ML20217P491
| ML20217P491 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/31/1998 |
| From: | Kofron K COMMONWEALTH EDISON CO. |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-98-0104, BYRON-98-104, NUDOCS 9804100112 | |
| Download: ML20217P491 (132) | |
Text
I Commonwealth I Aliwan Compan) ll) ton Generating Station 4 450 Nonh German Church Road ll) ton. II. 61010 9791
- Tel H142M54 41 i
March 31,1998 1 l l LTR: BYRON 98-0104 FILE:
{
i 2.7.611 l
l Office of Nuclear Reactor Regulation
- U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4
Attention: Document Control Desk
SUBJECT:
Byron Station Units 1 and 2 10 CFR 50.59 Annual Report NRC Docket Nos. 50-454 and 50-455 l
Pursuant to the requirements of 10 CFR 50.59 (b)(2), Byron Station is providing the required annual report for Facility Operating License Nos. NPF-37 and NPF-66.
l This report is being provided for the 1997 calendar year and consists of descriptions and safety evaluation summaries for changes to the facility as described in the j l safety analysis report. No tests or experiments governed by paragraph (a) of 10 l CFR 50.59 were performed. Also included as part of this report are changes made i to features of the fire protection program not previously presented to the NRC Staff.
l Please direct any questions regarding this submitta'. to Laurie Lahti, Regulatory ,
Assurance Department, at (815) 234-5441 extension 2852. (
. j K. L. Kofron -
Station Manager Byron Nuclear Power Station l KLK/LAL/rp Attachment cc: Senior Resident inspector - Byron Byron Project Manager - NRR g Regional Administrator - Rill 9804100112 980331 PDR ADOCK 05000454 l R PDR (p set >yiirs$80104 wpr; i A Unisom Compan)
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Byron Nuclear Power Station 10 CFR 50.59 Summary Report 1997 NRC Docket Nos. 50-454 and 50-455 '
License Nos. NPF-37 and NPF-66 i
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QESIGN CHANGE PACKAGES (DCPs)
- 1. DCP 8902463
- 2. DCP 9600167
- 3. DCP 9600206
- 4. DCP 9600308
- 5. DCPs 9600373,9600374,9700076, and 9700079
- 6. DCPs 9600387 and 9600390
- 7. DCP 9700133
- 8. DCP 9700294
- 9. DCP 9700318
- 10. DCP 9700331
- 11. DCP 9700333
- 1. DRP 64)66
- 2. DRP 6-072
- 3. DRP 6-073
- 4. DRP 6-077
- 5. DRP 6-085
- 6. DRP 64)86
- 7. DRP 6-087
- 8. DRP 6-094
- 9. DRP 6-101
- 10. DRP 6-103
- 11. DRP 6-104
- 12. DRP 7-001
- 13. DRP 74)04
- 14. DRP 7-005
- 15. DRP 7-010
- 16. DRP 74)11
- 17. DRP 7-012
- 18. DRP 74)l4
- 19. DRP 7-015
- 20. DRP 7-018
- 21. DRP 7-020
- 22. DRP 7-023
- 23. DRP 7-025
- 24. DRP 7-032
- 25. DRP 7-034
- 26. DRP 7-035
- 27. DRP 7-040
- 28. DRP 7-041
- 29. DRP 74)44 l
- 33. DRP 7 049
- 34. DRP 7-052
- 35. DRP 7-057
- 36. DRP 7-061
- 37. DRP 7-063 l
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- 38. DRP 7-065 -
- 41. DRP 7-081
- 42. DRP 7-085
- 45. DRP 7-097
- 46. DRP 7-100
- 47. DRP 7-114 -
- 48. DRP 7116
- 49. DRP 7117
- 53. DR!' 7-130
[ 56. DRP 7-139
! 59. DRP 7-144
- 60. DRP 7-147
FIRE PRO 1ECTION REPORT DRAFT REVISION PACK AGES (FDRP)
. 1. . FDRP 17-046 l
- 2. FDRP 18-004
. 3. FDRP 18-015
- 4. FDRP 18-028
- 5. FDRP 18-031 l 6. FDRP 18-035 l 7. FDRP 18-037
- 8. FDRP 18-039 l
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, IESTS AND EXPERIMENTS NOT DESCRIBED IN THE SAR (SSPs) l 1. SPP 97-007 l 2. SPP 97-017
- 3. SPP 97 020 l 4. SPP 97-021
- 5. SPP 97-024
- 6. SPP 97-031
- 7. SPP 97-075
- 8. SPPs97-082 through 97-084 9.' SPP 97-093
- 10. SPP 97-106 -
- 11. SPP 97-118 .
- 12. SPP 97-127 l
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- 13. SPP 97-129
- 14. SPP 97-131
- 15. SPP 97-137
- 16. SPPs97-150 and 97-151
- 17. SPP 97-156 ADMINISTRATIVE TECHNICAL REOUIREMENTS (ATR) f'HANGES
- 1. ATR Amendment 11
- 2. ATR Amendment 12 DOC'2 MENT CHANGE REOUES.ISJDCR)
- 1. DCR 970047
- 2. DCR 970048
- 3. DCR 970063
- 4. DCR 970093
- 5. DCRs 970247 and 960026
- 6. DCR 970291 WORK REOUESTS
- 1. 940014881 through 940014890
- 2. 97(X)09531
- 3. 970019152
- 4. 970027541 EROCEDURE CHANGES l
l 1. BAP 2000-3
- 2. BOP RC-4a (Temporary)
- 3. BOP RH-6
- 4. 1/2 BOS SX-sal l S. 1/2 BVS 1.3.4.lb l 6. 1/2 BVS DG-8 OTHER CHANGES j
- 1. Setpoint/ Scaling Change Request 97-016 I I
- 2. Sctpoint/ Scaling Change Requests97-028 and 97-031 )
- 3. Sctpoint/ Scaling Change Requests97-041 and 97-042 l
- 4. On-site Resiew 97-003 1 6G-97-0260
- 6. NDIT BYR97-327
- 7. Postaccident Sampling Commitment
- 8. Out-of-Service 940007543 3
DCP 8902463 DESCRIFrTION:
This design change upgraded the spent fuel pool bridge crane by replacing the chainfall-driven trolley and hoist with two new hoists mounted on motorized trolleys, and installing movable integrated control stations with digital position and load cell weight readouts. Each hoist has an integral load sensing system. The controller replaced existing hardwired relay logic that was used in the original control system. The new controls have variable-speed motor drives for all motors. The control system uses a dedicated microprocessor based controller to control machine and momtor safety interlocks. An alphanumeric display screen on the main control cabinet provides operator interface functions. The bridge, trolley, and hoist are operated using a control pendant station with joysticks, including easily read position and load displays. The UFSAR was revised via DRP 6-030 to reflect this design change.
SAFETY EJAL_ VAT 10N
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safe:y analysis report is not increased because the cranc load bearing components are not changed. The original safety features of the system were maintained and the functional integrity of the cranc, trolley and hoist were improved by the upgrade.
The design used the existing cranc and handling tools.
There will be no effect on the probability of a dropped fuel assembly accident. This change improved the control of the cranc and, therefore, should decrease the probability of a fuel handling accident.
The postulated accident would produce radioactive gasses that would cornbine with the air above the i fuel pool. The fuct handling building ventilation system is designed to mitigate the effect of the radioactive release. The fuel assembly is assumed to be damaged already; therefore, the consequences remain bound by those analyzed. This change does not affect the ventilation sy stem in any way, so i the consequences are not changed. It also does not increar.c the severity of the accident.
- 2. The possibility for an accident or malfunction of a di!Terent type than any evaluated previously in the '
safety analysis report is not created because the functional integrity of the crane, trolley and hoist has been maintained. Thus, the change does not adversely impact accident-related systems, stmetures, and components (SSCs). The addition of the upgrade control does not introduce any adverse interactions between any SSCs. Failures that would cause fuel assembly damage remain the same.
The fuel assembly is assumed to be damaged, so the existing analysis is bounding.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon uhich Technical Specifications are based.
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r 1 DCP 96C3167
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l l PESCRIPTION:
l DCP 9600167 lowered the oil level sight glass for essential scrsice water system (SX) cooling tower fan OSX03CE to make the oil level more visible. The UFSAR was revised to replace Figure 9.2-24 with the corresponding vendor drawing via DRP 7-029.
I SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety presiously evaluated in the safety analysis report is not increased because the SX i cooling tower fan cannot create or initiate an accident. The new configuration allows the operator to monitor the oil level with no effect the opera' ion of the SX cooling tower fan or the ultimate heat sink. Therefore, the SX system will continue to provide cooling as designed following an accident.
Hence, the consequences of the accident are not affected by this modification.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because no new failure modes have been created as a result of relocating the sight glass.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon w hich Technical Specifications are based.
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DCP 9600206 DESCRIPTION:
This design change brought a new Division 21 control power cabic to power the Unit 2 Fire Hazard Panel and installed a new channel "A" Postaccident neutron monitor (PANM) at this panel. Previously, there was only Division 22 control power and only the channel B PANM available at this panel. This design change was installed as a corrective action from LER 454-95405. The Dyron Fire Hazard and Safe Shutdown Analyses in Sections 2.2,2.3, and 2.4 of the Fire Protection Report were revised to reflect these design changes via FDRP 18-010.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes make insignificant changes to combustible loading in the affected fire zones. The changes do not affect the functioning of existing equipment on the fire hazard panel. No fire protection Report Fire Hazard Analysis conclusions are affected in any way. The safe shutdown analysis conclusions are enhanced because additional redundancy of power supplies and neutron monitoring capability is being added.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the new cable and neutron monitor is designed and installed per approved scismic and electrical design criteria. The redundant power supplies and neutron monitors are kept isolated from cach other so that the failure of train or channel cannot affect i the other.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based.
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DCP 9600308 l l
l DESCRIPTION: ]
l This design change allowed generic replacement of several grades of carbon steel with corresponding types of chrome-molybdenum stccl. These substitutions were limited to non-safety-related ponions of the following systems that are governed by piping design tables 002BB,100BB,102BB,105BB,300BB,302BB,303BB, 604BB, 905BB, 907BB,1505BB and " WEST": auxiliary steam, condensate booster, condensate, gland steam, heater drain, main steam, turbine building equipment drains, control room HVAC, radwaste and remote shutdown panel HVAC, laboratory HVAC, senice building HVAC, turbine building vent, miscellaneous auxiliary ventilation, auxiliary building equipment drains, and nonessential senice water.
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I SAFETY EVALUATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment j important to safety presiously evaluated in the safety analysis repon was not increased because the propenics of the substitute material are the same or better the carbon steel. These propenics include ,
material allowable stress and coefTicient of thermal expansion. Therefore, stresses in the pipe were j not increased and the material's ability to withstand the stress was not reduced. The probability of a l failure due to wall thinning is reduced due to the greater resistance to crosion/ corrosion exhibited by the chrome-molybdenum material. The material suintitution does not increase the consequences of a steam line break since there is no impact on the locatioef any pipelines and the process parameters
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are not changed. Any piping failure is bounded by the existing UFSAR accident analysis. j
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis repon is not created because the substitute materials have the same allowable stresses as the corresponding carbon steel material previously installed. The coefficients of thermal expansion are also the same; therefore, stresses due to pipe thermal expansion do not increase. The probability of a failure due to wall thinning is reduced due to the greater resistance to crosion/ corrosion exhibited by the chrome-molybdenum material, The location of postulated high-energy line breaks are selected at terminal ends and at cach fitting, welded attachment or valve, or at locations w here the sum of Equation 9 and Equation 10 stresses (Refer to ASME Section 111 Subsection NC/ND-3652) exceed
.8(1.2Sh + SA). Since the material allowable stresses are the same or better, there are no additional postulated line break locations.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based. l l
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l DCPs 9600373. 9600374. 9700076. and 9700079 l
l DESCRIPTION:
The changes upgraded the fuel transfer drive system from a chain drive to a winch drive system uith variabic-speed DC drive motors. This change improved the safety, cfTiciency, reliability, and maintenance activities of the fuel transfer system (FTS). DCP #9600374 included installation of a permanent instrument air line to replace bottled gas that would normally be used to run fuct handling tools.
Installation was performed in three phases:
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I e Phase one installed DCPs #9600373 (Unit 1) and 9600374 (Unit 2), which included the main installation.
