The correction of the 480V under voltage relay setting is acceptable as it will not cause nuisance tripping and the 6.9kV under voltage relay settings, as provided in the FSAR, does not expose the motors to unacceptable voltages on restoration of bus voltage.

l

-i i

l i

l- Attachment 1 to TXX-99182 - TU Electric l- Page 68 of 85 Unit: NN2 L

Evaluation Number SE-99-002 Revision 2 Activity

Title:

MIDLOOP LEVEL INSTRUMENTATION AND REACTOR COOLANT SYSTEM VENT TUBING

, Description of Change (s):

L This design modification provided a more reliable midloop level monitoring system.

l The system utilized a digital quartz pressure transducer to measure reference pressure at the pressurizer vent and/or reactor head vent, and a liquid h9ad pressure at the .

l number 4 reactor coolant loop. The pressure signals are transmitted to a remote computer system which determines the Reactor Vessel water level. Indication and display is provided remotely in the control room. The following is also included as part of this design modification: installation of vent tubing from the reactor head to the containment ventilation system with associated isolation valves; new flange

connections with a threaded tail pipe on the Pressurizer Relief tank; modification of Pressure level tree test connections to support the installation of the vent tubing; and the addition of vent valves on 2-LT-3615A, B and C to prevent spillage during instrument venting. This permanent installation of vent tubing and vent valves reduces the manpower required to install tygon tubing during outages, thus reducing personnel exposure and spread of contamination.

Summary of Evaluation:

The installation of the Mansell Midloop Level Monitoring System was performed in phases. Phase I of the modification entailed some permanent equipment being installed in the Containment while the unit is at power. Due to the high levels of radiation above the Containment Recirculation Sumps when the unit is in shutdown conditions, installing this equipment at power assisted in reducing personnel exposure and spread of contamination. It also aided in the installation of additional RCS Level Monitoring to support drain down of the Reactor Coolant System. Phase 11 of the i modification was installed after the unit is shutdown. The pressure transducers were installed in the RCS at locations where valves and piping connections already exist and the permanent installation of conduit, cabling and mountings for supporting the pressure transmitters were installed after shutdown. All equipment was installed per existing design modifications.

l L i to TXX-99182 TU Elactric Page 69 of 85 Unit: NN2 Evaluation Number SE-99-003 Revision 0 Activity

Title:

STEAM DUMP VALVE PERFORMANCE AND TIMING TESTING Description of Change (s):

Change the FSAR Steam Dump valve test and inspection description, (10.4.4.4) to delete reference to remote operation during steam dump performance and timing test, and to remove the requirement that this test be performed during unit operation.

Summary of Evaluation:

The FSAR description of Tests and Inspections related to the steam dumps, incit W the statement, "Dur:ng unit operation each dump valve is periodicially tested. The isolation valves are closed and the dump valves checked for performance and timing with remote operation." In order to satisfy this commitment, all steam dump valves must be isolated during testing, rendering the steam dumps unavailable during the time of the test. The Standard Review Plan, (NUREG-0800), specifies only that, " Periodic inservice test on each valve will be performed." Changing the FSAR to read "Each dump valve is periodically tested. The test can be performed during unit operation by shutting the associated isolation valve and locally checking for performance and timing." will allow a test methodology which is more descriptive of valve condition and less impactive on plant operation. Since the change does not alter the design, configuration or performance of the steam dump system there is no impact on accident analysis assumptions.

Attachment 1 to TXX-99182 TU El:ctric Page 70 of 85 Unit: NN2 Evaluation Number SE-99-005 Revision 0 Activity

Title:

SAFETY EVALUATION FOR SCAFFOLD CONSTRUCTION DURING PLANT OPERATION Description of Change (s):

To provide an evaluation for the impact on plant safety and safe shutdown equipment when permitting scaffold material and components to be erected during plant operation.

