ML20216C005

Proposed Tech Specs,Eliminating Ref to Inverters in TS 3.4.12.1

ML20216C005
Person / Time
Site:	San Onofre
Issue date:	03/06/1998
From:	SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20216B974	List: ML20216B969 ML20216B999 ML20216C005
References
NUDOCS 9803130239
Download: ML20216C005 (47)

Text

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LTOP System 3.4.12.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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1. Only required to be performed when the SDCS Relief Valve isolation valve pair is inoperable.

2 The power-lock open requirement is satisfied either with the AC breakers open for valve pair 2HV9337 and 2HV9339 or the inverter input and output breakers open for valve pair 2HV9377 and 2HV9378, whichever valve pair is OPERABLE.

SR 3.4.12.1.4 Verify the OPERABLE SDCS Relief Valve 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> isolation valve pair (valve pair 2HV9337 ,

and 2HV9339, or valve pair 2HV9377 and 2HV9378) is in the power-lock open condition.

SR 3.4.12.1.5 Verify that SDCS Relief Valve isolation 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> valves 2HV9337, 2HV9339, 2HV9377, and 2HV9378 are open when the SDCS Relief Valve is used for overpressure protection.

SR 3.4.12.1.6 Verify SDCS Relief Valve Setpoint. In accordance with the Inservice Testing Program 9003130239 980306 PDR ADOCK 05000361 p PDR SAN ON0FRE--UNIT 2 3.4-34 Amendment No. 127

ATTACHMENT "B" EXISTING SPECIFICATIONS UNIT 3

. LTOP System 3.4.12.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY-

___....______.-NOTES----------------

l 1. Only required to be performed when the l

SDCS Relief Valve isolation valve pair is inoperable.

1 2 The power-lock open requirement is satisfied either with the AC breakers open for valve pair 3HV9337 and 3HV9339 or the inverter input and output breakers open for valve pair 3HV9377 and 3HV9378, whichever valve pair is OPE'. TABLE. ,

SR 3.4.12.1.4 Verify the OPERABLE SDCS Relief Valve 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> isolation valve pair (valve pair 3HV9337 and 3HV9339, or valve pair 3HV9377 and 3HV9378) is in the power-lock open condition.

SR 3.4.12.1.5 Verify that SDCS Relief Valve isolation 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> valves 3HV9337, 3HV9339, 3HV9377, and 3HV9378 are open when the SDCS Relief Valve is used for overpressure protection.

l SR 3.4.12.1.6 Verify SDCS Relief Valve Setpoint. In accordance l with the  !

Inservice  ;

Testing Program l

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SAN ON0FRE--UNIT 3 3.4-34 Amendment No. 116

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i ATTACHMENT "C" PROPOSED SPECIFICATIONS UNIT 2 1

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i LTOP System 3.4.12.1 SURVEILLANCE RE0VIREF'8TS SURVEILLANCE FREQUENCY

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NOTES----------------

1. Only required to be performed when the SDCS Relief Valve isolation valve pair is inoperable.  ;

2 The power-lock open requirement is satisfied either with the AC breakers open for valve pair 2HV9337 and 2HV9339 or the inve:.cr input andTreghlating transform 6r output breakei's'opin"for Valks" psi F2HV9377 and 2HV9378, whichever valve pair is OPERABLE.

SR 3.4.12.1.4 Verify the OPERABLE SDCS Relief Valve 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> isolation valve pair (valve pair 2HV9337 and 2HV9339, or valve pair 2HV9377 and 2HV9378) is in the power-lock open condition.

l SR 3,4.12.1.5 Verify that SDCS Relief Valve isolation 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> valves 2HV9337, 2HV9339, 2HV9377, and 2HV9378 are open when the SDCS Relief Valve is used for overpressure protection.

SR 3.4.12.1.6 Verify SDCS Relief Valve Setpoint. In accordance with the Inservice Testing Program l

l SAN ON0FRE--UNIT 2 3.4-34 Amendment No. 4N L

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l ATTACHMENT "D" i PROPOSED SPECIFICATIONS UNIT 3 1

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LTOP System 3.4.12.1 i

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY l -------------------NOTES----------------

1. Only required to be performed when the SDCS Relief Valve isolation valve pair is I inoperable.

2 The power-lock open requirement is l satisfied either with the AC breakers l open for valve pair 3HV9337 and 3HV9339 l

or the inverter input :nd}lspinlitihy tFanYfoiniff output breakers opsK"fer I

Vs1Ve*pii'F"3HV9377and3HV9378,whichever valve pair is OPERABLE. t i

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SR 3.4.12.1.4 Verify the OPERABLE SDCS Relief Valve 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

isolation valve pair (valve pair 3HV9337 l and 3HV9339, or valve pair 3HV9377 and l 3HV9378) is in the power-lock open condition.

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SR 3.4.12.1.5 Verify that SDCS Relief Yalve isolation 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> valves 3HV9337, 3HV9339, 3HV9377, and 3HV9378 are open when the SDCS Relief Valve is used for overpressure l

protection.

SR 3.4.12.1.6 Verify SDCS Relief Valve Setpoint. In accordance l with the Inservice Testing Program l

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! SAN ONOFRE--UNIT 3 3.4-34 Amendment No. 146

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ATTACHMENT "E" UNITS 2 AND 3 REVISED BASES B~3~4~12 (FOR INFORMATION ONLY) l

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. LTOP System RCS Temperature s 256'F B 3.4.12.1 BASES i

SURVEILLANCE SR 3.4.12.1.3 (continued) )

REQUIREMENTS

b. Once every 31 days for a valve that is locked, sealed, or otherwise secured open and once every 31 days for open flanged RCS penetrations.

The passive vent arrangement must only be open to be OPERABLE. This Surveillance need only be performed if +.he vent is being used to satisfy the requirements of this LC0.

The Frequencies consider operating experience with mispositioning of unlocked and locked vent valves, respectively.

SR 3.4.12.1.4 and SR 3.4.12.1.5 When one or both SDCS Relief Valve isolation valve (s) in one isolation valve pair becomes inoperable, the other OPERABLE SDCS Relief Valve isolation valve pair is verified in a power-lock open condition every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to preclude a single failure which might cause undesired mechanical motion of one or both of the OPERABLE SDCS Relief Valve isolation valve (s) in a single isolation valve pair and result in loss of system function.

This surveillance requirement, SR 3.4.12.1.4, is modified by two notes. Note 1 requires to perform this SR when the SDCS Relief Valve isolation valve pair is inoperable. Note 2 specifies that the power lock-open requirement is satisfied either with the AC breakers open for valve pair 2HV9337 and

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2HV9339 or the inverter hpt =d : regulating l transformer output breakers open for valve pair ~2HV9377 and'2HV9378,'

whichever valve pair is OPERABLE.

When both pairs of SDCS Relief Valve isolation valves are OPERABLE and the SDCS Relief Valve is used for overpressure protection, the isolation valves are verified open every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

j SR 3.4.12.1.6 The SDCS Relief Valve Setpoint is verified periodically in accordance with the Inservice Testing Program.

(continued)

SAN ON0FRE--UNIT 2 B 3.4-63 Amendment No. 127

. LTOP System l RCS Temperature s 246*F l B 3.4.12.1 h

l BASES 1

SURVEILLANCE SR 3.4.12.1.3 (continued)

REQUIREMENTS

b. Once every 31 days for a valve that is locked, sealed, or otherwise secured open and once every 31 days for open flanged RCS penetrations.

The passive vent arrangement must only be open to be OPERABLE. This Surveillance need only be performed if the vent is being used to satisfy the requirements of this LCO.

The Frequencies consider operating experience with mispositioning of unlocked and locked vent valves, respectively.