. Phase two installed DCP #9700076, w hich included the installation of a permanent communication cable between the Unit I fuel handling building FTS control console and the Unit 1 FTS containment
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control console. J e Phase three installed DCP #9700079, which included the installation of a communication cable betueen the Unit 2 fuel handling building FTS control console and the Unit 2 FTS containment control console. The change also installed a remote carriage traverse control to the spent fuel crane for both Unit I and Unit 2.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the FTS 1 or components are not required to affect, support, or maintain safe shutdown of the reactor. The design of the FTS was maintained to prevent fuel assembly damage during traverse operations. Fuct l
transfer equipment remains scismically qualified. Safety features that protect fuct transfer operations wcre improved by the change. The change does not afTect criticality protection. Transfer of the fuct is maintained under water. One fuel bundle is transferred at a time, maintaining proper separation.
As analyzed in UFSAR Subsection 15.7.4, one fact assembly is assumed to be damaged in either the refuct cavity or the spent fuel pool with no additional consequences.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because this change maintained the as designed safety features of the FTS. Operational efTects of this change improved safe handling by allowing the cart to be traversed from the current location. If the proposed drive system fails, an additional manual hand operation allows the winch to be turned such that a stranded fuel assembly can be transferred to its proper storage location. Since the change used the existing fuel transfer cart and fuct assembly ,
containment devices, failures that would cause fuel assembly damage remain the same. Therefore, l the postulated event as described in the UFS AR analysis remains bounding.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because i the change does not affect any parameters upon which Technical Specifications are based.
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DCPs 9600387 AND 9600390 DESCRIPTION:
The design change added a 1-hour rated fire barrier to conduits CI A51B6 and C2A7422, which contain power cables sening Division 11 and 21 cmergency safeguards function electrical buses at the essential senice water cooling towers. This design change was installed as a corrective action from LER 454-95-005. The Byron Safe Shutdown Analyses in Section 2.4 of the Fire Protection Report was resised to reflect design changes via FDRP 18-026.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the change only added a qualified fire barrict wrap to the outside of existing conduits. The added barrier does not affect the operation or possible malfunction of equipment associated with the conduit. The Fire Protection Report Safe Shutdown Analysis conclusions are enhanced because the change is adding protection from fire to cables not presiously protected. This change reduces the probability of damage or malfunction by providing protection from fire.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the new fire barrier insulation is designed and installed per approved scismic and electrical design criteria.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based.
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DCP 9700133 DESCRIPTION:
This change installed a 6-inch diameter hole in the slab at cicvation 468'-2" and a 24"x18" opening in one of the block walls in the clevator room in the turbine building. The core hole and block wall opening were needed in order to support the refurbishment of the turbine building elevator motor. Because of the opening in the block wall, the block wall's fire rating had to be de-rated. This is addressed in FDRP 18-034. ,
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes only affect structural elements and the fire-rating of the block wall without adversely altering them or any other systems or components. This conclusion is reached as the result of the following analyscs:
a) Calculations 9.15.1-BYR97-151 and 9.10.4-BYR97-152: These were performed to investigate the impact of the slab hole and block wall opening on the structural integrity of the afTected slab and block wall. These calculations found that the remaining capacity of the slab and block wall after the changes are still adequate to resist the original design loads without additional reinforcement. This demonstrates the ability of the affected slab and block wall to function as intended and therefore, will not fail and afTect other plant systems and components.
b) Exhibit B of NEP-04-07 (Approved Fire protection Program Impact) and memo from S. Chingo, M&S staff engineer - Fire Protc,; tion: These documents collectively show the fire rating of the block wall is not credited to achieve or maintain safe shutdown.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the structural calculations show the affected slab and block wall will not fail and create accident or equipment malfunction of a different type. The fire protection analysis shows no reliance on the contribution from the wall's fire rating in any accident analyses.
- 3. The margin of safety, as defined in the basis for air, Technical Specification, is not reduced because:
a) Although the margm between the required structural strength and available strength is reduced, it has always been arbitrary and the commitment that the provided strength or capacity to be at least equal or greater than the required strength is still maintained. Therefore, they will not fail afict the installation of the changes and affect other systems and components.
h) The fire rating of the block wall was never credited in any of the existing analyses. Per the analysis provided in Exhibit B of NEP-04-07, any fire below cicvation 468' of the turbinc l building will not spread to higher clevations. The hazards from any fire inside the clevator room l are insignificant to spread outside the opening. Therefore, no safety margins as dermed in the basis for any Technical Specifications are reduced.
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DCP 9700294 DESCRIPTION:
DCP 9700294 separated the well water (WW) make-up lines from the essential service water system (SX) make-up lines, which flow into the SX cooling tower basins. The well water line was rerouted to flow directly through the SX valve chamber wall instead ofjoining the SX make-up piping inside the chamber and flowing into the SX basin. The piping tee where the WWjoined the SX system is replaced with a straight piece of safety-related pipe, so that the SX make-up water from the river screen house, as well as the water from the circulating water system, is still able to flow directly to the SX tower basin. Safety-related check valves OSX127A and OSX127B, w hich provided isolation between the SX and WW systems, were removed. These valves were then installed in the WW system discharge to the SX basin to prevent possible SX water flow from the basin into the well water aquifer if the SX basin were filled above the 100% level and above the WW make-up line discharge outlet. Annubar measurement taps were added to each of the two well water make-up lines in order to measure flow in the well water lines (replacing an ultrasonic flow-measuring device). The UFS AR was updated to reflect the design change via DRPs 7-082 and 7-145.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the design change only affects the way water is sent to the SX towers to fill the basins. The make-up water continues to be supplied to the SX tower basins during an accident using either the SX make-up pumps or the well water system. The operation of the SX tower as an ultimate heat sink is, therefore, not affected, and there is no increase in the possibility of an accident. The well water piping is scismically qualified, and is protected from or evaluated for contact with tornado missiles. The loss of the SX make-up system and wc!! water system would have the same consequences on plant safety as before the design change pipe separation.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the deep well pumps and SX make-up pumps continue to supply water, as needed, to the SX tower basins. The systems are scismically qualified, and evaluated for the impact of tornadoes and freezing weather. Trash racks in the SX basia screen large debris that could be ejected by the piping systems. The well water system is located sufficiently above the river so that flooding is not a concern.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon u hich Technical Specifications are based.
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i DCP 970(G 18 DESCRIPTION:
This design change package abandoned the boron concentration monitoring system (BCMS). Instead, boron concentrations are determined based on grab samples. The accuracy of boron concentration measurements taken from grab samples is more accurate than the results provided by the BCMS.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously cvaluated in the safety analysis report is not increased because the BCMS is not an accident initiator or precursor. DCMS is not used to prevent or mitigate the consequences of any analyzed accident. The BCMS is not used to shut down the reactor nor is it used to maintain the reactor in a safe shutdown condition. Abandoning the BCMS does not degrade the chemical and volume control (CV) system that is assumed to operate during an accident, nor does it increase the challenges to the CV system to function during an accident. Therefore, the probability of a malfunction of equipment important to safety is not increased.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change has no impact on other systems or system functions. The BCMS function can be performed by the use of grab samples. Therefore, the abandonment of the BCMS does not adversely impact systems or functions to create the possibility of an accident or malfunction of equipment of a type different from those already evaluated in the UFSAR.
3, The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the BCMS does not afTect any parameters upon which Technical Specifications are based.
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DCP 9700331 l
l DESCRIPTION l
' DCP 9700331 supported the temporary installation of a vendor-supplied metering pump in place of the out-of-service caustic pumps in the condensate polishing system to supply caustic flow to the regeneration tanks. This change was administered under the station's temporary alteration procedure. This alteration was required because caustic flow was needed to operate the anion and cation regeneration tanks. This alteration consisted of usmg a braided rubber hose to connect the temporary pump to the caustic day tank and the low temperature discharge flange (as a temporary discharge connection). Instrument air pressure was used to operate the pump, with a check valve installed in the line to prevent cross-contamination.
l SAITTY EVALUATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the condensate polishing system is not iinportant to safety, is not scismically qualified, and is not factored into any accident evaluations. The modification ties into station equipment outside the reactor i
coolant system and physical steam plant operating boundaries. There are not interactions with l equipment important to safety.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the equipment does not tic to any system that can cause an accident or malfunction.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.
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i DCP 9700333 l DESCR!PTION:
l The design change added a tap to the radwaste mixed-bed demineralizer inlet header to allow removal of l
radioactive corrosion products from line 0WX106A using a hydrolascr.
i SAFETY EVALUATION
SUMMARY
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- l. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report was not increased. The design change activity did not impact equipment operation require'J for safe plant shutdown. The failure of the afTected systems, structures, and components (SSC) is bounded by rupture of the spent resin storage tank or the boron recycle holdup tank, as discussed in UFSAR Chapter 15.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis repon is not created because the proposed activity does not change the function of the affected SSC. The hydrolasing tap consists of a normally-closed valve and a pipe stub scaled with a pipe cap, The tap is only be used when the affected line is out-of-service. The failure of the affected SSC is bounded by the tank rupture accident evaluated in the SAR.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not alTect any parameters upon which Technical Specifications are based.
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DCP 9700378 DESCRIPTLQN_;
DCP 9700378 replaced the 20,000-gallon regeneration waste drain tank (RWDT),0WX25T, with a larger tank (30,000 gallons nominal). New tank level instrumentation was also installed to reflect the larger tank capacity. Tank high and low level alarm setpoints were revised in conjunction with the level instrumentation change. A section of auxiliary building ventilation system ductwork was shortened to climinate an interference with the new tank. The UFSAR was revised to reflect this change via DRP 7-102.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment .
important to safety previously evaluated in the safety analysis report is not increased because the probability of rupture of any tank is not increased. The new tank is designed to the same requirements as the old tank. An overflow line to prevent overpressurization of the tank has been added, which is an improvement over the old design. Operation of the radwaste system is not affected by the new tank other than the increase in inventony provided by the larger tank capacity. The consequences of an atmospheric release event result from a rupture or operator error affecting the tank containing the worst case radionuclide inventory. For an atmospheric release, the inventory is assumed to be released directly to the environment via the station vent stack. The accident analysis
! considers the worst case radionuclide inventory to be contained in the spent resin storage tank (SRST) or the boron recycle hold-up tanks (l!UT). Comparison of the activity released from these I
tanks with the shiciding design-basis radioactivity concentration for the RWDT indicates that the RWDT contains less radioactivity than the other two tanks. This comparison was accomplished by totaling the number of curies that would be present in 30,000 gallons of RWDT contents, based on Table 12.2 30, with the activity released from the SRST and the HUT from Tables 15.7-3 and 15.7-4.
The ground release event results from a potential rupture of the HUT. The consequences of the accident result from the potential release of the contents of the 125,000-gallon HUT to the auxiliary building, where it leaks through a crack into the ground water supply. The RWDT contains only 30,000 gallons of water with less radioactivity than the HUT. This was verified by a comparison of the activity contained in the HUT, documented in Table 15.7-4, and the activity contained in the RWDT, documented in Table 12.2-30.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the
! safety analysis report is not created because the failure modes and effects of the new RWDT are the same as the old tank. Possible failures are rupture leading to airborne release oi liquid release, u hich are accidents already addressed in UFSAR Chanter 15. The increase in tank volume from 20,000
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gallons to 30,000 gallons does not cause the existing accident analyses to be invalid, as verified by comparison of the radioactive inventories of the various tanks. The efTect of the tank on the auxiliary building structure and on safety-related equipment has been evaluated and there are no adverse effects.
- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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UFS AR CHANGE DRP 6-066 DESCRIPTIQR The UFSAR was revised to reflect the installation of Excide cells and racks at the station switchyard relay house. The batteries were replaced based on the remaining lifetime of the original batteries.
A S_A_FETY EVALUATION SUMMAR_Y:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the replacement batteries provide the same function as the original batteries. The reliabihty is the same or better.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no new failure modes were introduced from the presious installation.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 6-072 DESCRIPTION:
The UFSAR was resised to reflect refueling water storage tank (RWST) level setpoints and corresponding time availabic for operators to complete switchover to cold leg recirculation following a loss-of-coolant accident (LOCA). The change is based on DCPs 9600072 and 9600073 and the design basis calculation for RWST setpoints.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the RWST level setpoints cannot initiate an accident and are structured to assure the emergency core cooling system (ECCS) operates properly following a LOCA. The methodology used to determine the i time available for operators to complete switchover to cold leg recirculation is more accurate than past methodology. It uses the plant simulator and provides greater assurance that switchover to recirculation will be completed prior to depleting the RWST.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analy sis report is not created because the RWST level setpoints were validated using UFSAR requirements to assure that equipment important to safety will perform as required and that operators will have suflicient time to complete switchover to cold leg recirculation following a LOCA.