Summary of Evaluation:

Scaffold material that is required to be constructed during plant operation has been evaluated to have no adverse effect on safety related equipment, structures, and components provided it is constructed and inspected to meet the requirements of Scaffold Procedure STA-690, Rev. 2 l

l.

i 1

l i

l i

n 1 l Attachment 1 to TXX-99182 TU El:ctric Page 71 of 85 Unit: NN2 Evaluation Number SE-99-006 Revision 0 Activity

Title:

Temporary blocking open of Safeguards El. 810' doors to facilitate work on these doors. Fire doors are req'd to be closed w / working.

Description of Change (s):

This activity (DCN-12739, Rev 0) involves the temporary blocking open or removal of door S1-29CX or S2-29CX which is located in the 810' 6" elevation of the Safeguards Building and separates corridor room 1/2-082 from Train A electrical switchgear room 1/2-083. During this activity roll-up fire doors S1-29C or S2-29C are requ; red to be closed under certain conditions.

Summary of Evaluation:  ;

Consideration has been given for all potential failure modes regarding the breach of l barriers to various hazard type which include fire, security, tomado, ventilation,  ;

internally generated missiles, radiological, HELB, MELB, flooding and EQ. For barrier l controls not covered under existing administrative controls, it has been determined that  ;

by implementing compensatory measures (closing roll-up fire door), no credible failure ,

modes exist which could adversely affect systems, structures, or components resulting  !

in the increase in the probability, severity, or consequences of any accident analyzed in ;

the LBDs. i j

l

7:

Attachment 1 to TXX-99182 TU Electric Page 72 of 85 Unit: NN2

~ Evaluation Number SE-99-007 Revision 0 Activity

Title:

REVISE OF FSAR SECFTION 8.2.2 TO DEFINE 345kV SYSTEM VOLTAGE i RESTRICTIONS REQUIRED BY CPSES Description of Change (s):

FSAR Section 8.2.2 is revised to define 345kV grid system voltage at CPSES at

! CPSES switchyard to be maintained between 340kV and 361kV by TU Electric

!- transmission.

Summary of Evaluation:

CPSES under voltage protection isolates CPSES Class 1E buses from the grid if the degraded grid results in a 6.9kV bus voltage of less then 87.7% (88.1% for Unit 2) of nominal, or a 480V switchgear bus voltage of less then 91.6% of nominal. These voltage settings assure that the safety related Class 1E equipment, when fed from offsite power source, will be exposed to steady state voltages of less than 90% of the equipment voltage rating 345kV grid minimum voltage of 340kV, requikred by CPSES, with maximum plant loading condition maintains Class 1E bus voltages above their under voltage protection settings. The maintenance of grid voltage above 340kV will eliminate actuatiors of the under voltage protection scheme and transfer of plant loads to onsite diesel generator. 345kV grid minimum voltage may drop to 328kV, however, if the grid voltage dips below 340kV the Class 1E loads will be protected from degraded voltage by under voltage protection scheme by isolating the buses from offsite source and feeding them from onsite diesel generator. Maximum grid voltage of 362kV with maximum CPSES load does not expose the Class 1E loads to voltage more than 110%

of their rated voltage. However during CPSES minimum loading condition the grid voltage of 362kV may expose some Class 1E loads to voltage nominally exceeding 110% (approximately 111%) of their rating. The exposure to voltages nominally above 110% of rated voltage does not adversely affect the performance of Class 1E loads, however, to eliminate equipment exposures to voltages above 110% of rated voltage, the maximum voltage of 345kV system at CPSES switchyard is required to be 361kV.