SR 3.4.12.1.4 and SR 3.4.12.1.5 When one or both SDCS Relief Valve isolation valve (s) in one isolation valve pair becomes inoperable, the other OPERABLE SDCS Relief Valve isolation valve pair is verified in a power-lock open condition every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to preclude a single failure which might cause undesired mahanical motion of one or both of the OPERABLE SDCS Relief Valve isolation valve (s) in a single isolation valve pair and result in loss of systea function.

This surveillance requirement, SR 3.4.12.1.4, is modified by two notes. Note 1 requires to perform this SR when the SDCS Relief Valve isolation valve pair is inoperable. Note 2 specifies that the power lock-open requirement is satisfied either with the AC breakers open for valve pair 3HV9337 and 3HV9339 or the-4nvceter input and 'regulati~n g transformer output breakers open for valve pair 3HV9377 and 3HV9378, whichever valve pair is OPERABLE.

When both pairs of SDCS Relief Valve isolation valves are OPERABLE and the SDCS Relief Valve is used for overpressure protection, the isolation valves are verified open every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

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SR 3.4.12.1.6 The SDCS Relief Valve Setpoint is verified periodically in ,

accordance with the Inservice Testing Program. '

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l SAN ON0FRE--UNIT 3 B 3.4-63 Amendment No. 116 i l

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I ATTACHMENT "F" DESIGN CHANGE DESCRIPTION

" Replacement of Shutdown Cooling Inverters With Transfer Switches" )'

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DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN C0OLING INVERTERS WITH TRANSFER SWITCHES i TABLE OF CONTENTS l

1. DESCRIPTION OF CHANGE i 1

A. Reason for Change 1-2

8. Functional Objective for Change 1-2 i C. Impact of the Change on Site Programs 1-3 D. Design Criteria .1-7 E. License Document Change Summary 1-15 F. Design Alternatives 1-16 l

2. SAFElf EVALUATION 2-1

3. LICENSE AND DESIGN DOCUMENT IMPACT 3-1

4. DRAWINGS & TIGURES Figure 4-1 Simplified P & ID Figure 4-2 Conceptual One-Line Diagram i Figure 4-3 Conceptual Elementary Diagram Figure 4-4 Preliminary Cabinet Outline & Arrangement l l I

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L L DESIGN CNANGE TITLE:

j REPLACEMENT OF SNUTDOWN C0OLING INVERTER $ WITH TRANSFER SWITCHES L ' 1.

. DESCRIPTION 0F CHANGE 1A. Reason for Chanae l

L The SDCS inverters (YOO6 for HV-9377 AND Y007 for HV-9378) have historically experienced blown fuses because of high currents attributed to inverter miscommutation and contact chatter. A blown fuse '

results in inverter shutdown / unsuccessful valve stroke operation. Each

, inverter is now provided with 3 selectable fast-acting input fuses via a selector switch to reduce the time to restore inverter operability upon a blown fuse event. The fuse selector switches were added to the SDCS inverters in a modification implemented in 1995. Subsequently, the NRC issued their findings that the steps-taken by SCE to improve the reliability of the inverters (installation of selectable fuses) provide

...an acceptable level of safety in the interim until a permanent L solution can be implemented." However,.the NRC also concluded that the current inverter design, specifically inverter size, does not comply with applicable industry guidance.

i In a response letter to the NRC addressing their request for a permanent solution, SCE committed to either replace the inverters with AC l motor-generator sets or with larger inverters, or to replace the/DCcurrent l valve actuator motor with a DC actuator motor and implement the changes- 1 during the Cycle 10 refueling outages. Based on the evaluations of I l these options along with the evaluation of a fourth option, it was decided to remove the inverters and replace them with selectable AC power to HV-9377 and HV-9378 directly from A and B Train MCC's via transfer switches.

IB. Functional Obiective for the Chanae The SDCS Isolation Valves inside containment have the function to remain l closed during normal power operation. These valves also have safety function to open to place the SDCS in operation. Two parallel suction l paths are provided each with two valves in series. In the 16" suction path HV-9337 (during normal operation the circuit breaker at the starter i for this. valve is maintained open) and HV-9339 are powered from opposite l ESF Switchgear Trains A and B respectively. In the 10" path HV-9377 l (during normal operation the circuit breaker at the starter for this l valve is maintained open) and HV-9378 are powered from the 125 VDC bus

. inverters. Trains C and D respectively. This arrangement assures that a i single failure of an isolation valve power supply does not prevent the -

l SDCS from being placed in operation and also assures that positive isolation of the boundary with the RCS can be maintained.

l The functional objective of this design change is to replace the 125 VDC SDCS Inverters for HV-9377 and HV-9378 with manual transfer switches capable of being positioned to either available diesel generator-backed ESF bus, a configu Mtion which will continue to maintain the system design basis of assuring that a single failure of an isolation valve or power supply does not preclude availability of the SDC system or preclude positive isolation of the RCS boundary.

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DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES

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SDCS Inverters Y006 and Y007 will be disconnected and removed from their existing mounting locations. New switch cabinets which contain manual transfer switches, input and output breakers, control circuit components, regulating (isolation) transformers and kirk key interlocks will be installed on the existing mounting pads previously used for the inverters. These cabinets will provide means to supply motive and control power to HV-9377 and HV-9378 from either Train A or Train B Motor Control Centers as determined by the transfer I switch position. Valve position indication will be powered from the Channel C (for HV-9377) and Channel D (for HV-9378) vital bus inverters. New cable and raceway will be installed from the Train A and Train B 480V Switchgear rooms on the 50' Control Building into the 125 VDC Switchgear Rooms for the input to each of the new switch cabinets. The output of the new switch cabinets will l utilize existing cables and raceway.

l IC. Imoact of the Chance on Site Proarams l

l l This design change will involve complete removal of the SDCS Inverters (Y006 and YOO7) and replacement with cabinets containing manual transfer switches at the same location - the respective 125 VDC Switchgear Rooms on the 50' elevation of the Control Building. Providing power to HV-9377 and HV-9378 with manual transfer switches capable of alignment to either Train A or Train B ESF  !

bus will maintain a design configuraticn which provides the availability of )

Class IE power within the accident analysis design basis scenario - loss of '

offsite power with a concurrent loss of one diesel generator. Operation of one of the new manual transfer switches (for either HV-9377 or HV-9378) and its I associated kirk key device on the new switch cabinet would be required in this scenario in order to select the available Class 1E Motor Control Center when ,

placing shutdown cooling into service. i l into service Currently,undernormalconditions,whenplacingshutdowncoolin$

the operator must take action at the 50' elevation of the Contro Building.

Power locked-out feedra breakers for HV-9337 and HV-9377 are required to be l manually shut in order to operate these valves from the Control Room. To establish shutdown cooling in an abnormal or accident condition which includes a loss of Train A or B, the operator must still perform actions at the 50' l elevation of the Control Building to, as a minimum, shut the power-locked out i feeder breaker for HV-9377 located on SDCS Inverter Y006. Re) lacing the l inverters with new cabinets containing manual transfer switcles and associated kirk key interlocks will not create any additional operator burden at the 50' of the Control Building for normal or abiormal conditions. Aligning the new transfer switches for HV-9377 and HV-9378 in preparation for initiating shutdown cooling will be similar to the actions presently performed since all l operator actions will be performed in the 125 VDC Switchgear Rooms.

Additionally, under the present system configuration, during a loss of offsite power or Station Blackout operator action is required to strip loads from the Channels 'C' and 'D' 125 VDC Class IE buses, including the CPC and CEAC, in order to minimize loads im>osed on the Class 1E batteries in anticipation of battery power needed for tie SDCS Inverter operation. With the permanent removal of the SDCS Inverters upon com)1etion of this modification, fewer operator actions will be required to sled battery loads and the battery load profile will be reduced.