3 The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the RWST level setpoints required by the Technical Specifications are not changed. They do not require resision since these setpoints have been validated to meet design basis requirements for ECCS operation.
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UFSAR CHANGE DRP 6-073 DESCRIPTION: ;
}
Subsections 9.4.3.3.1.2 c and 9.4.3.3.2.c of the UFSAR were revised to allow for a momentary loss of negative pressure in the radwaste building w hile trucks enter and exit the building.
SAFETY EVALUATION
SUMMARY
- 1 I
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment i important to safety previously evaluated in the safety analysis repon is not increased because radiation release accidents do not involve the radioactive waste building or solid radwaste storage and handling activitics. Additionally, the change does not affect any equipment that is important to safety.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because typically, it takes less than then minutes to bring a truck into the I I
bay. The outer door can then be closed and the truck can be loaded. If a door fails in the open position, no radwaste processing is allowed and the air would be continuously monitored until the situation is resolved. Assuming worst-case airborne conditions in the radwaste building, there is no '
adverse effect on 10 CFR 20 dose limits and no increase in total station effluent releases.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not affect any parameters upon w hich Technical Specifications are based.
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UFSAR CHANGE DRP 6-077 DESCRIPTION:
The UFSAR was revised to reflect the results of the containment spray (CS) system design basis resicw and reconstitution effon. The changes included a more comprehensive discussion of the CS system design bases, system design parameters for fission product removal and testing and inspections programs. The changes proside an enhancement to the description of the system and the parameters used as input to the equipment qualification program. The postaccident chemistry and the loss-of-coolant accident discussions that contain descriptions of the conditions resulting from the accident were updated. Also, the changes revised the maximum and minimum containment spray pH values and the basis for acceptability.
Miscellaneous tables and figures were deleted that were no longer be required because the sections in which they were referenced were modified so that they no longer require the figure or table to reinforce the discussion. Finally, supplemental discussions wcre added to provide the information developed from the CS system design basis resiew.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the
, changes have no effect on the accidents that involve the CS system. Therefore, the prcbability of l occurrence or the consequences of an accident due to the changes was not changed. i l 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the
! safety analysis report is not created because the changes enhanced the applicable sections to provide l the latest information from the development of the system design description. The changes did not l create any new failure modes from that which have been previously evaluated in the S AR.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not afTect any parameters upon uhich Technical Specifications are based.
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UFSAR CilANGE DRP 645 DESCRIPTION:
The UFSAR was revised to update and revise Section 9.1, "Fuct Storage and Handling Systems." The revision to the section reflects wording changes made to correct discrepancies and editorial changes that were identified during a comprehensive licensing basis review of the section. In addition, the DRP incorporated previously approved Technical Specifications Amendments that allowed for increased enrichment in fuel assemblics in the spent fuel pool. Changes were made to the facility description, including the description of new equipment in use. Additionally, the appropriate subsections of section 9.1 were revised to incorporate the results of the most recent spent fuel rack criticality analyses. Finally, numerous changes were made throughout section 9.1 to reflect the as-built configuration of the plant anct to accurately describe activitics related to core offloads and refueling.
SAFETY EVALUATION SUMM ARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment I important to safety previously evaluated in the SAR was not increased because the changes made to l section 9.1 have been determined to have no affect on the accidents of concern for the spent fuct )
storage and handling systems. These accidents arc abnormal storage conditions in spent fuel pool I (SFP) racks (Subsection 9.1.2.3) and fuel handling accidents inside the spent fuel storage building l (Subsections 6.5.1.3.3.1 and 15.7.4.2.1). In addition, the changes to reflect the most recent spent fuel rack criticality analyses were performed consistent with NRC Standard Resiew Plan (SRP) acceptance criteria. These criticality analyses were reviewed and approved by the NRC in suppon of a Technical Specifications Amendment to increase the SFP enrichment limits to 5.0 w/o U-235. The l changes to the description of refueling procedures and practices reflect the current design analysis for i maximum spent fuel temperatures. This analysis reflects SRP acceptance criteria and was reviewed l and approved by the NRC as part of the SFP cnrichment increase amendment. Therefore, the l
probability or consequences of the changes were not increased from uhat has been pres sously l
I cvaluated in the SAR.
- 2. The possibility for an accident or malfunction of a different type than any evahiated previously in the SAR was not created by the changes made to Section 9.1. As discussed above, the current SAR evaluates the failure modes and consequences for abnormal storage conditions in the spent fuel racks l and fuel handling accidents. The changes made to Section 9.1 did not create any new accidents or j malfunctions from what was presiously evaluated. Any potential malfunction created by the change is bounded by the fuct handling accident analysis. The other editorial changes in section 9.1 reflect the results of analysis that was performed consistent with established acceptance criteria or was reviewed and determined acceptable by the NRC as part of the SFP enrichment limit increase l amendment. Therefore, the changes to section 9.1 did not create any new accidents or malfunctions i ditTerent from w hat was presiously evaluated in the S AR.
- 3. The margin of safety, as defined in the basis for any TS, is not reduced by these changes because the i changes are consistent with the Technical Specifications limits.
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UFSAR CHANGE DRP 64186 DESCRIPTION:
The UFSAR was revised to reflect chemical feed equipment for the nonessential service water system.
S AFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety presiously evaluated in the safety analysis report is not increased, because the chemical feed system cannot initiate an accident. The chemical feed system does not directly l interact with any system that can initiate an accident required to ensure operation of any system.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in l
, the safety analysis report is not created, because operation of the chemical feed system enhances the operation of the circulating water, essential service water, and nonessential senice water systems by limiting or preventing biological growth and associated macro fouling. No new failures are introduced.
- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because the chemical feed system does not affect any parameters upon which Technical
! Specifications are based.
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UFSAR CHANGE DRP 6-087 DESCRIPTION:
The UFSAR was revised to clarify various parts of the essential service water (SX) system description.
The changes were predominantly editorial (e.g., improving wording, clarifying Byron vs. Braidwood configuration clarifications). The most substantial change was to correct the rated capacity of the sump pumps in the SX pump rooms.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the UFSAR changes are clarifications only and do not change any systems, structures, or components (SSC).
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no changes are made to any SSC nor any procedures used to operate or maintain any SSC.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 6-094 DE_ECRIPTION:
The UFSAR was resised to change the setpoint criteria stated in Table 11.5-1 for the containment atmosphere radiation monitors to be consistent with UFSAR Subsection 5.2.5.2 or Teclutical Specification Bases 3/4.4.6.1. The radiation monitors are credited as a leak detection system consistent with Regulatory Guide 1.45, which states that the monitor's particulate and gas channels would detect a one gallon per minute leak in one hour. The Regulatory Guide criterion was more limiting than the criteria stated in Table 11.5-1.
SAFETY EVALTUATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the radiation monitor setpoints were lowered to comply with the more conservative Regulatory Guide 1.45 criteria. l
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the SAR already described the detection capability of the containment atmosphere radiation monitors.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the monitors continue to meet the leak detection criteria of Regulatory Guide 1.45, as stated in the l bases.
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UFSAR CIIANGE DRP 6-101 DESCRIPTION:
The UFSAR was revised to correct errors and inconsistencies found during the UFSAR conformance review of the component cooling system. The majority of the changes were to editorial. The remaining changes were added to clarify existing information already contained in the UFSAR and to provide more detailed component data on the component cooling pumps.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes to the UFSAR have no affect on the operation of any plant equipment. The component cooling system continues to be capable of performing its safety function.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no changes are made to plant equipment or procedures.
Therefore, no new credible failure modes are created by the changes.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because )
the changes do not affect any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 6-103 DESCRIPTION:
The UFSAR was revised to more accurately reficct the plant configuration and to provide editorial clarity in describing system configuration (design / construction) and function (operability / usage) of the steam generator blowdown sample panel.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased. The change is a more accurate description of the system. The instrument panels, sample sink and sink drains do not have safety or accident mitigation functions. The are not accident initiators or precursors. The document change has no adverse efTect on plant operations or equipment.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because there are no changes to plant operations or effects on equipment failures.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon u hich the Technical Specifications are based.
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UFSAR CHANGE DRP 6-104 DESCRIPTION:
The UFSAR was revised to reflect the Phase !!! of the main control room (MCR) process computer. This phase replaced the MCR process computer colorgraphics display system, replaced the bechive operators console with the HMI (Human Machine Interface), and replaced the process computer alarm printer with a color printer. A CRT-based alarm system was also provided.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because Phase III of the process computer replacement leaves intact all of the capabilitics of the process comruter subcooling indication. Also the references to reactor coolant system subcooling in the accident analysis do not require that the process computer be available. All pre-existing capabilitics of the plant process computer displa: system were retained with additional features added.
- 2. The possibility for an accider i or malfunction of a different type than any evaluated previously in the l safety analysis report is not i,reated because the process computer replacement does not adversely impact UFSAR accident-re'ated systems, structures, and components (SSCs). All previous
)
capabilitics of the process computer displays are being maintained with additional options available to the operators. No direct control of SSC's is provided by the plant process computer.
- 3. The margin of rafety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 7 001 DESCRIPTION:
The UFSAR was revised to update the description of make-up demineralizer operations. References to mixed-bed dcmineralizer regeneration were removed since resin is now replaced when exhausted. The acid and caustic regeneration equipment descriptions were separated for clarity.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipmer.t important to safety previously evaluated in the safety analysis report is not increased because the make-up dcmineralizers are not assumed to operate in any accident. There were no accidents identified in the SAR review.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the proposed activity has no impact on plant operations.
The changes improve the water quality of the make-up water. Water quality remains adequate to minimize the corrosion of plant systems and meets program requirements. No new failures are introduced.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not afTect any parameters upon uhich Technical Specifications are based.
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DESCRIPTION:
UFSAR Table 6.2-58 was revised to indicate that steam generator blowdown valves ISD005A-D are normally open during power operation.
i SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment i important to safety previously evaluated in the safety analysis report is not increased because the l sample line flow is too small to induce any accident. The 3/8-inch globe valves pass very little flow; the valves are closed on a safety injection signal, and no new equipment challenges are created. The l UFSAR aircady recogni/cd that these valves are open in Subsection 9.3.2.2.2.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated in the safety analysis repon is not created because the steam generator blowdown sample system is designed for l continuous operation and is designed to automatically close on a containment isolation signal. The l UFS AR already recognizes that the sample valves are open in Subsection 9.3.2.2.2. Operation with the sampic valves open does not create any new malfunctions because the system is designed to be in this alignment.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because Technical Specifications assumes these valves are open. The sample valves receive automatic isolation signals, and are tested and maintained per Technical Specification 3.6.3.
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UFSAR CHANGE DRP 7-005 DESCRWrlON:
The UFSAR was revised to change the description of the GAPPIPE computer program and to remove the restriction for use only on the Byron Unit 2 seismic stop pilot program reactor coolant bypass subsystem.
The change provides the correct description of the program in the applicable reference sections. Removal of the restriction was based on the NRC's written approval of the program.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change made an editorial update to the sections of the UFSAR where the computer program is referenced. The change removed the restriction of the use of the program for Byron Unit 2 only. The change has no impact on any accident or malfunction evaluated in the SAR.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change only made an update to the sections where the reference to the computer program is contained. The change was an editorial update to remove the restrictions for the use of the program. The NRC has already approved use of the program for other applications.
- 3. The margin of safety, as defined in the basis for any Technical Specification is not reduced because the change does not affect any parameters upon u hich the Technical Specifications are based.
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f IJFSAR CHANGE DRP 7-010 DESCRIPTION:
UFSAR Table 6.2-58 was revised to describe the correct location of containment isolation valve 1S18824.
to inside containment, rather than outside containment.
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! SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment 1 important to safety presiously evaluated in the safety analysis report is not increased because the change has no impact on any analyzed event.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the I safety analysis report is not created because the change processed in the subject DRP does not adversely impact UFSAR accident-related systems, structures, and components..