The maintenance of 345kV grid voltage between 340kV and 361 kV will assure adequacy of voltage for Class 1E loads and will also reduce the probability of actuation of under voltage protection to isolate Class 1E buses from the degraded grid and feeding them from onsite diesel generator. l

.l

m Attachment 1 to TXX-99182 TU El:ctric Page 73 of 85 Unit: NN2 Evaluation Number SE-99-009 Revision 0 Activity

Title:

UNIT 2 HIGH PRESSURE TURBINE UPGRADE: DM 97-007 Description of Change (s):

DM 97-007 will upgrade the Unit 2 High Pressure Turbine (steam flow design conditions) to support a thermal uprate from 3411 MWth to 3445 MWth. The LDCR SA 98-012 updates LBDs to reflect changes made by DM 97-007. The new High Pressure Turbine design includes an inlet steam admission ring and more efficient stationary and rotating blades to increase electrical generation output. The installation of the new designed High Pressure Turbine, during the 2RF04 outage, will result in a guaranteed l . generation increase of 4.8 MWatts electric and an expected increase of approximately l 8 MWatts electric. The new High Pressure Turbine rotor will require overhall/ inspection every 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> instead of the current 50 000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> criteria. The Tref program uses Turbine impluse Pressure as an mput to maintain the Reactor Coolant System at approximate temperature (Tave). The installation of the new High Pressure Turbine is l expected to change the full load Turbine impulse Pressure, resulting in the need to

! adjust the scaling of the Turbine impulse Pressure instrument channels. In order to more easily make these adjustments and to accommodate making them at power, if necessary, these instrument channels will re re-scaled in un4s of Percent Turbine Load.

Summary of Evaluation:

i The installation of the new designed High Pressure Turbine, during the 2RF04 outage, I will result in a guranateed generation increase of 4.8 MWs electric and an expected increase of approximstaly 8 MWs electric. All the Systems Structures or Components (SSCs) affected by this modification are not required for the safe shutdown of the plant, have no protective functions and cannot impair the ability of protective systems to function. The only accident in the Final Safety Analysis Report (FSAR) that could be i - impacted by the Structures, Systems or Components (SSCs) associated with this l' proposed activity are "Overspeed of the Main Turbine Generator". The probability of occurrence of this accident is not expected to increase due to this Activity. Therefore, this activity will have no adverse impact on any existing Structures, Systems or

- Components. This activity will not have any affect on accidents, malfunctions or the margin of safety as described in the LBDs. There is no unreviewed safety question (s).

L 1

i s

(l '

to TXX-99182 TU El:ctric Page 74 of 85 Unit: NN2 Evaluation Number SE-99-010 Revision 0 Activity

Title:

MODIFY METHOD OF DEENERGlZING 8701 A/B AND 8702 A/B BY MAINTAINING BREAKERS OFF i Description of Change (s):

Attemate method of doenerging u-8701 A (RHR Pump u-01 HL u-01 RECIRC OMB ISOL VLV), u-8701B (RHR PMP u-02 HL u-04 RECIRC OMB ISOL VLV), u-8702A (RHR PUMP u-01 HL u-01 RECIRC IMB ISOL VLV) and u-8702B (RHR PMP u-02 HL u-04 RECIRC IMB VLV) by maintaining the Motor Operated Valve power supply breakers OFF. The current practice to de-energize these valves removes the thermal -

overload heaters from the Motor Control Center which allows the breaks to be maintained in the ON position and provides Main Control Board (MCB) valve position indication. This is open to interpretation as a departure from a paragraph in TXX-91151 under the SIGNFICANT HAZARDS CONSIDERATION Section ll fourth paragraph. " Implementation of this change (the removal of the autoclosure interlock circuitry and the addition of a control room alarm) does not affect the availability of the RHR suctions valve open permissive interlock or the position indication lights at the Main Control Board (MCB). Power removal from the RHR suction valves is accomplished in a mannor which maintains va!ve position on the MCB". Nuclear Licensing will issue a notfication to the NRC of this departure fromt he statement in TXX-91151, Summary of Evaluation:

There is no impact on plant safety to modify method of de-energizing the RHR pump hot leg recirculation isolation valves. This method satisfies the operational requirement for the valves to be de-energized in MODES 1 through 3 AND provides positive indication that the valves are de-energized. This method also provides a simplified method to accomplish the task, by minimizing the coordination of various Work Groups and the time to perform the task. When the valves are de-energized by opening the breakers, the light indication on the MCB handswitch is removed by virtue of removing control power to the valve. Diverse and reliable indication of valve position remains available to the Operator in the Control Room. Individual alarms for each valve, which indicate the valve is not closed with RCS pressure above 415 psig is provided. In addition, computer points for each valve are available on the Plant Computer to provide valve position indication. Diverse valve position indication is derived from a limit switch, which senses valve position from the MOV CAM position switches, or a stem mounted position switch. The limit switch output is either fed directly to an alarm circuit / computer input or the switch output is fed to a relay powered by a power source independent of the MOV power supply. The relay contact feeds an alarm circuit / computer input. Therefore, the alarm indications and computer inputs are diverse and reliable sources of valve position indication. Modifying the method of de-energizing the RHR pump hot leg recirculation isolation valves was initiated in part by the Action assigned from ANI9880992203-02 to evaluate the practice for de-energizing the valves. Leaving the breakers de-energized at power povides an increased assurance that the power supply to the valves is removed by virtue of a positive indication of such. the handswitch lights being distinguished.

i

\

Attachment I to TXX-99182 TU El::ctric ,

Page 75 or 85 Unit: NN2

- Evaluation Number SE-99-012 Revision 0 Activity

Title:

Unit 2, Cycle 5 CORE CONFIGURATION Description of Change (s): i During the refueling outage for Unit 2 (2RF04), prior to operation of Cycle 5, fresh Region 7A fuel assemblies,52 fresh Region 7B fuel assemblies, 36 fresh Region 7C fuel assemblies and one fresh Region 6W assembly replaced 72 Region 5 assemblies, 8 Region 4A assemblies, and 12 Region 48 assemblies. The Region 2 assembly was replaced by another Region 2 assembly. For the Unit 2, Cycle 5 core configuration,91 fresh fuel assemblies manufactured by Siemens Power Corporation (SPC) is re co-resident with 100 partially burned fuel assemblies manufactured by SPC and 1 fresh and 1 partially burn optimized fuel assemblies (OFA) manufactured by Westinghouse. j in addition, provisions for increasing the power level from 3411 to 3445 MW were made.

i Summary of Evaluation: j The CPSES U2C5 mixed core configuration has been evaluated for mechanical and I thermal-hydraulic compatibility between the different SPC and W fuel assemblies. All ]

applicable design criteria were determined to be satisfied at both the current and the increased power levels. The neutronic characteristics of the Cycle 5 core configuration have been evaluatad for their effect on the accident analyses. In all cases, it was determined that the applicable event acceptance criteria are satisfied. Because all mechanical design criteria continue to be satisfied, there is no reduction in any failure point introduced by the Cycle 5 core configuration. All acceptance criteria of the accident analyses continue to be satisfied; therefore, there is no increase in the consequences of any accident previously analyzed. Based on the foregoing, it is concluded that the Unit 2 Cycle 5 core configuration does not reduce any margin of safety as defined by the plant Technical Specifications; therefore, the proposed change does not involve any unreviewed safety questiors.

l 1

l 1-i

)

' Attachment 1 to TXX-99182 TU Elactric L Page 76 of 85 Unit: NN2 I

. Evaluation Number SE-99-013 l Revision 0 Activity

Title:

l CROSS-CONNECTING UNIT 1 AND 2 TRAIN B SAFETY CHILLED WATER / UNIT 1 SUPPLYING '

l Description of Change (s):