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DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTD0WN C0OLING TMVERTERS WITH TRANSFER SWITCHES l IC1. Ooerations Procedures Imoact As described above, replacement of the SDCS Inverters with manual transfer switches will not create any additional operator burden i

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at the 50' of the Control Building for the process of aligning the power supplies to the SDCS isolation valves in preparation for initiating shutdown cooling.

Under normal conditions, prior to the initiation of shutdown cooling, the configuration of the power supplies to valves HV-9377 and HV-9378 will be as follows: (ref. attached FIGURE .

4-2,'AFTER') I a) Both MCC feeder breakers (Train A and Train B) closed b) One transfer switch input breaker (Train A and Train B) shut.

l c) Manual Transfer Switch selected to the shut input breaker.

d) Regulating Transformer output breaker open for HV-9377 and )

shut for HV-9378 l 1 The Kirk Key interlock scheme for the SDCS switch cabinets is I designed to prevent the transfer switch input breakers from being closed at the same time and to prevent operation of the transfer i switch when either input breaker is closed.

Lineup of the )ower suaplies to HV-9377 and HV-9378 will require i

o)eration of tie kirk ceys, breakers, and transfer switches at tie SDCS switch cabinets, all located inside the 125 VDC switchgear rooms. After completion of the breaker and switch alignments, power would be available to the valve control circuits and operation of the valves will be performed at the Control Room control panel as directed in the Operating Instructions.

In the event of a loss of one ESF bus, with one diesel generator available, operation of the SDCS switch cabinets to align power to HV-9377 and HV-9378 will be the same as described above.

However, the manual transfer switches for both valves will be selected to the one available ESF bus rather than the normal lineup of Train A for HV-9377 and Train B for 9378. Thus,

! operator actions outside the Control Room to establish the lineup l for initiating shutdown cooling with valves HV-9377 and HV-9378 l

in both normal and abnormal conditions are restricted to the area of the 125 VDC Switchgear Rooms (Channels C and D). Therefore, this modification is consistent with the actions currently recuired with the SDCS inverters and does not impose any adtitional operator burdens.

The following tables provide a brief outline of actions to j operate the SDCS isolation valves for normal and abnormal conditions with a comparison of Before and After DCP conditions.

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J l DESIGN. CHANGE TITLE:

REPLACEMENT OF SNUTDOWN C0OLING INVERTERS WITH TRANSFER SWITCHES NONNAL DPENATIONS OPERATING SDC !$0L. VALVES TO INITIATE SHUTDOWN COOLING DURING NORMAL OPERATIONS BEFORE DCP AFTER DCP

1. AT THE TRAIN 'A' 480 VAC SWITCHGEAR ROOM 1. AT THE TRAIN 'A' 480 VAC SWITCHGEAR ROOM SHUT SHUT THE MCC FEEDER BREAKER FOR HV-9337. THE MCC FEEDER BREAKER FOR HV-9337. NOTE:

NOTE: THIS BREAKER 15 NORMALLY OPEN TO MEET NORMALLY, THl$ BREAKER WILL BE MAINTAINED OPEN THE APPENDIX 'R' POWER LOCK 0UT REQUIREMENT TO MEET THE APPENDIX 'R' POWER LOCK 0UT REQ'T.

NO CNANGE

2. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR ROOM, 2. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR ROOM, SHUT SHUT CB-2 DN Y006 WHICH IS THE INVERTER THE REGULATING TRANSFORMER DUTPUT BREAKER AT CUTPUT BREAKER FOR HV 9377. THE SWITCH CABINET FOR HV-9377.

NOTE: THIS BREAKER !$ NORMALLY OPEN TO MEET N0fts NORMALLY. THIS BREAKER WILL BE MAINTAINED THE APPENDIX 'R' POWER LOCK 0UT REQUIREMENT OPEN TO MEET THE APPENDIX 'R' POWER LOCK 0UT REQ'T.

NO CNANGE

3. AT CGNTROL ROOM PANEL CR57. INITIATE VALVE 3. AT CONTROL ROOM PANEL CR57, INITIATE VALVE STROKE BY OPERATING THE ASSOCIATED SDC STR0KE BY OPERATING THE ASSOCIATED SDC !$0LAT!0N ISOLATION VALVE KEY-LOCK SWITCH. VALVE KEY-LOCK SWITCH.

NO CRANGE LOSS OF TRAIN 'A' OPERATING SDC ISOL. VALVES TO INITIATE SHUTDOWN COOLING DURING ABNORMAL OPERATIONS (LOSS OF 0FFSITE POWER WITH A CONCURRENT LOSS OF ONE ESF BUS). THE LOSS OF ONE ESF BUS RESTRICTS SHUTDOWN COOLING PATH TO THE 10" LINE, HV-9377 AND HV 9378 BEFORE DCP AFTER DCP

1. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR R00M. 1. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR ROOM, SHUT CB 2 ON Y006 WHICH 15 THE INVERTER OPERATE THE KIRK KEYS AT THE HV 9371 SWITCH OUTPUT BREAKER FOR HV-9377 CABINET AND RE.Pos! TION THE TRANSFER SWITCH 10 THE TRAIN 'B' FEEDER. SHUT THE REGULATING TRANSFORMER NOTE: THIS BREAKER IS NORMALLY OPEN TO MEET OUTPUT BREAKER. NOTE: NORMALLY. THIS BREAKER WILL  !

THE APPENDIX 'R' POWER LOCK 0UT REQUIREMENT BE MA!NTAINED OPEN TO MEET THE APPENDIX 'R' POWER l

LOCK 0UT REQUIREMENT ,

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2. AT C0NTROL ROOM PANEL CR57. INITIATE VALVE 2. AT CONTROL ROOM PANEL CR57, INITIATE VALVE STROKE STR0KE FOR HV-9377 AND HV-?178 BY OPERATING FOR HV 9377 AND HV-9378 BY OPERATING THE

! THE ASSOCIATED SDC !$0LATION VALVE KEV-LOCK ASSOCIATED SDC !$0LAT!0N VALVE KEY-LOCK SWITCH.

SWITCH.  ;

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r DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES LOSS OF TRAIN 'B' OPERATING SDC !$0L. VALVES TD INITIATE SHUTDOWN COOLING DURING ABNORMAL OPERATIONS (Loss 0F 0FFSITE POWER WITH A CONCURRENT LOSS OF ONE ESF BUS). THE LOSS OF ONE ESF BUS RESTRICTS SDC PATH TO THE 10' LINE. HV-9377 AND HV-9378 BEFORE DCP AFTER DCP

1. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR ROOM. 1. AT THE CHANNEL 'C' 125 VDC SWITCHGEAR ROOM SHUT SHUT CB-2 ON V006 WHICH IS THE INVERTER THE REGULATING TRANSFORMER OUTPUT BREAKER. NOTE:

OUTPUT BREAKER FOR HV-9377. NOTE: THIS BREAKER NORMALLY. THIS BREAKER WILL BE MAINTAINED OPEN TO IS NORMALLY OPEN TO MEET THE APPENDIX 'R' MEET THE APPENDIX 'R' POWER LOCK 0UT REQUIREMENT POWER LOCK 0UT REQUIREMENT NO CNANGE

2. AT CONTROL ROOM PANEL CR57. INITIATE VALVE 2. AT THE CHANNEL 'D' 125 VDC SWITCHGEAR ROOM.

STROKE FOR HV-9377 AND HV-9378 BY OPERATING OPERATE THE KIRK KEYS AT THE HV-9378 SWITCH THE ASSOCIATED SDC ISOLATION VALVE KEV-LOCK CABINET AND RE-POSITION THE TRANSFER SWITCH TO THE SWITCH. TRAIN 'A' FEEDER.