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not redaxd because the change does not affect any parameters upon which Technical Specifications are based.
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- DESCRINION
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l UFSAR Figure 9.5-4 was resised to include an installed check valve in the lubricating oil supply to the turbocharger. P&lD M-152 Sheet 9 was also resised to include this check valve.
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i SAFETY EVALUATION
SUMMARY
l 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety previously evaluated in the safety analysis report is not increased because the l change did not affect the normal operation or function of the dicsci generators.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the change does not impact the operation of the dicsci generator. No new failures were created.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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UFSAR CilANGE DRP 7-012 DESCRIPTION:
The UFSAR was revised to reflect that engineering information such as the Safety-Related Components List and Piping Line List was migrated into the Electronic Work Control System (EWCS).
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the engineering information for the plant equipment is still being maintained and the UFSAR has been changed to identify the database that now contains the information. Equipment that is important to safety is maintained no differently than it was in the past, with the engineering information on the equipment being maintained in a database instead of within various printed lists. Therefore, no change in the probability or consequences of any accident or malfunction could occur due to changing the location w here this information is maintained.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because maintaining engineering information on equipment is still being done. The method of maintaining the engineering information was changed. Maintaining the equipment in accordance with the design information precludes the possibility of any new accident or malfunction.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the location of engineering information on equipment and how it is maintained is not specifically addressed by the any Technical Specification.
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UFSAR CHANGE DRP 7-014 DESCRIfrTION:
UFSAR Table 11.2-8 was revised to more fully agree with Table D-10 of the Generic Section of the Byron Station Offsite Dose Calculation Manual (ODCM). OfTsite dose calculations use the methodology and assumptions presented in the ODCM, which has been approved by the NRC. The ODCM consumption factors are updated factors used for calculating offsite dose.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because no accident precursors are changed. The effect on offsite dose is not changed bcuiuse the consumption factors currently used to evaluate offsite dose are supplied in the ODCM.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the consumption factor change does not impact UFSAR related systems, structures, and components (SSCs), and does not introduce any interactions between l any SSCs.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the change in consumption factors does not affect any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 7-015 DESCRIPTION:
The description in the UFSAR was changed to indicate the slot dimension for the Unit Two weir plate in the reactor containment floor system (RF) was 1/8 inch, not 1/4 inch as previously written.
SAFETY EVAL.UATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety piniously evaluated in the safety analysis report is not increased because the 1/8-inch slot design does not affect the ability of the containment floor drain system to detect a one gpm leak in containment.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the ability of the containment floor drain system to detect and monitor a one gpm Icak is unaffected by this change. Therefore, there is no impact on system or functions different from those evaluated in the S AR.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because is not affected because the change does not affect any parameters upon uhich Technical Specifications are based.
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gF_SAR CHANGE DRP 7-018 DESCRIPTION:
The UFSAR was revised to refine how the loose parts menitoring system is operated when a Hi Alarm is received in the control room.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this change does not impact any plant equipment.
- 2. The possibility for an accident or malfunction of a ditTerent type than any evaluated previously in the safety analysis report is not created because this change only reflects how an operator responds to a Hi Alarm without any changes made to plant equipment. I
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not afTect how the in-plant equipment works, only how an operator responds to a Hi Alarm rcccived in the Control Room. The margin of safety has not changed. ]
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UFSAR CHANGE DRP 7-020 DESCRIPTION:
The UFSAR was revised to reflect in operating procedures to allow isolation of auxiliary feedwater (AF) to a ruptured steam generator (SG) in procedure BEP-0 prior to transitioning to procedure BEP-3. This change prosided further assurance that margin-to-overfill requirements for a SG tube rupture (SGTR) recovery were met.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the accident has already occurred therefore, this procedure change has no effect on the probability of SGTR nor any other accident. This procedure enhancernent allowed isolation of AF to the ruptured SG carlier to provide further assurance that design basis operator action time requirements for the SGTR event was met. This action also significantly reduced the mass in the ruptured SG secondary side during event recovery. Reduced secondary mass in the ruptured SG reduces the potential for offsite release during a SGTR event. This change did not add any new actions that were not previously preformed the response to a SGTR event.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this change reduced the consequences of a SGTR by reducing the amount of water added to the secondary side of the SG. Minimizing the filling of the ruptured SG reduces the chance of overfilling the SG and decreases the probability of a potential release offsite.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the basis of the AF system is to ensure that the reactor coolant system can be cooled down to less than 350 F from normal operating conditions in the event of a total loss-of-offsite power. Isolation of AF to a ruptured SG does not prevent AF from being available for plant cooldown. The margin-to-overfill analysis determined that two SGs are adequate for plant cooldown during a SGTR.
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UFSAR CHANGE DRP 7-023 DESCRIPTION:
The recommended UFSAR setpoints for the 1/2AR011/12 fuel handling incident monitors wcre resised to agree with Technical Specifications Tab!c 3.3-6, and Byron On-Site Review 97-015. The UFSAR had recommended these monitors be set at 100 mR/hr; however Technical Specifications require the monitors to be set to detcet a submersion dose of 10 mR/hr above normal background. The change addresses the discrepancy between the two documents.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the resised setpoints are more conservative than the original recommended setpoint. The accident analyses remain bounding.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the new setpoints are more conservative than the original recommended setpoints. Therefore, in the event of a fuel handling incident, the containment ventilation isolation signal is actuated in the same way, but at an earlier phase in the accident.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change to the UFSAR recommended setpoint for the 1/2AR0ll/12 monitors is consistent with the Technical Specifications requirements.
34 L______ _
DESCRIPTION m UFSAR Appendix E, and Byron Administrative Procedures BAP 320-1, BAP 2010-2, and BAP 2010-2Al were resised to climinate the Station Control Room Engineer (SCRE) position and the create the Unit Supenisor positions. The changes did not impact functionality or dutics of the control room supenisor position.
SAFETY EVALUATION:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes proposed were administrative in nature and did not alter the responsibilitics of the control room supenisors. This included any and all Shift Technical Advisor (STA) functions presiously identified in the UFSAR.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the )
safety analysis report is not created because the changes proposed were administrative in nature and do not change the responsibilitics for the control supenisor position.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the changes are consistent with the requirements in Section 6 for the STA function and shift crew
! composition.
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UFSAR CilANGE DRP 7-032 DFSCRIPTION:
The UFSAR was revised to clarify the Quality Assurance Audit process associated with postshipment inspection of new fuel. The changes are consistent with a revision to the Quality Assurance Topical Report CE-1-A that was approved by the NRC in 1994.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because these changes only clarify the wording associated the audit function for new fuel inspection. This process is still subject the audit under the Quality Assurance Program. There is no impact on any analyzed events.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the audit process itself has no effect on any accident or malfunction.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the Audit process has been removed from the Technical Specifications. The internal audit program was removed from the Technical Specifications and relocated to the Commonwealth Edison Quality Assurance Topical Report. Therefore, the change does not affect any parameters upon w hich Technical Specifications arc based.
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UFSAR CliANGE DRP 7-034 DESCRIPTION:
The UFSAR was resised to reflect use of fuel assemblics with ZIRLO components and the corresponding j safety analysis to allow the use of the increased peaking factors (IPF), FNDil and FQ. ZlRLO components improve the mechanical properties of fuel assemblics to suppon strategic increases in assembly burnup and fuel cycle length. IPF supports increased burnups and cycle lengths as well as increasing available peaking factor margin.
SAFETY EVAL 1ATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the use of ZIRLO fuel components meet all of the design criteria in the UFSAR and licensc-based WCAPs.
The design criteria assure that licensed-based acceptance criteria are met. Fuel is not directly related to the probability of any presiously analyzed accident, but adhering to applicable design criteria and standards precludes challenges to components and systems that could increase the probability of a presiously analyzed accident. The cladding integrity is maintained as well as the structural integrity
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of the fuel assembly and components by the use of ZlRLO and the associated mechanical changes. 1 The dose predictions in the UFSAR are not dependent on the fuel rod material, so the radiological consequences of failure of equipment important to safety will not be increased.
For the IPF change, the applicable departure from nucleate boiling (DNB) criterion is met for the increase in FND11 and FQ, by offsetting the efTect of the increased peaking factor with a resised safety analysis limit (SAL) DNB ratio. Evahiations of applicable UFSAR transients were performed that show that the resised SAL DNB ratio is met for the increase in FNDil and FQ.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the use of ZlRLO fuel components meets all of the design criteria. The design criteria assure that licensed-based acceptance criteria are met.
For IPF, all key safety parameter limits are met. No new performance requirements are being imposed on any system or component such that any design criteria will be exceeded, nor will the core operate outside of design basis operating limits. No new failure modes or limiting single failures have been created. The demonstrated adherence to these standards and criteria precludes new risks to components and systems that could introduce a new type of accident.
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- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because I the Technical Specifications aircady permit the use of ZlRLO fuel components. The change is consistent with these requirements.
For IPF, the increase in FNDil and FQ and its effect on DNB ratio are accounted for by reducing the applicable SAL. This approach is used to specifically minimize the effect of the FNDil on the existing Non-LOCA licensing basis safety analyscs and corresponding reactor protection system setpoints; especially the Overtemperature AT and Overpower AT reactor trip setpoints. To offset the increase in FNDil u hile minimizing the effect of this change on the licensing-basis safety analyses ,
and plant protection system setpoints, revised reactor core safety limits ucre determined. Using these resised core safety limits, the current Overtemperature and Overpower AT reactor trip setpoints were evaluated and found acceptable for protection against exceeding these limits _ llence, the system transient responses for the UFSAR Non-LOCA events that rely on the Overtemperature and Overpower AT reactor trip setpoints for protection are not affected by the increase in FNDil or FQ.
37
DESCRIPTION:
UFSAR figures showing pump performance curves were resised to be consistent with the analyses of record. The text was also revised to more clearly define how the pump performance data are used in the accident analyses.
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SAFETY EVALUATION
SUMMARY
1
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because neither j the function nor the performance of the pumps is changed. The testing requirements are also unchanged. No boundary to radioactive release is affected.
l 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the function and operation of the pumps and their ability I
to perform their required functions are not changed. No other safety equipment is impacted, and new failures are created.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the Technical Specifications values continue to be used in the accident analyses. The changes have no impact on the applicable Technical Specifications parameters.
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UFSAR CilANGE DRP 7-040 DESCRIPTION:
The UFSAR was resised to document the qualification evaluation of equipment due to the revised peak temperature in the main steam pipe tunnels and safety valve enclosures (Enviromnental Zone T3) following a main steam line break (MSLB) outside containment. It incorporates the results of a new analysis and evaluation for a MSLB outside containment.
SAFETY EVALIJATION SUMM ARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment I important to safety previously evaluated in the safety analysis report is not increased because the temperature change does not change any initiating conditions. The equipment that is required to safety shutdown the reactor and mitigate the consequences of this accident has been presiously evaluated and continues to perform its intended function at the resised peak temperature (372.68 F)
I without any degradation in performance. Regulatory Guide 1.97 equipment has been evaluated at the resised peak transient temperature and found to not impede the ability of the operators to mitigate the accident and safely shutdown the plant
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the equipment that is relied upon to function during this event to safely shutdown the reactor or mitigate the dose consequences of the design-basis MSLB is l not adversely affected by this change. The resised peak temperature of 372.68 F is bounded by the previous safe-shutdown equipment evaluation, and the Regulatory Guide 1.97 equipment has been
! cvaluated for the increased peak temperature. Regulatory Guide 1.97 components impacted by the revised peak temperature are expected to function as designed or have been eva!uated as not being required for this event.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the new MSLB analysis does not affect any parameters upon which Technical Specifications are based.