Crossties between Unit 1 and 2 Safety Chilled Water at the Spent Fuel Pool Cooling pump room emergency fan coils units (EFCUs) are considered to be GDC-5 isolation boundaries required to ensure that in the event of an accident in one unit, the other can be safely shut down. The procedure change wi!! only be used in the event of a loss of Train A decay heat removal on Unit 2 and there is a need for long term cooling of Unit 2 Train B.- Opening the crosstie from Unit 1 Train B results in that Train being inoperable for the mitigation of DBAs and the procedure change requires the Unit 1 LCO to be entered. The procedure change ensures that Unit 1 Train A supported equipment is OPERABLE before making Train B inoperable. Calculation shows that Unit 1 Train B CHS can maintain Unit 2 RHR and CCW pump rooms below normal maximum temperatures via the crosstie if the flow to certain non-required EFCUs are isolated. The procedure change requires the above isolation and directs additional isolation if required to maintain Unit 2 Train B pump room temperatures. The implementation of the cross-connect via this procedure change will ensure the long term operability of decay heat removal via Unit 2 Train B.

Summary of Evaluation:

There is no effect on the probability of malfunctions, events, or accidents as described in the current licensing basis (CLB). The consequences of accidents as described in the CLB are not affected by this change because the Unit 1 LCO would be entered as is allowed.

i i

l l

t I_

7.

Attachment 1 to TXX-99182 TU El:ctric Page 77 of 85 Unit: NN2 Evaluation Number SE-99-014 Revision 0 Activity

Title:

INSTALLATION OF NEW SECURITY SHIELDS AND BOTHS ON THE ROOFS OF THE SAFEGUARDS AND FUEL BUILDINGS Description of Change (s):

New security shields and booths are being installed at various locations in the plant.

These shields and booths provide no safety related or safe shutdown function for the plant. I Summary of Evaluation:

The new security shields and booths installed per DCN 12742 do not affect the ability of any structure, system or component to perform their design basis functions as described in the LBDs. The functions of these security shields and booths are not specifically addressed in the LBDs. The new security shields and booths have been designed so as to not interfere with the ability of any structure, system or component from performing its Design Basis function.

l l

l L

to TXX-99182 TU El:ctric Fage 78 of 85 Unit: NN2 Evaluation Number SE-99-015 Revision 0 Activity

Title:

Fabrication of Barriers Description of Change (s):

New security barriers / changes (>40) were fabricated, erected and/or installed within the Protected Area. Some of these are considered Safeguards Information.

Summary of Evaluation:

Details of barrier (s) fabrication, erection and/or installation available on an as needed bases in accordance with regulation and facility procedures for review of Safeguards Information. None of the installations affect the design basis function (s) of any system, structure or component.

1 l

I

i Attachment 1 to TXX-99182 TU El:ctric Page 79 of 85 Unit: NN2 1

Evaluation Number SE-99-016 l . Revision 0 Activity

Title:

SAFEGUARDS SAFETY EVALUATION Description of Change (s):

10 Security improvement items were generated to support the OSRE inspection and

' activities beyond the inspection to support Security activities. Detailed information available for review in accordance with regulatory and facility requirements for access to Safeguards Information and/or Confidential Information.

Summary of Evaluation:

. Changes identified donot decrease design basis functionality or safety margin for any t

system, structure or component.

I i

1 4

l

,c Attachmer t 1 to TXX-99182 TU El:ctric p Page 80 of 85 Unit: NN2 L

,, Evaluation Number SE-99-017 Revision 0 Activity

Title:

TM 2-99-03 RO, TEMPORARY REMOVAL OF FUEL TRANSFER SYSTEM LIFTING ARM -TRANSFER CAR POSITION INTERLOCK 1

Description of Change (s): . I During 2RF04 fuel handling operations, the pit side proximity switch was interfering with the travel of the transfer car. The proximity is an electrical interlock which prevents upending the container if it is not at the end of travel (or "home"). This proximity switch is redundant to another electrical interlock which is for the transfer motor stall (or

- torque"). This stall (torque) interlock prevents upending the container if the motor is running. There is also a backup mechanical interlock which is a latch that prevents the fuel container from " tilting"in the water during horizontal traversing of the car along the track. The purpose of this Temporary Modification is to jumper around the proximity switch electrical interlock and position the bypassed switch so that the switch will not

. Interfere with core loading during 2RF04. This action removes the proximity switch electrical interlock and removes the Fuel Building console " green" light indication for when the transfer car is at the end of travel (or "home") on the pit side.