3. AT CONTROL ROOM PANEL CR57. INITIATE VALVE STR0KE l

FOR HV-9377 AND HV-9378 BY OPERATING THE ASSOCIATED SDC ISOLATION VALVE KEV-LOCK SWITCH.

NO CNANGE Alarm contacts will be provided with the new SDCS switch cabinets to input to the plant annunciator upon loss of power on the load side of the regulating transformer output breaker when the breaker is closed. Since the regulating transformer will be normally deenergized until required for operation of the SDCS isolation valves, the loss of power alarm scheme will be disabled when the output breaker is open.

Operator training will be required to address these changes. The required changes to the Shutdown Cooling System Description will be included in the DCP.

102. idaintenance Imoact l Removal of the SDCS Inverters will eliminate the existing preventative maintenance requirements for these devices.

Associated maintenance procedures will need to be revised accordingly. Manual transfer switches are historically reliable devices used throughout the industry for similar applications, including safety-related. Thus, this design change will produce a significant reduction in corrective maintenance activities related to power supplies to the SDCS isolation valves. The new transfer switches will require a surveillance program consistent with 3rograms existing for other similar Class IE manual transfer swittles installed at SONGS.

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• DESIGN CHANGE TITLE REPLACEMENT OF sNUTDOWN C0OLING INVERTERS WITH TRANSFER SWITCHES The regular maintenance requirements on these components will be I as prescribed by the supplier. Surveillance testing will be i required for verification of proper operation. l The switch cabinet vendor will provide a list of required spare parts in accordance with SONGS Mini-Specification S023-302-16.

Submittal of required spare parts into the maintenance program will be addressed in the DCP.

1D. Desian Criteria 1D1. -[gdes and Standards All the changes of the proposed modification will comply with the technical requirements of sections 8.1.4.3 and 8.3 of the SONGS l 2 & 3 UFSAR, Revision 12. Other specific codes and standards which apply:

1. IEEE 344-1975 Recommended Practices for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations

2. IEEE 379-1972 Application of Single Failure Criterion to Nuclear Power Generating Station Class 1E Systems

3. IEEE 384-1974 Criteria for Independence of Class 1E Equipment and Circuits L 4. IEEE 279-1971 Standard Criteria for Protection Systems for Nuclear Powered Generating Stations

5. IEEE 323-1974 Standard for Qualifying Class 1E l Equipment for Nuclear Power Generating Stations

6. UFHA Updated Fire Hazards Analysis 102. Reaulatory Reauirements

1. RG 1.75 Physical Independence of Electrical Systems, Rev. 1.

2. RG 1.89 Qualification of Class 1E Equipment for Nuclear Power Plants

3. RG 1.100 Seismic Qualification of Electrical and Mechanical Equipment for Nuclear Power Plants, Rev.1.

4. 10 CFR 50 Appendix A, General Design Criteria for Nuclear Power Plants

5. BTP RSB 5-1 Design Requirements of the Residual Heat Removal System PAGE 1 - 7

P DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN C0OLING INVERTERS WITH TRANSFER SWITCHES 1D3. Inout Parameter Reauirements Input parameters regarding equipment classification, seismic category, quality class, and environmental classification are as specified in the SONGS 2 & 3 UFSAR. This proposed modification does not represent any functional change to the current design basis of the Shutdown Cooling System.

1D4. Interface Reauirements The physical changes required by this proposed modification will be confined to the Trains A and B Class 1E Switchgear Rooms, the Channels C and D 125 VDC Switchgear Rooms, and tne corridor area at the Control Building 50' elevation. Existing cables and raceways from the Channels C and D Switchgear Rooms to the SDCS ,

valve operators and to the control circuit interfaces will be utilized to avoid adding extensive new raceway and cable.

Physical independence of Class 1E circuits will be maintained by use of- a new regulating transformer employed as an isolation device. Short runs of new cables from the Trains A and B Switchge6r Rooms will be routed to the Channels C and D 125 VDC Switchgear Rooms for the line side connections at the new manual transfer switch input breakers (Figure 4-2).

Operating Procedures for the alarm response to Inverter Trouble alarms at annunciator panel 57C will be revised, as will the annunciator engraving, to reflect modifications to the annunciating scheme.

105. Material Reauirements Material required for this modification shall be Safety Related, Quality Class II. Cabinets containing the following components will be installed in place of the existing SDCS inverters Y006 and Y007:

1. Three-pole, double-throw manual transfer switches with separation barriers between line side compartments.

2. Three-pole input and output circuit breakers installed in separate compartments.

3. Four kirk-key interlocks designed to prevent operation of the transfer switch while an input breaker is shut.

4. Terminal blocks,120 VAC control power tr2nsformers, and reversing motor starter contactors.

5. Regulating transformers.

9 PAGE 1 - 8

DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES These cabinets will be manufactured in accordance with applicable industry codes and standards as delineated in SONGS mini-specification S023-302-16.

New cables and conduits required for the feeders from the Motor Control Centers to the transfer switch input breakers will be a type and size in accordance with SONGS design standards for Class IE circuits.

E6. Plant Lavout and Arranaement Reauirements New switch panels will be installed at the present location of SDCS Inverters Y006 and Y007 after their removal. Minimal lengths of conduit will be installed from the Control Building 50' elevation Corridor to the Channels C and D 125 VDC Switchgear Rooms.

Therefore, this modification will not affect plant layouts and arrangements.

107. Environmental Condition.

The new switch panels will be installed in the 125 VDC Switchgear Rooms for Channels C and D. These rooms are located in the Control Building 50' elevation where the environmental conditions are mild. Therefore,10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, does not apply.

108. Safety Reauirements Since this modification wi',1 be performed in the Control Building 50' elevation, no special Radiological Safety Requirements are required for the instaliation of the manual transfer switch panels. Part of this modification will involve working near energized equi > ment. Therefore, appropriate caution shall be taken when wor <ing inside energized switchgear. Standard construction safety procedures shall be followed to prevent undue risk to the health and safety of the construction and operations personnel.

109. Quality Class and Seismic Cateaory The highest Quality Class and Seismic Category of work associated with this modification is Quality Class II, Seismic Category I.

This change is in accordance with the cuality classification of major plant structures, components, anc systems per Appendix 3.2A of the SONGS 2 & 3 UFSAR.

l PAGE 1 - 9

y DESIGN CHANGE TITLE:

REPLACEMENT OF $NUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES s

1D10. Other Related Criteria Fire Protection The Appendix R analysis postulates fires to the plant under normal operating conditions. Impact of the additional new cables for this modification within each Class IE Switchgear Room and Corridor areas at the control Building 50' elevation is bounded by the existing analysis. New cables to be added, which impact combustible loading, will be documented in the UFHA changes within the DCP.

The circuits for HV-9377 and HV-9378 are identified in the SONGS Appendix k Compliance Report as required for safe shutdown and have been analyzed for compliance to the separation criteria l established in 10CFR50, Appendix R, Section III.G. As documented 1 in the Safety Evaluation Report, SONGS considered hot shorts per the guidance provided in Generic Letter 86-10 for postulating shorting of power and control cables to valves which could result in spurious valve operation. Furthermore, this analysis evaluated spurious valve operation due to hot shorts and the i impact of such an event on i Branch Technical Position (plant shutdown BTP) RSB in shutdown 5-1, safe accordance with using natural circulation.