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l DESCRIPTION:
I The UFSAR was revised to change the average linear power density (KW/Ft.) value from 5.44 KW/Ft to 5.45 KW/Ft. This reflects the value used in the safety anal) sis and includes the correction due to fuel height densification.
f SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety previously evaluated in the safety analysis report is not increased because neither l plant equipment nor design criteria are affected by the change. The method and manner in uhich the plant is operated remains unchanged. All existing equipment continues to function as designed.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this change does not impact UFSAR accident-related systems, structures, and components (SSCs). Additionally, the UFSAR clu:nge to the linear power density does not introduce any adverse interactions between any SSC5. All plant equipment continues to perform as was assumed in the safety analysis
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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DESCRIPTION:
This UFSAR change deleted references to iodinc in the waste gas decay tank rupture accident. It also resised tables to reflect the current revision of the dose calculation.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the accident initiators are unchanged. The change affects only the calculation of dose following an accident. The dose changes were approved by the NRC in the safety evaluation report for license amendment 92 on August 13,1997. Removing the references to the iodine has no impact because there is no dose calculated for iodines.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change does not affect equipment or operation of equipment. The accident initiators remain the same. The calculated doses are those approved in the NRC safety evaluation report. Deleting the iodine references has no impact on the calculated dose.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the limit for total activity in the waste gas decay tank, as specified in Technical Specification 3.11.2.6, is unchanged. Maintaining the activity limit in the tanks ensures that offsite dose limits are also met.
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UFS AR CliANGE DRP 7-015 DESCRIPTION:
The UFSAR was revised to state how the charging pump suction will be aligned for circumstances u hen the plant is shutdown from outside the main control room (MCR). The charging pump suction will be aligned to the refueling water storage tank (RWST) by local manual action, rather than being switched using jumpers at its motor control center (MCC).
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change has no impact upon the probability that a fire or other circumstances will cause the MCR to be evacuated. Additionally, the change performs the same function as before, to align the suction of the charging pump to the RWST. Performing the alignment with local manual action and with the motor-operated valve (MOV) de-energized, has less potential to cause equipment malfunction than the previous method of usingjumpers at the MCC. The consequences of the accident or malfunction are not changed because the same functional objective, alignment to the RWST, is achieved.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analy sis report is not created because the change will align the suction valves to the charging pump with local manual actions and the MOVs de-energized. With the MOVs de-energized, they are not susceptible to spurious operation because of" hot shorts" on control cables due to a fire in the MCR. The change climinates potential malfunctions, without creating potentials of a different type.
- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon w hich Technical Specifications are based.
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I UFSAR CHANGE DRP 7447 DESCRIPTION:
The UFSAR was revised to change the reference for the meteorological measurements program. The calibration procedures had previously been maintained in the Generating Station Emergency Plan (GSEP)
Annex. When this document was deleted, tne information relating to mescorological measurements was transferred to the site-specific portion of the Offsite Dose Calculation Manual and is documented by the vendor. The UFS AR change removes the reference to the deleted GSEP annex.
SAFETY EVALUATION
SUMMARY
)
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because buildings and equipment are not affected by the change. There are no changes to the methodologies used to calculate offsite dose.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the 3 safety analysis report is not created because this editorial reference does not impact accident-related l systems, structures, or components.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications arc based.
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DESCRIPTION:
1 The UFSAR was revised to incorporate several as-built changes and clarifying information to UFSAR l sections impacting the diesel generators and associated support equipment.
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! SAFETY EVALUATION
SUMMARY
i
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because no physical changes were made to the plant and the changes did not represent any differences in the normal operation or function of the diesel generators.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis repon is not created because no physical or operational changes were made to the plant as a result of this revision to the UFSAR. No new failures have been introduced.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon which Technical Specifications are based.
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UFSAR CH ANGE DRP 7-049 DESCRIPTION:
The description of the Generating Station Emergency Plan (GSEP) in the UFSAR was revised to provide a standardized description of the GSEP for all six Commonwealth Edison nuclear sites. The revision meets all regulatory requirements for UFSAR content.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the GSEP does not afTect any accident initiators or precursors. The GSEP does not affect plant equipment, plant operations or offsite dose.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the GSEP does not impact UFSAR accident-rclated systems, structurcs, and components. The GSEP is resiewed and resised in accordance with Appendix E of 10 CFR 50.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the requirement in Technical Specifications to have a written emergency plan continues to be satisfied. This revision did not affect any parameters upon u hich Technical Specifications are based or reduce the requirements and response actions carried out under the GSEP.
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l UFSAR CHANGE DRP 7-052 DESCRIPTION:
This UFSAR change deleted a historical FSAR drawing list in Section 1.7 and replaced it with a list of the UFSAR figures and their associated station drawings. Text was added to indicate that the FS AR drawing list is available in the FSAR.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the 3 change does not afTect any accidents or malfunctions of equipment. The figures themselves are not i changed; nor are the equipment and systems t' tat they represent.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because there are no changes to plant equipment or operation of plant equipment. There are no new source terms or changes that would alTect the consequences of an accident. The drawing list includes references to drawings that are already part of the UFSAR.
1
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the change does not affect the basis for any Technical Specification.
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DESCRIPTION:
The UFSAR was resised to remove a statement based on the auxiliary building safety-related components flooding analysis. Specifically, the statement "In general, this (flood) will not disable the essential senice water pumps" was removed because it does not suppon the stated position contained in Branch Technical Position Section B.3.b.3. The Flood level, as stated in Byron Calculation 3C81281-001, does not change.
SAFETY EVALUATION
SUMMARY
- 1. The probability of an occurrence of an accident presiously evaluated in the UFSAR is not increased because the essential senice water (SX) system is not changed, the system continues to operate as designed. The consequence of an accident is not increased due to climinating the statement that a flood will not disable the SX pumps. The probability of a malfunction important to safety is not increased because the SX system is redundant, and operating trains are separated by watertight rooms. The consequences of a malfunction of equipment important to safety is not increased because the auxiliary building flooding design analysis is still maintained. There is no change to the function of the SX system.
- 2. The possibility for an accident or malfunction of a different type than any presiously evaluated in the safety analysis report is not created because the design-basis accident analyses remains unchanged.
Per calculation HELB-8," Confirmation of Safe Shutdown Capability After Auxiliary Building Flooding," the SX system is a dual-purpose moderate-energy systent, therefore, per BTP 3-1, a single failure in the SX system need not be postulated along with any pipe cracks or breaks. In addition, leak detection sumps are available in the SX pump rooms. These leak detection sumps annunciate a high level alarm in the control room, w hich alerts the operators to excessive leakage in a given area.
No new failures are postulated.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect the parameters in the bases for the SX system Technical Specifications.
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UFSAR CHANGE DRP 7-061 DESCRIPTION:
The UFSAR was revised to update and clarify the battery testing schedules and standards.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change is encompassed by rewording without change in meaning and addition of clarifying information. There are no changes to plant equipment.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the change is encompassed by rewording without change in meaning and addition of clarifying information. There are no changes to plant equipment.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not impact the basis for any Technical Specification.
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UFSAR CH ANGE DRP 743 DESCRIPTION:
The UFSAR was revised to change the described operator actions for dilution events during reactor startup and full power operation. These changes allow operators to initiate and continue boration until adequate shutdown margin has been restored and to terminate the dilution. Two additional methods are added to describe how boration of the reactor coolant system is accomplished.
S AFETY EVALUATION SUMM AR_Y:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the accident would have occurred already; therefore, this change has no efTect on the probability of dilution event nor any other accident. The change ensures that the adequate shutdown margin is restored in the event that a dilution accident does occur by any of the described methods of available boration flow paths that instead of this listing one method.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the affected systems equipment operation and purposes were not changed. No new failurcs have been introduced.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the required boration can still be initiated to restore adequate shutdown margin.
19
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UFSAR CHANGE DRP 7-065 DESCRIPTION:
The UFSAR was revised to add exceptions to Regulatory Guide 1.21, " Recommendations for Information l
to be included in the Annual Radiological EfTluent Release Report." The first deviation is the way in
)
w hich the OITsite Dose Calculation Manual (ODCM) software uses meteorological data to calculate public l dose. Regulatory Guide 1.21 recommends using concurrent meteorological data. The NRC-approved ODCM software includes average annual meteorological data for ODCM calculations. Additionally, the NRC has stated that they are primarily interested in doses to maximally exposed individuals, not populations out to 50 miles from the site. Due to the cost-prohibitive nature of upgrading the software to calculate these data, which are not currently required by the NRC, an exception from this Regulatory Guide recommendation was added. Finally, to remain consistent with the fonnat in w hich all effluent data are recorded, radioactive waste data is tallied on a quarterly basis, rather than in a semi-annual format, as recommended by the Regulatory Guide.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment imponant to safety previously evaluated in the safety analysis report is not increased because no buildings or equipment is affected by the change.
- 2. The possibility for an accident or malfunction of a diiTerent type than any evaluated previously in the .
safety analysis report is not created because this change does not impact UFSAR accident-related j systems, structurcs, and components. I
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the requirement in Technical Specifications to submit an annual report continues to be met. The Technical Specifications do not provide guidance on how the repon should be prepared.
50
UFSAR CilANGE 7-069 DESCRIPTION:
The UFS AR was revised to clarify the efTect of a failure of 1(2)S18840 to open on demand during switchover from cold leg recirculation to hot leg recirculation fonowing a loss-of-coolant accident.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because failure of the valve to open is not an initiating event. An analysis has been performed to ensure that sufficient hot leg recirculation flow can be provided by the safety injection pumps alone. As a conservative action, residual heat removal flow would be reestablished to the cold legs to prevent boosting the suction pressure of the safety injection pumps to the point they could exceed their run out capacity and to maintain a conservatively high rate of total flow to the core.
l 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there were no changes to any parameters upon uhich Technical Specifications are based.
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UFSAR CHANGE DRP 7-071 DESCRIPTION:
The UFSAR was revised to reflect the maximum flood level and source of the floodwater for the auxiliary feedwater (AF) dicsci pump room (s). For Unit 1, the flood level is 6 inches and the source is a 20-inch noncssential service line break. For Unit 2, the flood level is 13 inches and the source is a 30-inch nonessential service line break. These flood levels were calculated in the auxiliary building flood calculation, 3C8-1281-001.
S AFETY EVALUATION SUMM ARY.;
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the AF system is not changed, the system will operate as designed. The consequence of an accident is not increased because no physical changes are made to the AF system. The change makes the UFSAR consistent with the design basis flooding calculation. The probability of a malfunction important to safety is not increased because the new flooding height of five inches is below the previous flood height of six inches (Unit-1) and 13-inches (Unit-2). There is no change to the function of the AF system; the AF pumps will operate as designed.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the design basis accident analyses remains unchanged.
The actual flood level has decreased.
l 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l there were no changes to any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 7-081 DESCRIPTION:
The UFS AR was revised to reflect the auxiliary building air conditioning chiller unit configuration. The references to refrigeration unit OWOO3CC and chilled water pump OWOO3PC were deleted.
S_AFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report was not increased because the refrigeration units and chilled water pumps cannot cause or mitigate the consequences of any design basis accidents. The auxiliary building refrigeration units and chilled water pumps are scismically restrained to prevent impacting equipment important to safety. The auxiliary building ventilation (VA) system retained its safety-related function. Essential senice water (SX) room coolers continue to cool emergency core cooling system (ECCS) components. Therefore, the probability of a malfunction of equipment important to safety did not increase.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because reducing the number of auxiliary building refrigeration units and chilled water pumps from three to Iwo did not create the possibility of a new accident or equipment malfunction. The remaining equipment is capable of performing the design function of the system.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specification limits are based.
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UFSAR CHANGE DRP 7-085 DESCRIPTION:
The UFSAR was revised to address conformance with NRC Regulatory Guide 1.160, Resision 2, w hich was issued in March 1997. The major changes incorporated into the UFS AR description based on this Regulatory Guide resision were:
- Change the applicable resision number of Regulatory Guide 1.160 e Update reference to the current resision (resision 2) of the NUMARC 93-01 " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
. Deleted the sentence referencing NUM ARC 87-00, " Guidelines and Technical Basis for NUMARC Initiatives Addressing Station Blackout at LWRs,"
. Deleted the paragraph associated with not using Unplanned Capacity Loss Factor (UCLF) as a plant level indicator.
SAFETY EVALUATION
SUMMARY
1
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment ;
important to safety presiously evaluated in the safety analy sis report is not increased because the j change does not impact the operation of any systems, structures, or components (SSCs). No SSCs are
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being added, removed, or modified as a result of the commitment to Revision 2 of Regulatory Guide i 1.160.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the change does not affect plant operation. No UFSAR accident-related SSCs are being added, removed, or modified as a result of this change.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not afTect any parameters upon w hich the Technical Specifications are based.
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UFSAR CHANGE DRP 7-089 DESCRIPTION:
The UFSAR was revised to reflect the laundry facility equipment and its use.