1 Summary of Evaluation: .

The fuel transfer system performs its function of transferring nuclear fuel assemblies between the reactor containment building and the spent fuel building underwater via the fuel transfer tube. When traversing, the fuel container is required to be positively {

l restrained from being titited to the vertica! until it is at one of the pick-up points. The l fuel container is positively restrained through the use of interlocks. Damage to a fuel J assembly will be prevented by: (1) the electrical interlock for transfer motor stall (or ,

' torque'); (2) the mechanical interlock; and (3) the operator performing the back-up i function by visually ensuring the basket is against the stop. The two (2) additional interlocks in conjunction with the compensatory measures will ensure there are no adverse consequences during the temporary modification while the proximity switch interlock is jumpered around.

l I

L1 1

1. l j

Attachment 1 to TXX-99182 TU El:ctric Page 81 of 85 Unit: NN2 Evaluation Number SE-99-019

, Revision 0 l

Activity

Title:

Cell 19 on battery CP2-EPBTED-01 (BT2ED1) is bypassed, leaving this battery with 59 cells.

Description of Change (s):

DCN 12931 Revision 0 installs a jumper between cell 18 and 20 bypassing cell 19 of battery CP2-EPBTED-01 as a result of the failure of cell 19, leaving this battery with 59 cells. LDCR SA 99-21 makes changes to FSAR Table 8.3-4 and Figure 8.3-14 for CP2-EPBTED-01. FSAR Table 8.3-4 provides a new design margin for battery CP2-EPBTED-01 because this battery will now have 59 cells.

Summary of Evaluation:

Cell jumper cable is sized to have sufficient current-carrying capacity for the maximum battery discharge amperage and to meet Technical Specification requirements for cell-to-cell and terminal connection resistance. Battery is unchanged in its ability to perform its design function. No new failure modes are introduced.

l l l

i

]

o Attachment 1 to TXX-99182 TU Elsctric Page 82 of 85 Unit: NN2 Evaluation Number SE-99-023 Revision 0 Activity

Title:

. RESIDUAL HEAT REMOVAL PUMP COUPLING UPGRADE Description of Change (s):

Texas Utilities (TU) Electric has implemented the Residual Heat Removal System (RHRS) pump coupling upgrade program for Comanche Peak, Units 1 and 2.

Westinghouse and Ingersoll-Dresser Pumps (IDP), formally Ingersoll-Rand, jointly developed this hardware upgrade for IDP pump models W, WD and WDF with a closed couple design. In the closed-couple design, the motor and pump share a common, one piece shaft. The coupled pump upgrade involved the addition of a coupling between the pump and motor to simplify pump maintenance and to reduce the radiation exposure to plant maintenance personnel. The addition of the coupling required a considerable amount of new pump hardware,'as well as modification of the existing motor shaft, pump impeller and pump diffuser. The upgrade also included the addition of a guide bearing on the new pump shaft and the conversion of the mechanical seal to a cartridge design.

Summary of Evaluation:

This Safety Evaluation was prepared dur to the combined Nuclear Overview Evaluation and Engineering Self Assessment , discovered that the 10CFR50.59 Activity Screens for these modifications concluded that no Safety Evlauation was required. These modifications converted the closed coupled RHR pumps to a direct coupled configuration in order to reduce the duration of maintenance activities and thereby minimize exposure to radioactive pump internals. The justification for the conclusion that no Safety Evaluation was required, was based on the premise that the  ;

modifications satisfied the original pump design requirements and the fact that no  !

change to any licensing basis documents was required because the FSAR does not  ;

describe the RHR pump in sufficient detail. The FSAR was the only licensing basis document listed as a reference. The conclusion that no change to any licensing basis document would be required as a result of these modifications, was in error. The modifications did in fact change the facility as described in the licensing basis documents, therefore a Safety Evaluation should have been prepared. Specifically, the

' Inwvice Test Plan (licensing basis document) identifies the RHR pumps as a cedrifugal closed coupled type pump and selects testing parameters (driver bearing vibration) from ASME/ ANSI OM Part 6 for centrifugal closed coupled type pumps.