SDCS valves HV-9337 and HV-9377 are in parallel paths and are required to be maintained shut in order to isolate the Shutdown Cooling System from the RCS during normal operations. Per the Safety Evaluation Report, HV-9337 and HV-9377 are required to be Power Locked Out in order to prevent inadvertent opening of these valves which would result in a loss of coolant accident. Power Lockout is accom)lished for HV-9337 at the MCC feeder breaker.and forHV-9377attleSDCSInverter(Y006)outputbreaker.This modification will not affect the Power Lockout configuration for HV-9377 upon removal of Y006 since the new manual transfer switch cabinet will include an output breaker on the load side of the regulating transformer (Figure 4-2). During normal operations, this output breaker will provide the Power Lockout requirements under conditions identical to those currently specified in the Technical Specifications and Operating Instructions.

Therefore, this modification presents no adverse impact to the Fire Protection or Appendix R criteria. A Fire Protection Checklist will be included in the DCP.

RG 1.75. Physical Indeoendence of Electric Systems Presently, the circuits for valve HV-9377 are designated Channel C (power originating from the C Channel DC bus) and circuits for HV-9378 are designated Channel D (power originating from the D Channel DC bus).

i Under this proposed modification, the power supply for the valve motor operators and control circuits will originate directly from the 480VAC Class 1E Motor Control Centers, Trains A and B, respectively.

In order to minimize the impact of adding new cables and raceways, yet

! maintain the requirements of Reg. Guide 1.75 and IEEE 384-1974, a qualified isolation device will be included in the manual transfer 1

PAGE 1 - 10 l

(

l > I l

, DESIGN CHANGE TITLE: )

i REPLACEMENT Of SHUTDOWN COOLING INVERTERS WITH TRANSTER SWITCHES switch cabinet for each valve. Because of its current limiting i characteristics, the regulating transformer included in this modification will be utilized as an isolation device between the Train A or Train B power source and the Channel C or Channel D circuits which share the same raceways. Although each valve can receive power from a Train A or B )ower source, the regulating transformer allows those

! portions of tie circuits downstream of it to be designated as and remain with Train C and D circuits.

Additionally, a kirk-key interlock scheme will prevent cross-train interactions by restricting operation of the manual transfer switch to only times when both input breakers are open.

Security Criteria Security criteria are not affected by this modification.  ;

ID11. Environmental Reaulatory Reauirements This mdification will not create or add any new air pollution control, hazardous waste, or National Pollutant Discharge Elimination System i (NPDES) concerns to the existing environmental condition. Therefore, it does not require any non-radiological environmental permits.

1D12. Radioactive Waste Treatment Systems l

This modification does not change any radioactive waste treatment systems (liquid, gaseous, and quantities and personnel expo sure/orfrom solid). Norpreviously those does it change any release identified.

I i

1D13. Electrical Loads Each switching cabinet transformer shall be designed to start and )

operate a motor o)erated valve under the most limiting conditions of I open pressure loccing and locked rotor (with Limitorque Actuator No.

SB-1-15-1500) which has the following characteristics:

Motor size: 0.50 Hp nominal i Voltage: 460VAC Phases: 3 Closing time: 2-3 min FLA: 2.8 0 0.21 p.f. .

LRA: 9.0 0 0.69 p.f.

Speed: 850 rpm Start Torque 15 ft-lbs Run Torque 3 ft-lbs I

l l

PAGE 1 - 11

s

. DESIGN CHANGE TITLE:

DEPLACEMENT OF SNUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES l The electrical characteristics of the Ferro-Resonant Regulating Transformers are as follows:

Capacity (KVA) 7.5-10 KVA (Vendor shall determine actual rating based on the characteristics of

! the load listed in section 5.3. Short Circuit current limit shall be a minimum of 200% but no more than 250%.

Voltage (V) 480 A (primary) - 480Y(secondary)

Input voltage tolerance: +10%,-20%

Output voltage regulation: *S% no load to full load l Frequency 60HZ 15%, 30 Type Distribution},Ferroresonant, Class (AA/FA Indoor, insulation class H. 1.2KV, BIL 10KV, temp rise 80'C over 40*C, hot spot 110'C Removal of the SDCS Inverters Y006 and Y007 will reduce loading on the Class 1E Channels C and D batteries which will contribute to extending the discharge capacity of the batteries. Placing the motor and control power for HV-9377 and HV-9378 directly on the Class IE Motor Control

' Centers will not adversely affect diesel generator loading since motor operated valves are not considered a continuous load burden.

Listed below are the calculations which are affected by these changes and which will be revised in the DCP:

1. E4C-017 125 Volt Battery DC System Sizing

2. E4C-046 Reg. Guide 1.63 Implementation i

3. E4C-082 System Dynamic Voltages During Design Basis Acc.

4. E4C-086 SONGS 2BECAPandPSS/EDataDevelopment

5. E4C-087 SONGS 3BECAPandPSS/EDataDevelopment

6. E4C-088 Emergency Diesel Gen. Loading

7. E4C-090 Auxiliary System Voltage Regulation

8. E4C-092 Short Circuit Studies ,

9. E4C-102 GL 89-10 MOV Voltages During Design Basis )

Acc.

10. E4C-109 Class 1E Design Change System Protection i

11. E4C-112 Class 1E 480V MCC Protection

12. E4C-121 125 & 250VDC Power Cable Sizing Calculation j 1D14. Control Room Desian Standard for Human Factors l

This modification will not change the existing design of the Control l Room. Changes to alarms at annunciator panel 57C will be made to i reflect the new alarm circuit at the regulating transformer.

PAGE 1 - 12

r DESIGN CHANGE TITLE:

!* REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES 1D15. Reaulatorv Guide 1.97 Reauirement This design will not change any Regulatory Guide 1.97 Instrumentation l on the Instrument Report contained within the Nuclear Consolidated Data Base (NCDB) 90010A.

l 1E. License Document Chanae Summarv

1. Changes to UFSAR sections reflecting the replacement of Y006 and ,

YOO7 with manual transfer switches will be included in the DCP-. l

2. This modification does not decrease the effectiveness of the -

Security Plan or the Emergency Plan.

3. Changes to the UFHA at a result of this modification will be included in the DCP.

4. The SONGS 2 & 3 Operating License and Technical Specifications will require a change to remove reference to inverters as power supply sources to the SDCS isolation valves. Proposed Licensing ChangeNPF-10/15-490 addresses the required revisions.

5. The SONGS 2 & 3 Licensee Controlled Specifications (LCS) will be changed to add surveillance requirements for the new regulating i transformers and manual transfer switches. The LCS changes will be included in the DCP.

1F. Design Alternatives Following is a discussion of the four alternatives developed to resolve the problem of the SDCS Inverter unreliability due to fuse blowing occurrences. Alternative 4 was chosen as the best option due to economic benefits while continuing to maintain the design basis of the Shutdown Cooling System and complying with regulatory requirements.

Alternative 1: Replaca Inverters with Motor Generator Sets This option replaces the 30CS Inverters with qualified motor generator sets. A 5 or 7.5 HP motor to 2.5 or 5KVA generator would be adequate to '

meet the power requirements for the SDCS isolation valves HV-9377 and HV-9378. The M-G set peripherals would include a starter and control box. New cable and conduit and larger protection devices would be required due to the increase in running and in-rush current for the DC circuit. The increase in overall dimensions and weight will require modifying the base and supports. In addition, construction activities to divert air (reduce the air flow rate) from switchgear rooms 302A and 308A and increase the air flow rate to the inverter rooms 3108 and 310C (current room temperature approaching design limit) may be required.

l PAGE 1 - 13

, DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES I

j ADVANTAGES

• M-Gsetnotrequiredtooperatecontinuously/reductioninnormal heat load for room.

e Reliable e No input fuses to blow due to miscommutation of Silicon Controlled Rectifiers (SCR)

DISADVANTAGES

• Additional maintenance requirements.