1 SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the modification has no impact on the flooding within the auxiliary building. The modification does not affect the efiluents from the liquid radwaste s) stem or the air flow in the laboratory ventilation system.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety 1 analysis repon is not created because this modification does not introduce additional high or raoderate !
cncrgy components or systems in the auxiliary building that may impact accidents as identified in I UFSAR Section 15. Structural changes to the auxiliary building were reviewed and qualified in the structural PECN, P-1395.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not afTect any parameters upon w hich Technical Specifications are based.
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UFSAR CHANGE DRP 7-094 DESCRIPTION:
The UFSAR was revised to clarify emergency boration requirements. The pump capacity is not necessarily representative of actual system performance of the pumps, but rather the nominal values for pump performance."
SAFETY EVALUATION
SUMMARY
- 1. The probabihty of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change is to clarify the safety requirement of the boric acid transfer pump. Performing a quarterly inservice test (IST) would still identify the degradation of the pump. The requirement for emergency boration to supply 30 gallons per minute to the reactor coolant sy stem via the centrifugal charging pumps is maintained.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analy sis report is not created because this change is only to clarify the safety requirement of the boric acid transfer pump. The pumps continue to supply the required flow for emergency boration in response to an accident. No new failures have been introduced.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not afTect Technical Specifications requirement to supply 30 gallons per minute.
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UFSAR CH ANGE DRP 7-097 DESCRIPTION:
The UFSAR was revised to reflect the requirements of ANSI /ANS 56.8,1994 and NEl 94-01, Revision O.
The changes revise the " Temperature Stabilization" section to a " Containment Stabili<ation" section for Type A tests. The minimum pressure for a Type A test is changed to .96 Pa and the maximum pressure for Type B and C tests is changed to 1.1 Pa for components that increasing pressure decreases leakage.
SAFETY EVALUATION SUMM ARY:
1, The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis repon is not increased because the new Type A stabilization methodology and the new limits on the Type A, B, and C test pressures ensure tlic tests are conducted in accordance with the current regulatory requirements. Meeting the current regulatory requirements ensures the containment leakage is within design limits as assumed in the accident analyses.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the l safety analy sis report is not created because the design limits are unchanged. The accident analyses I remain bounding. I
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change is consistent with Technical Specifications requirements for containment leak testing.
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f SAR CHANGE DRP 7-100 LJ DESCRIPTION:
The UFSAR was revised to allow standing water in containment floor drain lines that is caused by improper slope of those drain lines.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the containment floor drain system cannot cause equipment failurcs. There is no specified time requirement for leakage collected in the trench drains to reach the containment floor drain sump.
The ability of the containment floor drain system to detect and quantify reactor coolant s) stem leakage is not adversely affected.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because the containment floor drain system continues to function as designed. No new failure modes are introduced. l
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not affect any parameters upon w hich Technical Specifications are based.
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l UFSAR CHANGE DRP 7-114 DESCRIPTION:
The UFSAR was revised to change the containment pressure instrumentation range in Subsections 5.2.3.a and 6.2.1.7 to be consistent with the actual instrumentation loop ranges and UFSAR Subsection 7.3.1.2.5 and Table 7.5-2.
SAFETY EVALUATION
SUMMARY
' J
- l. The probability of occarrence or the consequences of an accident or a malfunction of equipment l
important to safety previously evaluated in the safety analysis report is not increased because the instrumentation is not an accident initiator and is not used to mitigate the consequences of an
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accident.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no new failures are created. The instrumentation range has no impact on containment pressure.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because I
the change did not impact any parameters upon which Technical Specifications are based.
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UFSAR CHANGE DRP 7-116 DESCRIPTION:
The UFSAR was revised to reflect a design change that revised the auxiliary feedwatsr ( AF) system suction pressure setpoints for low suction pressure AF suction switchover, and AF pump trip. These setpoints were revised to disposition an operability concern for the availability of suction supply to the AF system under design basis conditions. The text in section 10 D.3.4 was revised to enhance the description of the actual process used to perform the switchover of the AF suction supply from the condensate storage tank system to the safety-related essential senice water (SX) system.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequencer of an accident or a malfunction of equipment important to safety presiously evaluated in the SAR was not increased by the changed text in section 10 D.3.4. The text now accurately reficcts the actual process used to perform the switchover of the AF suction supply from the CST to SX. This change does not represent an increase in the probability of accidents that require AF supply to the steam generators. The design change to resise the setpoints was presiously evaluated and determined to be acceptable to ensure that the safety-related supply of water to the AF system is maintained under design basis conditions. The failure modes and conscquences of the AF function have been presiously evaluated in the SAR. This change does not afTect those presious evaluations and therefore, the consequences of an accident or malfunction of equipment is not increased by this change.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the SAR was not created by this change to the text in Section 10.D.3.4. The change was made to accurately describe the process used to perform the switchover of the AF supply from the CST to SX.
l This does not represent a new accident or malfunction of equipment different from that previously evaluated in the SAR. The failure modes and consequences of the AF function have been previously j cvaluated in the SAR. This change does not create any new failure modes of the AF function.
( 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because i the resised value for AF switchover setpoint is in the consen ative direction compared to the original value, as contained in Technical Specifications Table 3.3-4, Functional Unit 6g.
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UFSAR CHANGE DRP 7-117 DESCRIPTION:
The UFS AR was revised to address changes identified in the UFSAR Conformance Review project. The changes corrected and clarified words and wording that could potentially be interpreted incorrectly and lead to perceived nonconformances. Therefore, the changes were processed to update historical information and to provide flexibility in the interpretation of the wording. The changes included corrections to acronyms and clarifications to installed equipment elevations that varied by 6 inches.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment imponant to safety previously evaluated in the safety analysis repon is not increased because the changes are administrative in nature. The contained discrepancies in acrony ms and insignificant equipment cicvation values. There is no impact on any analyzed accident.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the changes do not impact UFS AR accident-related systems, structures, and components..
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because
! the changes do not affect any parameters upon w hich Technical Specifications are based.
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UFSAR CHANGE DRP 7-118 DESCRIITION:
The UFSAR was revised to address a discrepancy betueen two sections concerning dicscl generator testing. One section had stated that a dicsci generator engine had been tested under load with the closed cycle cooling system functioning but without service water. It also stated that the engine had been tested under this condition for a period of 20 minutes. An analysis concluded that the basis for the 20-minute test statement was not credible, and the statement was revised to be consistent with another section of the UFSAR.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analy sis report is not increased because the l
change did not affect any procedures or design bases documentation associated to the design, operation, or function of the diesel generators.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the change does not adversely impact UFSAR accident-related systems, structures, and components.
- 3. The margin of safety, as defimed in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon w hich Technical Specifications are based.
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UFSAR CHANGE DRP 7-120 DESCRIPTION:
Subsection 9.2.5.3.1 of the Byron UFSAR," Ultimate Heat Sink Design Basis," was revised to clanfy the capability of the ultimate heat sink (UHS) to withstand a design-basis tornado. Certain main components of the UHS are not designed to withstand the design basis tornado. The examples provided in Subsection 9.2.5.3.2 are the essential service water (SX) cooling tower fans, fan motors, and fan drives. The UFSAR change noted that the UHS was designed to withstand the design basis tornado except for the exceptions discussed in Subsection 9.2.5.3.2 of the UFSAR. This change ensures consistency betuccn the two referenced sections of the UFSAR.
i SAFETY EVALUATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the SAR was not increased by this change. The noted exception that the SX fans, motors, and drives were not designed to withstand the design basis tornado has been previously reviewed and approved by the NRC as part of the original licensing basis for Byron Station. l
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the SAR was not created. The revised section of the UFSAR discusses that the UHS temperature could reach as high as 1100F during a normal shutdown of both umts under non LOCA conditions with j the SX fans inoperable. Even though 1100F is greater than the design basis temperature for SX of 1000F, the UFSAR analysis determined that there was no adverse impact on safety equipment as a result. The NRC accepted this as part of the original licensing basis for the plant. Therefore, no I accidents or malfunctions different from those previously evaluated were created by this change.
- 3. The margin of safety, as def med in the basis for any TS, is not reduced by this change because the change does not affect any parameters upon which Technical Specifications are based.
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UFSAR CilANGE DRP 7-124 DESCRIPTION:
The UFSAR was revised to incorporate use of procedures as an alternate alarm function for the containment floor drain sump.
SAFETY EVALUATION SUMM AR,Y:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the )
change does not alTect any accident or malfunction previously analyzed. The alternate monitoring alerts the control room operators of any degrading reactor coolant system pressure boundary to allow preemptive operator action to be taken.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the procedures allow operators to detect a one gallon per minute increase in leakage within one hour of the increase. This requirement is consistent with Regulatory Guide 1.45.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because t the change does not afTect any parameters upon w hich Technical Specifications are based.
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UFSAR CHANGE DRP 7-130 DESCRIPTION:
The UFS AR was revised to correct an error in Table 6.3-4 for the safety injection (SI) accumulator check valve clapper ann shaft materitl. The material had been incorrectly described as 57-4 Pil, but the originally supplied material by Westinghouse was inconel 718.
S_AFETY EVALUATIONjpMMARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the referenced material is a suitable material for the application. The originally supplied material by Westinghouse was Inconel 718 solution treated at 1925-1950 degrees F followed by a precipitation hardening at 1400 degrees F. Inconci 718 has been the only matenal Westinghouse has used on valves of this design per Westinghouse letter EDRE-AEE-97-281 dated 10/14/97. The change does not impact any analyzed accidents or malfunctions.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the j safety analysis report is not created because the supplied material is suitable for the application. No new failures hate been introduced.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because change does not afTect any parameters upon uhich Technical Specifications are based.
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UFSAR CHANGE DRP 7-136 DESCRIPTION:
The UFSAR was revised to reflect an alternate lineup to perform the OB control room makeup system high-cificiency particulate absorber and charcoal absoiber filter performance tests. The control room ventilation system was in the purge mode with make up filter running dampers OVC09Y, (OVC25Y),
OVC16Y (OVC32Y), OVC282Y (OVC284Y) closed and damper OVC313Y (OVC312Y) open.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because both portions for the system function in response to the accident identically when operated in the alternate lineup. Therefore, no change to the probability has occurred by this change. No change to the accident response occurred and a consequence of a malfunction of equipment important to safety has not occurred.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety
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l analysis report is not created because the response to the actuation signals following a design-basis i accident is unchanged by the alternate lineup.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because
! the change does not affect any parameters upon which Technical Specifications are based, f
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DESCRIPTION:
The UFSAR was revised to desenbc an additional lineup of the auxiliary building ventilation (VA) system during maintenance and troubleshooting of equipment located in the VA supply and exhaust plenums.
S AFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment importarit to safety previously evaluated in the safety analysis report is not increased because the alternate line-ups do not impact the VA system in such a way as to prevent it from performing its intended functions of filtering exhaust air and providing required cooling to ECCS equipment. At least two VA supply and exhaust fans are available during operation in the alternate line-ups to meet the UFSAR accident analysis assumptions, and there is no impact on the capability of the equipment to perform its design functions.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because, during both alternate VA line-ups, the charcoal booster fans maintain the auxiliary building and emergency core cooling system rooms at the required negative pressures. Supply fans are available to cool the building, if required. Required air filtration prior to release continues to occur with the alternate lineups.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because all of the Technical Specification limits specified are satisfied with either of tiic ahernate VA line-ups as long as VA supply and exhaust fans are available to be started.
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lJfSAR CHANGE DRP 7-139 p_ESCRIPTION:
The UFS AR was revised to correct a text error that had been introduced in the conversion from the FSAR to the UFSAR. The change clanfics that valves over 2-inch nominal pipe size have double-packed stuffing boxes with lantern ring leakoff connections. UFS AR Revisien 0 change ID 5.4-128 incorrectly incorporated Westinghouse System Description CAE/CBE-281.
In addition UFS AR Figure 5.1 1 (Drawing M-60-5) was corrected to show the blind flange downstream of IRYO45, w hich had been qualified to ASME Section 111 requirements during the plant constmetion.
LAFETY EVALUATION
SUMMARY
- q
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analy sis report is not increased because this ,
activity is only a correction of UFSAR 5.4.12.2 text error and Figure 5.1-1 crror. There is no impact I on accident initiators or precursors, or on equipment used to mitigate the consequences of an accident.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because no new failurcs are introduced.
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, 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon uhich Technical Specifications are based..