Implementation of the subject modifications converted the RHR pumps to a direct coupled configuration, however, the IST Plan was not revised to reflect this. This Change wi!! make the required change to the Inservice Test Plan. Implementation of the above mentioned design modifications will neither initiate nor affect the progression

_ of any accident described in FSAR Chapters 6 or 15. The Westinghouse design

' reviews and qualification program have shown that the coupling upgrade satisfies all the original RHRS pump design requirements for Comanche Peak, Units 1 and 2 and any applicable new requirements. Therefore, this activity will have no adverse impace on any existing Structures, Systems or Components. Will not increase ths probablity of a malfunction of equipment important to safety previously evaluated in the LBDs. Will

, not increase the Radiological consequences of a malfuntion of equipment important to safety previously evaluated in the Licensing Basis Documents. Will not create a new type of unanalyzed event. Will not decrease the margin of safety as defined in the basis for any Technical Specification.

m-

m Attachment 1 to TXX-99182 - TU El:ctric Page 83 of 85 Unit: NN2 Evaluation Number SE-99-024 -

Revision 0 Activity

Title:

REACTOR COOLANT PUMP CARTRIDGE SEAL UPGRADE Description of Change (s):

The proposed Design Modification includes the conversion of Model 93AS Reactor

~ Coolant Pumps with standard seal to accept cartridge seals. These cartridge seals are similar in function and performance to the original equipment, and, as a unit, provide the same sealing function as the original equipment. Changes to the RCP pessure boundary include substitution of a new lower seal housing incorporating a gasketed joint and new bolting associated with the lower seal housing and cartridge seal.

Summary of Evaluation: j '

This safety evaluation was generated to provide further clarification and detail on equipment changes due to the Reactor Coolant Pump seal package modification originally identified in Safety Evaluation 94-33. It does not change the original intent or original scope of Safety Evaluation 94-33. The design modification converted the Reactor Coolant Pump (RCP) seal package to a cartridge seal assembly. The .

cartridge seal package performs the function of maintaining the RCS pressure boundary, but provides a more efficient means of removing and installing the seals, by 4 the use of an articulated arm. The new seal packages does not adversely affect the j RCS pressure boundary or the DNB parameters. The articulated arm is attached to the i' inside of the motor stand and is secured to the motor stand during operation in such a' way as to not interfere with the operating components and will remain secure during a seismic event. Spool pieces and flange connects were also revised and rerouted to coincide with the lower seal housing location. The changes to the piping and flange i

connections do not adversely impact any safety related systems or the integrity of the pressure boundary. Safety Evaluation 94-33 did not specifically address the  ;

replacement of the Seal Outlet Temperature RTD with a Seal inlet Temperature RTD. j Since, the seal package was moved lower in the housing the Outlet Temperature RTD was moved to the inlet side of the seal water. The new location provides a means of measuring seal conditions by providing a delta temperature in conjunction with the seal water bearing temperature RTD for evaluating effectiveness of the Thermal Barrier Can Assembly and the condition of the seals.

i to TXX-99182 TU Electric Page 84 of 85 Unit: NN2

- Evaluation Number SE-90-026 Revision 0 Activity

Title:

l Doors / Tornado Dampers to be opened for extended periods of time in order to aleviate room 1/2-088 temperature (Tech Spec 3.7.10 limits)

Description of Change (s):