• Noisy e Rotatingmachinery/missilehazard

• Additional operator actions required to operate M-G set, j e High Cost Alternative 2: Replace Existing Inverters with Larger Inverters This option replaces the existing 5KVA inverters with larger capacity 7.5 or 10KVA Inverters to meet the specifications of the existing M0V's HV-9377 and HV-9378. Increasing the KVA capacity of the inverter is not expected to require any major electrical cabling rework (terminations only).However,theinputbreakermayincreaseinsize.Alarger inverter will result in a change to the inverter dimensions. Inverter mounting plates and supports will need to be modified. In addition, activities to divert air (reduce the air flow rate) from switchgear i rooms 302A and 308A and increase the air flow rate to the inverter rooms 310B and 310C will be required (current room temperature approaching designlimit).

ADVANTAGES e Operations and Maintenance familiarity with equipment.

• Static device, relatively low maintenance o Reliable o Easter Installation PAGE 1 - 14

.o l ,

DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES l

DISADVANTAGES e Must operate continuously / additional heat load l e Ideally, an inverter should have a continuous load e Ferro resonant type inverter can be noisy duc to output transformer e Failure of logic boards or SCR/ diodes will cause breaker or fuse to open, o High Cost Alternative 3: Replace existing AC motors at HV-9377 and HV-9378 with DC motors This option would require obtaining an environmentally qualified DC motor / actuator or DC motor to fit the existing actuator for the isolation valves HV-9377 and HV-9378. A DC motor could be powered directly from the 125 VDC bus. However, there are several major disadvantages to this option that makes it not feasible. The first concern has to do with qualifying the motor for inside containment use due to the fact that DC motors require commutation circuits or brushes to transmit current. Commutation circuits and brushes are susceptible to moisture, steam, and corrosive contamination effec.s of LOCA-type events.

An in-house qualification effort would be labor-intensive and costly.

Approximately 8 to 10 months would be required to develo) the test plan and prepare the equipment for qualification tests with t1e possibility of failure. In addition, the existing vendor does not have a suitable qualifiedDCmotor/actuatorreplacement.

ADVANTAGES e No intermediate device required for operation of the valves.

• Reliable DISADVANTAGES e Additional training for DC M0V maintenance o Qualified DC motors not available o EQ Risk PAGE 1 - 15

I l

• DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES Alternative 4: Train A and B MCC Feed to the Valves

! This option would eliminate DC po er to the inverters and instead feed the isolation valve motors directly from a Train A or Train B MCC via a manual transfer switch. A manual transfer switch would be installed in each of the respective shutdown cooling inverter rooms. MCC feeds from i

each train would feed the manual transfer switches through input breakers. The transfer switch would feed a regulating transformer (used for voltage regulation and as a Reg. Guide 1.75 isolation device), a control transformcr for the existing valve control circuit, and then the isolation valve motor. The input to the regulating transformer will be either Train A c: Train B, 3 phase, 480V power as determined by the position of the transfer switch. The output of the regulating transformer will be Train C (for HV-9377) or Train D (for HV-9378) 3 l phase, 480V power. No new cable would be required from the new switch i panel to valve motors because existing cable and routing could be '

utilized. Kirk Key interlocks will be provided at the transfer switch  :

and the associated input breakers within the switch cabinet so that only I one of the incoming power feeds (either Train A or Train B) can be energized at any given time. The regulating transformer will be sized to  !

provide an MOV motor terminal voltage equal to or better than the existing configuration.

ADVANTAGES l

e No Inverter or M-G set maintenance.

e Voltage regulation equal to or better than the existing regulation e Reduced load on the Class 1E DC system (batteries) e Reliable, direct AC power feed.

• Reduced heat load e Low cost DISADVANTAGES

• Additional operator training required for some operation scenarios, o Some new equipment to be installed with new surveillance requiraments.

l PAGE 1 - 16

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0 l PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

PEPJ.ACEMENT OF SHUTDOWN COOLING INVFRTERS WITH TRANSFER SWITCHES NOTE:

The following preliminary draft 10CFR50.59 Safety Evaluation is the most current va sion to date. As the proposed design change is processed through the SCE snter.: from the its current Concep.ual Engineering Package to an approve Design Change Package, this 10CFR50.59 Safety Evaluation will be reviewed, revised, and updated several times. Currently the preliminary evaluation does not indicate the proposed change involves an unreviewed safety question. However, if in the final analysis, SCE determines this design change will not pass the 10CFR50.59 Safety Evaluation, SCE will submit the proposed design for NRC approval.

SAFETY ANALYSIS

1. May the proposcd change increase the probability of occurrence of an accident previously evaluated in the Updated Final Safety Analysis Report (UFSAR)?

No. This design change affects the power to two of the four shutdown cooling suction isolation valves and the areas and raceway in which the changes are made. The design continues to supply control and instrumentation circuits from battery-backed sources. Electrical separation is provided in accordance with the assumptions in the UFSAR.

Static transfer switches (" Kirk-Key Interlocks") between redundant Class 1E divisions have been identified as a qualified isolation device and are in use elsewhere in the SONGS design. The use of regulating transformers as qualified isolation devices is consistent with the SONGS commitment to Regulatory Guide 1.75, Revision I since the transformer accomplishes its function to maintain isolation by limiting fault current and by not relying on fault current to activate an interrupting device.

The transfer switch is a three position mechanical switch that is normally off and may cnly be selected to one input at any one time. In addition to this, the use of Kirk-Key ir.terlocks to prevent operation of the transfer switch while an input breaker is shut, along with the protection coordination with the Motor Control Center feeder breakers, ensures no common-mode failure mechanism exists which would cause a loss of both Trains A and B due to a fault in the power or control circuits of the isolation valves. ,

Assumptions in the UFSAR regarding the integrity of the reactor coolan;.

system pressure boundary, the ability to achieve and maintain safe shutdown, accident precursors, and the ability to mitigate the consequences of design basis accidents that are related to the o)erability and functionality of these valves are met by the design clange without an increase in either failure to actuate or spurious operation frequencies over that of the base design.

A. The evaluations of the design change impacts related to the integrity of the reactor coolant pressure boundary are as follows:

PAGE 2 - 1 a

PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES

1. The ability of the valves to remain open at icw Reactor Coolant System (RCS) tem)eratures to maintain the path co the LTOP relief valve is uncianged from that described in the UFSAR. The valves are motor-operated, fail-as-1s, and will have power to their operators locked out if only a single flow path to the LTOP relief is available. Therefore, the frequency of low tem)erature overpressurization of the RCS has not increased over t1at assumed in the UFSAR

2. There is no impact upon UFSAR assumptions related to intersystem LOCA as electrical separation will assure that adequate redundant isolation interlocks for the valving high to low pressure interface are maintained. Interlock functionality is not required to be maintained once the plant has reached shutdown cooling entry conditions, and the UFSAR and Technical Specifications assume that the interlock is removed prior to entering shutdown cooling. Therefore, the frequency of intersystem LOCA has not increased over that assumed in the UFSAR.

B. The evaluations of the design change impacts related to achieving and maintaining safe shutdown are as follows:

1. The reliability of shutdown cooling valve operability and control circuit o)erability will be increased by removal of the inverter and lence removing inverter fuse failure-induced inoperability. The regulating transformer design will provide voltage somewhat above that assumed in the MOV setpoint program 2HV9378)(460V so valve operator - see sectionshould performance 5.0 of Calculation become even more M-8910-SP-reliable after the chanae. The time period during which valve operability will be assured is increased by the removal of valve power as a load upon their respective station batteries.

2. The ability of the plant to comply with the requirements of NRC Branch Technical Position RSB 5-1 will be improved as long term battery ca) ability requirements have been reduced by providing the a)ility to power these valves from Load Group 1 or 2 and not a battery. In Section 5.4.3 of the Safety Evaluation Report (2 requirement for remo/1/81), te operation the of NRC concludedcooling the shutdown that the RSB 5-1 system was met by limited action outside the control room because:

" Power restoration is required prior to initiating the use of the system for shutdown cooling. This is done in the motor control center which is immediately above the control room. This area is remote from the process piping and is in a low radiation area. The action required is of short duration and repeated access is not required."