This activity (Work Order 4-99-125198-00, Unit 1 and Work Order 4-99-125199-00, Unit 2) involves the opening of doors S1/S2-33X for extended periods of time. These doors are normally closed doors. This activity will also evaluate the opening of tomado dampers to room 1/2-88, CP1/CP2-TVSGTD-15, (the discussion that follows will address the affected rooms as room 88). This door is a normally closed door and serves as the access door to the pipe penetration area room 88. This door serves as a tornado blowout door which opens on differential pressure and also blows open during a HELB in room 88. There are no other barrier functions required of this door and this door is not a fire rated door. During summer conditions, there are times when increased temperature excursions in the room can be alleviated by the opening of this door and the tornado damper. The ventilation of room 88 is accomplished by transferring air from the corridor through an opening above the door. Once this air absorbs heat in room 88, this air is exhausted directly to the atmosphere via the primary plant ventilation system. Opening the door and damper do not affect the HVAC of the remaining portion of the plant and can only improve the environment of room 88. There are primarily two programs of concem which may be impacted by this activity, these are the tornado venting analyses and the Systems Interaction Program (SIP). In order to equalize the pressure differentials on the building structure during a tomado, the tornado damper is designed to open and the door is designed to blow out.

Therefore, opening the door and the damper will have no detrimental effects on the tornado venting analyses. In the SIP program, the analysis of concern in the environmental analysis. The bounding HELB (i.e., Steam Generator Blowdown pipe ]

break) in room 88 causes the damper to open in less than 0.25 seconds and the door to blow open in less than 0.5 seconds. Sensitivity studies indicate that opening the door prior to the HELB results in significant temperature changes (less than 1oF) in other areas of the plant. In addition, no area changed in classification from a mild to a harsh environment. Therefore, opening the damper and the door witl result in no significant environmental impact to equipment qualification from environments created by a break in room 88. Breaks outside of room 88 were also evaluated as part of this sensitivity study for the effects on room 88 since the door and the damper would now be open. All the equipment necessary in room 88 has been qualified to the most limiting HELB environment. Since a break in room 88 results in the most limiting HELB environment, environments resulting from breaks outside room 88 are therefore not limiting and need not be considered.

Summary of Evaluation:

~ Although the change in the door position results in. :hange to the facility, there is no effect on the probability of malfunctions, events, or accidents as described in the licensing basis. The consequences of accidents as described in the LBDs are not affected by this change because the equipment qualification environmental parameter changes generated by this activity are of no significance and the tomado venting pressure differentials would remain virtually unchanged and reduced. The ability of the

' equipment to mitigate the consequences of these accidents remains the same.

l l

1

1 i

1 Attachment 1 to TXX-99182 TU El:ctric Page 85 of 85 Unit: NN2 Evaluation Number SE-99-027 L Revision 0 l l l Activity Title Update the number of nozzles on Unit 2, Train A, Region 8 of FSAR Table 6.2.2-1, Table 6.5-5, Section 6.5.2.2.3 and FSAR Figure 6.5-4 j l

Description of Change (s):

Update the number of nozzles on Unit 2, Train A, Region B (on Line #

6-CT-2-124-301R-2) in the FSAR to reflect the actual number of nozzles in the field.  !

Summary of Evaluation:

The removal of one nozzle from the Unit 2, Train A Region B header did not significantly affect any of the analysis or reduce the margin of safety below that which was already analyzed. The flow to the header is sufficient as a result of improved i containment spray pump impellers previously installed on Unit 2. Unit 2 acceptability I was based on the results of the Unit 1 analysis. The number of containment spray l nozzles was not a controlling factor for radiological consequences. Unit 2 had an I additional equivalent margin of 2.5 nozzles more that Unit 1 for the containment spray analysis. The Containment Spray System function is to mitigate the effects of a LOCA or MSLB. The absence of one nozzle in the Unit 2 containment spray system does not affect the capability of the system to perform its design function. The Unit 1 containment sprayed volume analysis (which takes into account the iodine removal rate and the pressure /temperatuire analysis) remains bounding for both CPSES Unit 1 and i Unit 2.

1 i

b