Operator access outside the control room will be required to operate the transfer switches. The transfer switches and PAGE 2 - 2

PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTD0WN COOLING INVERTERS WITH TRANSFER SWITCHES their kirk key interlocks are located in the same area as the feeder breaker. This meets the RSB 5-1 scenario requirements since operating the transfer switch and kirk key interlock is part of a process of restoring power to these normally power-locked-out valves and is consistent with the action outside the control already required and approved by the NRC. The motor operators are small loads (0.5 HP) and do not challenge Load Group 1 or 2 capacity since high pressure safety injection and containment spray loads will not be present when these valves are operated in the RSB 5-1 scenario. Therefore, the pro)osed design will not increase the frequency of valve ino) era)1lity over that assumed in the UFSAR and thus the pro) ability of an inability to reach cold shutdown has not increased over that assumed in the UFSAR.

C. The evaluations of the design change impacts related to systems identified as precursors to design basis events or that are required to mitigate the consequences of design basis events are as follows:

1. Increase in Heat Removal by the Secondary System: The design change does not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to operate to mitigate the i consequences of the event, other than the manual operator '

action required to provide entry to cold shutdown following the event. Electrical se)aration is provided in accordance with the assumptions in t1e UFSAR, ensuring that there are no adverse im) acts upon other systems that could be used to mitigate tie event. Therefore, the assumptions of the safety 1 analyses related to increases in heat removal by the secondary system are validated and there is no increase in the probability of anticipated operational occurrences, materate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

2. Decrease in Heat Removal by the Secondary System: The design change does not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to operate to mitigate the consequences of the event, other than the manual operator action required to provide entry to cold shutdown following the event. Electrical se)aration is provided in accordance with the assumptions in tie UFSAR, ensuring that there are no adverse im) acts upon other systems that could be used to mitigate t1e event. Therefore, the assumptions of the safety analyses related to decreases in heat removal by the secondary system are validated and there is no increase in the probability of anticipated operational occurrences, moderate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

3. Decrease in Reactor Coolant Flowrate: The design change does PAGE 2 - 3

1 l

3 PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

REPlACWENT Of SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to operate in order to mitigate the consequences of the event, other than the manual operator action required to provide entry to cold shutdown following the event. Electrical se)aration is provided in accordance with the assumptions in tie UFSAR, ensuring that there are no adverse im) acts upon other systems that could be used to mitigate tie event. Therefore, the assumptions of the safety analyses related to decreases in the reactor coolant flowrate are validated and there is no increase in the probability of anticipated operational occurrences, moderate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

4. Reactivity and Power Distribution Anomalies: The design change does not alter structures, systems, or components that are precursors to the event. The valves and their power {

supplies are not needed to operate in order to mitigate the I consequences of the event, other than the manual operator actiu required to provide entry to cold shutdown following the event. Electrical se)aration is provided in accordance with the assumptions in t1e UFSAR, ensuring that there are no adverse im> acts upon other systems that could be used to mitigate tie event. Therefore, the assumptions of the safety analyses related to reactivity and power distribution anomalies are validated and there is no increase in the probability of anticipated operational occurrences, moderate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

5. Increase in Reactor Coolant System Inventory: Valve operation when the RCS is below SDCS design pressure is normal and results in no increase in anticipated operational occurrences above that already considered in the UFSAR. Valve operation when the RCS pressure is greater than the SDCS design pressure would result in a derease in RCS inventory. Therefore, the assumptions of the ufety analyses related to increases in the reactor coolant system inventory are validated and there is no increase in the probability of anticipated operational occurrences, moderate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

l l 6. Decrease in Reactor Coolant System Inventory: There is no  ;

impact upon UFSAR assumptions related to intersystem LOCA as l electrical separation will assure that adequate redundant isolation interlocks for the valving high to low pressure  !

interface are maintained. Interlock functionality is not required to be maintained once the plant has reached shutdown cooling entry conditions and the UFSAR and Technical Specifications assume that the interlock is removed prior to i entering shutdown cooling. Electrical separation is provided PAGE 2 - 4 j

l'

/

PRELIMINARY ENGINEERING DESIGN PROGRAM i 10CFR50.59 SAFETY EVALUATION ESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES in accordance with the assumptions in the UFSAR, ensuring that there are no adverse impacts u)on other systems that could be used to mitigate the event. Tierefore, the frequency of intersystem LOCA has not increased over that assumed in the UFSAR. Therefore, the assumptions of the safety analyses related to the spectrum of LOCAs are validated and there is no increase in the probability of anticipated operational ,

occurrences, moderate frequency incidents, infrequent I inc1 dents, or limiting faults in this category from that described in the UFSAR.

7. Fuel Handling Accidents: The design chang: does not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to o)erate to mitigate the consequences of the event, other than tie manual operator action required to provide entry to cold shutdown following the event. Electrical separation is provided in accordance with the assumptions in the UF5AR, ensuring that there are no adverse impacts u)on other systems that could be used to mitigate the event. Tierefore, the assumptions of the safety analyses related to fuel handling accidents are validated and there is no increase in the probability of anticipated operational occurrences, moderate frequency incidents, infrequent incidents, or limiting faults in this category from that described in the UFSAR.

8. Anticipated Transients Without Scram (ATWS): The design change does not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to operate to mitigate the consequences of the event, other than the manual operator action required to provide entry to cold shutdown following the event. Electrical se)aration is provided in accordance with the assumptions in tie UFSAR, ensuring that there are no adverse im) acts upon other systems that could be used to mitigate tie event. Therefore, the assumptions of the safety analyses related to ATWS are validated and there is no increase in the probability of limiting faults in this category from that described in the UFSAR.

9. Asymmetric Cooldown: The design change does not alter structures, systems, or components that are precursors to the event. The valves and their power supplies are not needed to

o)erate to mitigate the consequences of the event, other than I

tie manual operator action required to provide entry to cold l shutdown following the event. Electrical separation is provided in accordance with the assumptions in the UFSAR, ensuring that there are no adverse impacts u)on other systems that could be used to mitigate the event. Tierefore, the assumptions of the safety analyses related to asymmetric cooldown are validated and there is no increase in the probability of moderate frequency incidents in this category from that described in the UFSAR.

l PAGE 2 - 5 l

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1 PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

REPLACEMENT 0F SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES

10. Station Blackout: HV-9377 and HV-9378 are not credited in the Station Blackout Analysis. The ability of the station to cope with blackout is unaffected by this change. Electrical separation is provided in accordance with the assumptions in the UFSAR, ensuring that there are no adverse impacts upon other systems that could be used to mitigate the event.

A blackout that occurs while the auxiliary feedwater system and atmospheric dump valves are providing decay heat removal does not require the actuation of shutdown cooling system and therefore does not require that these valves be operated. A blackout that occurs while the SDCS is providing decay heat removal does not require that the valves be closed. If the operator maintains RCS pressure below about 408 psia at the LTOP valve maintaied)d.e., stays below

, the SDCS suction440 F if saturation isolation is need to valves do not be closed. Only if RCS 3ressure exceeds this value would an operator need to close tie valves to prevent loss of RCS inventory.

This design change does not preclude manual action inside containment to open the valves, and meet the assumptions of the analysis submitted to the NRC in response to Generic Letter 81-04 (Letter, Baskin to Miraglie, 8 The analysis described that the operator wouldaintain m/31/81).

a sufficiently low RCS temperature (<385 F) that valve operation would not be expected to be recuired, but would be accomplished locally, if needec . Hence, the assumptions of the safety analyses are met and there is no increase in the frequency of a blackout event over that assumed in the UFSAR nor is there the possibility that a more challenging design basis accident sequence needs to be considered. Therefore, the assumptions of the safety analyses related to station blackout are validated and there is no increase in the probability of limiting faults in this category from that described in the UFSAR.

Therefore, the proposed change does not increase the probability of occurrence of an accident previously evaluated in the UFSAR.

2. May the proposed change increase the consequences of an accident previously evaluated in the UFSAR7 No. Assumptions in the UFSAR regarding the integrity of the reactor coolant system pressure boundary, the ability to achieve and maintain safe shutdown, and the ability to mitigate the consequences of design basis accidents, that are related to the operability and functionality of these valves or the separation between structures, systems, and components, are met by the design change. System operability assumptions of the safety analyses are met, as described in the responses to question 1, and there is no possibility that a more PAGE 2 - 6

t PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TIILfa REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHE1 challenging design basis accident sequence than that assumed in the UFSAR could develop.

Radiological consequences of UFSAR accident analyses will be unchanged as the proposed change does not: 1) change event frequencies such that the event would require reanalysis with revised source term assum)tions (e.g., iodine spiking), or 2) degrade the assumed performance of )asic accident mitigation structures, systems, and components as described in the UFSAR. Thus, the change in power supply to the valves does not increase the consequences of an accident previously evaluated in the UFSAR.

3. May the proposed change increase the probability of occurrence of a malfunction of equipment important to safety evaluated previously in the UFSAR7 No. The design continues to supply Class 1E motive power to the SDCS valves. The reliability of shutdown cooling valve operability and control circuit operability will be increased by removal of the inverter l l and hence removing inverter fuse failure-induced inoperability.

l The ability of the plant to comply with the requirements of NRC Branch Technical Position RSB 5-1 will be improved as long term battery capability requirements have been reduced by providing the ability to power these valves from Load Group 1 or 2 and not a battery. The motor l operators are small loads (0.5 HP, each) and do not challenge Load Group 1 or 2 capacity since high pressure safety injection pump (600 HP, each) i and containment spray pump (500 HP, each) loads will not be present when

! these valves are operated in the RSB 5-1 scenario. The ability of the valves to remain open at low RCS temperatures to maintain the path to the LTOP relief valve is unchanged from that described in the UFSAR.

The change will also allow disconnection of the inverters, reducing heat loads during normal, post-accident, and station blackout conditions.

Electrical separation is provided in accordance with the assumptions in the UFSAR, ensuring that there has not been an increase in the likelihood of interactions between circuits than that are already analyzed in the original design and re)orted in the UFSAR. Therefore, the change does not increase the proba)ility of occurrence of a malfunction of equipment important to safety evaluated previously in the UFSAR. ,

1

4. May the proposed change increase the cansequence of a malfunction of I equipment important to safety evaluated previously in the UFSAR7 i No. Electrical separation is provided in accordance with the assumptions in the UFSAR, ensuring that there has not been a change in the nature of the interactions between circuits than that are already analyzed in the original design and reported in the UFSAR. Design separation provisions provide conservative barriers to the propagation PAGE 2 - 7 <

9 PRELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUATION ESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER. SWITCHES of the equipment malfunctions and their consequences. The redundancy of the power supply ensures that the consequences of either a Load Group 1 or 2 malfunction does not prevent initiation of shutdown cooling.

Therefore, the design change does not increase the consequence of a malfunction of equipment important to safety evaluated previously in the UFSAR.

5. May the proposed activity create the possibility of an accident of a different type than previously evaluated in the UFSAR?

No. The change modifies power su) ply characteristics, only. Power is a support element of the design. T1e proposed change will not increase the probability of an LTOP or intersystem LOCA rvent above that assumed in the UFSAR, as described in the response to question 1 of this  !

evaluation. Electrical separation ensures that any single failure of a  !

load group or channel will not propagate to a redundant load group or  !

channel. Electrical separation is maintained and these changes do not modify system operatir,g characteristics. Therefore, this design change '

does not create the possibility of an accident of a different type than previously evaluated in the UFSAR.

6. May the proposed activity create the possibility of a malfunction of equipment important to safety of a different type than any previously ,

svaluated in the UFSAR?

No. The change modifies power supply characteristics, only. Power is a support element of the design. Electrical separation is provided in accordance with the assumptions in the UFSAR, ensuring that there has not been a change in the nature of the interactions between circuits than that are already analyzed in the original design and reported in the UFSAR. Design separation provisions provide conservative barriers to the propagation of the equipment malfunctions and their consequences.

The redundancy of the power supply ensures that the consequences of either a Load Group 1 or 2 malfunction do not prevent initiation of shutdown cooling. Therefore, the design change does not create the possibility of a malfunction of equipment important to safety of a different type than any previously evaluated in the UFSAR.

PAGE 2 - 8

.i i

PRELIMINARY ENGINEERING DESIGN PROGRAM l 10CFR50.59 SAFETY EVALUATION DESIGN CHANGE TITLE:

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES i

7. Does the proposed activity reduce the margin of safety as defined in the basis for any technical specifications?

No. There is no Technical Specification or Licensee Controlled Specification (LCS) that requires that the valves be operated solely from battery power. The Bases to Technical Specification 3.8.4 describes that the SDCS valve inverter receives DC power, but this does j not establish a margin of safety with respect to diversity. Diversity '

is satisfied by two independently-powered, normally-closed, fail-as-is isolation valves The only margin of safety for this basis is related to the capability of the battery-powered DC system to accommodate the loads. By removing the valve power supply from the batteries, the i battery margin is increaseo. j l

UFSAR Section 7.6.1.1.2.F requires that power be locked out from at least -one valve in each flow path of series valves when RCS pressure is greater than SDLS design pressure, however, there is no Technical l Specification or LCS that requires that power be removed from the valves during power operation. The design change does not impair the ability to remove power from the valves.

LCS 3.5.101.1 specifies that the pressurizer high pressure interlock be o)erable to prevent the valves from opening. This change does not alter tie effectiveness of this interlock.

There will need to be a change to Technical Specification SR 3.4.12.1.4 (Licensing Document Change PCN 490) to clarify how power to the valves is locked out - at the MCC, not the inverter breaker during shutdown cooling operation. The bases for this section relate to low temperature overpressure protection and are related to verifying u at )ower cannot ,

be inadvertently applied to close the valves and isolate t1e LTOP relief '

valve. The change does not alter the design protection against LTOP events.

The motor operators are small loads (0.5 HP) and do not challenge Load Group 1 or 2 capacity since high pressure safety injection and l containment spray loads will not be present during normal operation or l when these valves are operated in the RSB 5-1 scenario. Inasmuch as these motor loads are manually energized, there is no change to the starting and loading analysis and thus the requirements of each of ihe i

surveillances for LCOs 3.8.1 and 3.8.2 continue to demonstrate that

diesel generator operability is maintained.

Therefore, the change does not reduce the margin of safety as defined in the basis for any technical specifications.

r PAGE 2 - 9

i.

ERELIMINARY ENGINEERING DESIGN PROGRAM 10CFR50.59 SAFETY EVALUA110N 1

bESIGN CHANGE TITLE: )

REPLACEMENT OF SHUTDOWN COOLING INVERTERS WITH TRANSFER SWITCHES

3. LICENSE AND DESIGN DOCUMENT IMPACT A. Operating License - see section IE.

i B. UFSAR/UFHA/SP/EP-seesectionIE.

C. Design Criteria - see section ID 1 1

D. System Description Changes - not required for CEP; to be included in DCP E. Design Bases Document Changes - not required for CEP; to be included in DCP )

F. General Design Criteria Changes - see section 1D.

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