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UFSAR CHANGE DRP 7-140 DESCRIPTION:
The UFS AR was resised to remove the statement that " low-head safety injection pumps" provide makeup to the refueling cavity since the residual heat removal (RH) pumps are not the only means to provide flow from the refueling water storage tank (RWST) to the cavity.
SAFETY I! VALUATION SUMM ARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because use of alternate flow paths from the RWST to the refueling cavity does not introduce a dilution flow path since the dilution flow paths are still precluded. Consequences of a dilution accident in the refueling cavity will likely decrease since diverse methods of RWST makeup w ould exist.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because dilution and loss of inventory of the refueling cavity have already been analyr.cd. Use of other flow paths for RWST makeup of the cavity does affect plant systems so as to cause another kind of accident.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not afTect any parameters upon which Technical Specifications are based. The Refueling Cavity boron concentration will still comply with Technical Specification requirements.
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UFSAR CH ANGE DRP 7-141 DESCRIPTION:
The UFSAR was revised to clarify the treatment ofinstrument uncertainty for emergency core cooling system (ECCS) flow and pressure instrumentation.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change only documents how uncenainty of instruments used to validate performance of ECCS systems is accounted for in the 10 CFR 50.46 loss-of-coolant accident analyscs.
- 2. The possibility for an accident or malfunction of a difTerent type than any evahiated previously in the safety analysis repon is not created because the change merely documents how uncertainty of instruments used to validate performance of ECCS systems is accounted for in the 10 CFR 50.46 loss-of-coolant accident analyses.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there were no changes to any parameters upon which Technical Specifications are based.
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DESCRIPTION:
UFSAR Table 11.1-1 was revised to correct an error in the footnote. The table contains a list of the parameters used in the calculation of design-basis primary coolant activitics. The footnote was revised to reflect the correct ASME steam table value provided for reference conditions for cation dcmineralizer.
The value for flow is used to determine the amount ofiodine removed in the letdown demincralizers for determining realistic source terms as described elscuhere in UFSAR. The design calculation, which used the value as an input assumption, was revised and the efTect of the error was determined to be negligible.
The change ensures that Table 11.1 1 accurately reflects the design assumptions used in the dose analysis for primary coolant activitics.
l S AFETY EVALUATION
SUMMARY
l 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report was not increased because it has
, no impact on accident initiators or precursors. The dose calculation that had used the incorrect value i
was revised and the efTect of the error was determined to have a negligible impact. Therefore, the consequences of accidents presiously evaluated in the SAR are not afTected by this change.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report was not created because the use of the corrected value for water flow does not create any new accidents or malfunctions of equipment. The function or design basis of the dcmineralizer is not impacted by this change.
l 3. The margin of safety, as defined in the basis for any TS, is not reduced by this change because there were no changes to any parameters upon uhich Technical Specifications are based.
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UFSAR CHANGE DRP 7-147 DESCRIPTION:
This UFSAR change clarifies u hen one charging pump is permitted to operate in hot shutdown. The limitation is temperature dependem, rather than pressure dependent. The UFSAR was revised to change "1000 psig or less" to "330 "F" to reflect this dependency and to be more consistent with the Technical Specifications.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis repon is not increased because the change does not allow operation of a charging pump in a manner that will cause an accident. The change to the UFSAR makes it consistent with the Technical Specifications. The pump cannot be operated in a manner differently than it had been, so the probability of occurrence or consequences of an accident is unchanged.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because there is no change to the operation of the pump. The
. operrting procedures and Technical Specifications had already restricted operation. The UFSAR change is made for consistency.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the pump continues to be operated in accordance with the Technical Specifications limitations.
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UFSAR CHANGE DRP 7-148 DESCRIPTION:
The UFS AR was revised to reflect the long-term out-of-service of the boron thermal regeneration system (BTRS). Byron does not intend to operate the system again. This change adds notes in the UFSAR to state that the system is no longer used.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the BTRS cannot initiate an accident. The system is permanently isolated and cannot be used to dilute the reactor coolant system. The BTRS is not used to mitigate the consequences of an accident. The functions of the BTRS are performed by other systems. The operation of these systems are not affected by discontinued use of the BTRS.
- 2. The possibility for an accident or malfunction of a different type than any evahiated previously in the safety analysis report is not created because equipment is not operated in a different manner. The BTRS has been isolated to prevent an inadvertent dilution, and no new accident or malfunction results.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the BTRS is not addressed in the basis for any Technical Specification.
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1 DESCRifrTION:
The UFS AR was revised to remove the dimensions of the condensate polisher (CP) resin hopper. The dimensions were incorrect; they are categorized as descriptive and not as design information. Thus, they are being removed from the UFSAR text.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this UFSAR change is for documentation only. The function and operation of the CP resin hopper, w hich does not perform any safety functions or important to safety functions, is not being changed. The probability of a safety equipment malfunction is not increased.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because this change does not affect plant operation. No new failure modes are introduced.
1 The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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l DESCRIPTION:
l l This UFSAR change revised the applicable resision of Regulatory Guide 1.63, " Electric Penetration l
Assemblics in Containment Structures for Light-Water-Cooled Nuclear Power Plants," from Revision 2 to j Resision 0. The resision had been incorrectly changed during the conversion from the FSAR to the UFSAR.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l l important to safety previously evaluated in the safety analysis report is not increased because the i resision to the Regulatory Guide does not affect any accident initiators or precursors. The design function of the electrical penetrations is to accommodate the postaccident conditions without exceeding the designed leak rate. Because this function is performed after the accident has already occurred, there is no affect on the probability of the accident. The electrical penetration assemblics continue to perform this function.
- 2. The possibility for an accident or malfunction of a different 13pc than any evaluated presiously in the safety analysis report is not created because the change to the resision does not affect equipment operation or equipment malfunction. The equipment is not postulated to malfunction and cause an l accident; therefore, the consequences are bound by the current accident analyses. The requirements in Resision 0 are appropriate based on the date that the Byron construction permit application was docketed.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect the basis for any Technical Specification.
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FIRE PROTECTION REPORT CHANGE FDRP 17-046 DESCRIITION:
The Byron Fire llazard Sections 2.2 and 2.3 of the Fire Protection Report were revised to reflect design changes resulting from DCPs 9600192 and 9600193. The design changes made minor changes to the combustible loading values in fire zones 8.5-1 and 8.5-2 due to the addition of a new heat exchanger and two gallons of tube oil to the motor-driven feedwater pumps.
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SAFETY EVALJATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes make insignificant changes to combustible loading in the affected fire zones. The Fire Protection Report Fire Hazard Analysis conclusions are not affected. The additional cooling capability of the lubricating system of the motor-driven feedwater pump enhance the performance of the pump, however, this pump is non-safety related and is not credited for safe shutdown.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the motor-driven feedwater pump is not needed for safe shutdown of the plant and there are no safe shutdown equipment close by to this pump. l
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not afTect any parameters upon w hich Technical Specifications arc based.
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FIRE PROTECTION REPORT CHANGE FDRP 18404 I
l DESCRIPTION:
The Byron Fire Hazard Analysis in Section 2.3 of the Fire Protection Report was revised to reference Byron SER Supplement No. 5, Section 9.5.1.4, in fire zones 3.2A-1 and 5.2-1. The reference was added to clarify w hich bus duct penetrations are provided with fire stops. The clarification states that fire stops
- will be provided where bus ducts penetrate walls that separate redundant shutdown divisions. This is not l a change of Byron's documented commitment or NRC's acceptance.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the revision is not a change, but a reference to supporting documentation. Fire evaluations at the subject locations confirmed the credited fire barriers satisfy the licensing basis. The original Fire llazard and Safe Shutdown analysis conclusions are unchanged.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the l safety analysis report is not created because the change did not adversely affect credited fire boundaries or other fire protection featurcs and the consequences of previously evaluated design basis fires did not change.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon uhich Technical Specifications are based.
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l FIRE PROTECTION REPORT CilANGE FDRP 18-015 DESCRil' TION:
The Byron Fire Hazard Analysis in Section 2.3 of the Fire Protection Report was resised to state some steel beams embedded in the 3-hour fire rated barriers of the dicscl generator and switchgcar room air shafts are not firc-proofed. This is acceptable because the worst-case potential fire exposure will not affect the structural integrity of the beams or fire barrier.
l S_AFETY EVALUATION SUMM ARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the change did not impact conditions likely to cause a fire. Fire evaluations at the subject locations confirmed the credited structural beams do not require fire resistant coatings to satisfy their design basis for worst-case fire exposure. Also, the credited fire barriers are not impacted. The original Fire Hazard and Safe Shutdown analysis conclusions are unchanged.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change did not adversely afTect credited fire boundaries or other fire protection features and the consequences of previously evaluated design-basis fires did not change.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based. j l
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El_RE PROTECTION REPORT CHANGE FDRP 18-028 DESCRIPTION:
The Byron Fire Hazard Analysis in Sections 2.2 and 2.3 of the Fire Protection Report was revised to include the combustible loading resulting from Thermo-Lag fire barrier abandoned-in-place on cable trays and conduits and their associated supports. Previously Thermo-Lag was not included in the combustible loading, but recent NRC guidance directed that it should be considered a combustible material.
SAFETY EVAL UATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the increased fire loading in the areas containing Thermo-Lag was either a negligible change from the analyzed loading or the changed value was still within combustible loading values considered to be low. The previous fire hazard analysis conclusions were not changed when the increased combustibic loading was considered.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because, as stated above, the fire hazard analysis conclusions were not changed. The change also did no' affect credited fire boundaries or other fire protection features and the consequences of previously evaluated design basis fires did not change.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon uhich Technical Specifications are based.
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FIRE PROTECTION REPORT CHANGE FDR.P 184)31 DESCRIPTION:
The Byron Fire Protection Report Section 3.0, Table 3 1, was revised to reflect design changes resulting from DCP 9600302. The design change de-energized and abandoned in place the extended discharge portion of the halon fire suppression system in Fire Zone 3.3B-1. Special testing in this zone has demonstrated that the extended discharge capability is no longer necessary to satisfy fire suppression requirements.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because special testing has confirmed the halon fire suppression capability can satisfy the design requirements for this zone, without relying upon the extended discharge capability. The original Fire Hazard Analysis conclusions for a design basis fire in this zone is not affected by the change.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the extended discharge equipment was de-energized and l abandoned in p' ace. The equipment as left will not impact other equipment or structures so as to create an recident or malfunction of other equipment.
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- 3. The margi's of safety, as defined in the basis for any Technical Specification, is not reduced because the changc did not affect any parameters upon u hich Technical Specifications are based.
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FIRE PROTECTION REPORT CHANGE FDRP 18-035 DESCRIPTION:
The Byron Fire Protection Report Section 2.1.4.1 was revised to specify two additional minor modifications made to UL-labeled doors to accommodate applications at Byron Station. The modifications included a door pull handle to assist the closing of doors in areas with differential air pressure that made it difficult to close the door. The second modification acknowledges that fire doors may have been installed with cardboard shims behind the door hinge in order to achiese the proper alignment of the door. Doors modified with the new pull handles are categorized as " fire door oflabel construction," which were discussed previously in Section 2.1.4.1.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the change only impacts fire doors. The fire endurance of the door was not affected by the modifications.
The added door pull handle does not affect the capability of the door to remain latched and does not affect the capability of the door to resist deflection or allow flaming to reach the unexposed side of the door. Similarly, the presence of the cardboard shims does not change the fire endurance capability of the door.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change does not affect the fire endurance capability of the fire door. The fire barrier remains intact and the fire is contained within the area that has been previously evaluated in the Fire Hazard Analysis. The change allows the continued confidence that the fire doors will be closed, properly aligned, and undamaged by the stress of closing the doors against differential air pressure with previously installed door hardware.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon u hich Technical Specifications are based. l l
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FIRE PROTECTION REPORT CilANGE FDRP 18-037 i DESCRIPTION:
l The Byron Fire Hazard and Safe Shutdown Analyscs in Sections 2.2,2.3, and 2.4 of the Fire Protection l Report were revised to reflect design changes resulting from DCP 9600375. The design change removed l controls for Train B control room ventilation system from the Unit I remote shutdown panel IPLOSJ. The l Train B controls were moved to a new local panel, IPLO5JA, located one level below panel 1PLO53. The l Train A controls for this system remain at panel IPLO51, as before. The design change prevents a single l fire at the remote shutdown panel from affecting both trains of the ventilation system. This design change i
was installed as a corrective action from Licensec Event Report 454-95-005.
l SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the changes make insignificant changes to combustible loading in the affected firc zones and the change does not affect the functioning of existing equipment remaining on the remote shutdown panel. The capability to operate the Train A portion of the main control room (MCR) ventilation system remains unchanged, except that the location of the controls are on a ditTerent panel. No Fire Protection Report Fire Hazard Analysis conclusions are affected in any way. The Safe Shutdown Analysis conclusions are enhanced because the potential to loose both trains of the MCR ventilation system due to a single
- fire at the remote shutdown panel location is climinated.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no functional changes were made to the Train B controls and normal plant operation is not afTected. The existing cables and cable routing were used, except
, for the cable termination at the new panel. The new panel and cable tennination are designed and I
installed per approved scismic and electrical design criteria.
- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because the change did not afTect any parameters upon uhich Technical Specifications are based.
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FIRE PROTECTION REPORT CH ANGE FDRP 18-039 DESCRIPTION:
The Byron Fire Protection Report Section 3.0, Table 3-1, was revised to specify minor deviations from NFPA 14," Standpipe and Hose." The deviation states that only trained fire brigade personnel use hose stations. Hosc rects that require replacement may be purchased non-UL or FM listed, as replacement UL or FM-listed hose rects are no longer available. Non-listed hose rects do not impact fire-fighting capability by the station's trained fire brigade. Also, the hose reels are not be labeled " Fire Hose for use by occupants," as specified in NFPA 14.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change does not alter the conclusion that any fire can be fought with the full capability of the station's fire brigade. The purpose of the hose rect is to store the hose when not in use and to allow its access if called upon by the fire brigade. This function of the hose rect requires no unusual capability susceptible to failure. The hose station continues to be available for use by the fire brigade. The NFPA standard includes requirements, such as the label for use by occupants only, that are intended for applications without a trained fire brigade.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety anal) sis report is not created because the change does not afTect the capability of the trained fire brigade to use the hose station. The change allows the continued use of the hose recis presently installed in the station, for which the fire brigade has been trained.
- 3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based.
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LPP 97-007 l
l DESCRifrrlON:
l This special test provided procedural guidance to perform hydrostatic tests on the dicscl generator fuel oil system to comply with the 10-year surveillance requirements in Technical Specifications. Technical l Specifications require a 110% hydrostatic test of the system, which was built originally to ASME Section 111 criteria.
! SAFETY EVALUATION
SUMMARY
( l. The probability of occurrence or the consequences of an accident or a malfunction of equipment
! important to safety picsiously evaluated in the safety analysis report is not increased because the affected dicsc1 generator was inoperable during the performance of the test.
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, 2. The possibility for an accident or rnalfunction of a different type than any evaluated presiously in the l
safety anal) sis report is not created because the affected diesel generator was inoperable during the performance of the test. In addition, standard hydrostatic testing methodology was utilized to prevent ;
over-pressurization of the system.
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! 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because I l the changes do not affect any parameters upon w hich Technical Specifications are based.
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SPP 97-017 DESCRIPTION:
This special test verified the necessary functions to satisfy the modification testing requirements for the covers over the emergency stop pushbuttons on the dicscl generator local control pancis installed under DCPS 9600052 and 9600053. The test verified that this installation did not impact the Technical Specification functional requirement that the emergency stop pushbutton can lockout a dicscl generator.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the test was performed during a condition in which the diesel generator was inoperable and not required to perform its intended safety function.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the test was performed during a condition in uhich the dicscl generator was inoperable and not required to perform its intended safety function.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the chr.nges do not affect any parameters upon which Technical Specifications are based.
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SPP 97-020 DESCRifT10N: -
This special test verified the necessary functions to satisfy the modification testing requirements for the i new air dryers for the dicscl generators installed under DCP 9600046/9600047. This test involved the setup of the new air dryer refrigeration system and a dew point verification. The dew point verification necessitated the de-pressurization of one of two starting system air receivers. During installation, a change / clarification was made to the testing acceptance criteria. In addition, setpoint changes97-041 and 97-042 were installed. SPP 97-020 was revised under a temporary procedure change to reflect these )
changes to the design and operation of the new air dryers.
l SAFETY EVALUATION
SUMMARY
l :
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this test satisfied the required testing criteria without impacting diesel generator operability. Additionally, the revision to the special test was evaluated under different configuration management processes and in no way degraded dicscl generator operability or reliability. l 1
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the safety function of the diesel generators associated with ,
the air dayers under test was not impacted in any way. I
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon which Technical Specifications are based.
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SSP 97-021 DESCRIPTION:
This special test procedure was written to isolate scal injection to the reactor coolant pumps uhile the pumps are operating. During the evolution, three pumps were secured and only one pump was running.
This configuration was required to repair pipe cap leakage on valves 2CV061 and 2CV202.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because a reliable means of reactor coolant pump seal integrity was still available through the evolution. The procedure required that maintenance be stopped and component cooling system water restored if component cooling were lost. The procedure ensured proper scal injection flow was established following maintenance to avoid crud blockage consequences uhile scal injection was secured. The equipment failure that is associated with is a reactor coolant pump seal failare, which would result in a small-break loss-of-coolant accident under worst-case conditions. This was not anticipated since component cooling was required to provide scal integrity via the thermal barrier.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because other flow paths remain available to ensure reactor coolant system (RCS) inventory is maintained. RCS boration levels are adequate, and reactor coolant pump seal integnty is maintained. The procedure included steps to verify proper scal injection flow following maintenance.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the procedure was conducted in Mode 4, which requires a reduced pressure. Technical Specification 3.4.6.2, w hich limits controlled leakage, does not apply at the test pressure.
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SPP 97-024 QESCRIPTION: j This special test exercised the control rod drive bank overlap thumb u heel switches and then tested l
functionality by resetting and manually incrementing the bank overlap unit. Exercising the switches j served to avoid problems caused by dirty switch contacts. '
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the affected accidents assume certain failure of the bank overlap function. Administratively enforcing bank overlap has no effect on the accidents, their initial conditions or consequences. The design of i the rod drive system does not allow the bank overlap function to fail such that the accident is worse j than already analyzed.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the i safety analysis repon is not created because the test procedure administratively enforced bank overlap requirements. Before the reactor would reach a condition outside the analyzed bank overlap condition, the procedure required a reactor trip.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because i the test preserved properly sequenced and overlapped rod motion.
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l-( SSP 97-031 DESCRIPTION:
l This special test was performed to de-energize 480vac bus 134Z to change out 480vac feed breaker for maintenance.
l- SAFETY EVALUATION
SUMMARY
! 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment
! important to safety previously evaluated in the safety analysis report is not increased because this l
procedure is not an initiating event for the accidents listed. It also does not impact the ability to l mitigate the consequences of an accident.
! 2. The possibility of an accident or a malfunction of a different type than any evaluated previously in the I safety analysis report is not created because this procedure does create a new failure mode.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change did not affect any parameters upon which Technical Specifications are based.
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SPP 97-075 DESCRIPTION:
In this special test, the reactor coolant system crossover lines were partially filled with dcmineralized water during steam generator replacement (SGR) outage in order to lower dose rates during work activitics in the area. This was consistent with ALARA principles. In addition, reactivity concerns were administratively controlled by the out-of-senice program, and chemistry concerns were addressed by l sampling the water during draining to verify chemistry specifications.
SAFETY EVALUATION
SUMMARY
1 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment i important to safety presiously evaluated in the safety analysis report is not increased because the plant was defueled to support SGR activitics. All cight steam generator (SG) legs were severed, and dcmineralized water was placed in the severed crossover legs from the SG to an elevation of 388 feet to lower local arca dose rates. The loop stop isolation valves were closed and out of service.
Temporary hose was used as ! cycl indication to prevent disk pressurization leakage from spilling out into the severed piping. The procedure had no impact on accident initiators or precursors, and did not impact the ability to mitigate the consequences of an accident.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the plant was defueled to support SGR activitics. During restoration, reactivity and chemistry issues were administratively controlled through the use of the out of senice program and chemistry sampling respectively. No new failures were created.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the Technical Specifications do not specifically address reactor coolant system parameters in the mode of applicability. Restoration activitics were planned and executed to verify all applicable
. specifications were met, prior to the plant entering the next mode.
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SPPs97-082. 97-083.and 97-034 DESCRilrTION:
These special test procedures supported the alignment and positioning of all heat exchangers, pumps and valves required to perform surveillance procedures 0/1/2BVS XLT-3 (13utterfly Valve Diagnostic Testing) on valve ISX007 - essential senice water (SX) Unit I component cooling (CC) heat exchanger throttle vah e, and 1/2SX010 - SX cooling tower basin 1/2A return header isolation valve.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because adequate SX and CC flow at normal operating temperature is supplied to all components that remain in senice during the testing. If any abnonnal plant conditions arise, the procedurc would be exited and the SX system restored to a functionally equivalent pre-test alignment. Since SX and CC temperature and flow remain within the analyzed band during the perfonnance of this procedure, the consequences (predicted off site dose levels) during an accident are not increased. Slightly lower than nominal flow rates are not considered significant per Chapter 5. The SX and CC systems function in accordance i with the accident analyses if an accident were to occur during the performance of this test.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the safety analysis report is not created because the plant alignments specified in the procedure do not create any new equipment failure modes. Adequate cooling flow remains supplied to all SX and CC-seniced components that remain in service during the testing. The plant alignments specified in the procedure do not affect any accident initiators. The accident analyses remain bounding.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the Technical Specifications action statements are entered when an SX component or CC heat exchanger is taken out of senice or isolated. No parameter used to establish Technical Specifications has been changed by this procedure.
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SPP 97-093 DESCRIPTION:
This procedure, "Depressurization of Emergency Core Cooling System (ECCS) Piping," was written to use the safety injection system test line to equalize pressure between the 2D accumulator and the ECCS piping downstream of the 2S18956D check valve. The intent of the leakage was to increase the differential pressure across the 2S18948D check valve in an effort to reduce in-leakage into the 2D accumulator.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the test line was not pressurized beyond its design rating and the accumulators were always available to mitigate the consequences of an accident.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there were no changes to any parameters upon uhich Technical Specifications are based.
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SPP 97-106 DESCRIPTION:
This procedure," Pressurizer Spray Valve Bypass Flow Adjustment," was written to adjust the spray valve bypass flow to optimize pressurizer heater demand and wturn the system to its design condition.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analy sis report is not increased because pressurizer spray flow is not credited in the Chapter 15 analyses. Spray vahr bypass flow is not necessary to prevent thermal shock or promote chemical , mixing in the pressurizer.
- 2. The possibility for an accident or malfunction of a different type than any evahiated presiously in the safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there were no changes to any parameters upon u hich Technical Specifications are based.
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l SPP 97-118 l
l- DESCRIPTION:
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This procedure supported the modification testing for the sequence of events recorder replacement on Unit 1. This procedure satisfied the modification testing requirements for DCP 9700181.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment
- important '.o safety previously evaluated in the safety analysis repon is not increased because the field l inputs and wiring did not change. The field wiring inputs to the sequence of events recorder via a connector plug. Input points were not added or deleted from the computer during this modification.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the L safety analysis report is not created because the procedure only tests the sequence of events recorder l by inputting signals into the recorder and monitoring the output. The balance of the annunciator system is unaffected. This test verifies 32 points at a time; all other points were operable during this testing. This test does not impact any other systems or functions.
l 1 The margin of safety, as defined in the basis for any Technical Specification. is not reduced because the change does not affect any parameters upon w hich the Technical Specifications are based.
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SPP 97-127 DESCRIIrrlON:
This procedure, " Pressurization of IS18819C Check Valyc," was written to use the safety injection pump to pressurize the downstream side of IS18819C through the safety injection system test line in an attempt to improve the seating of the check valve and to reduce back leakage.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the test line was not pressurized beyond its design rating. The safety injection system and its containment isolation valves remained within the requirements of the Technical Specifications at all times.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there wcre no changes to any parameters upon which Technical Specifications are based.
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f f' SPP 97129 p_ESCRIPTION:
This procedure, " Pressurization of IS!8819C Check Valve," was written to use the safety injection pump to pressurize the downstream side of IS!8819C through the safety injection system test line in order to perform a visual leak inspection following replacement of the valve.
l SAFETY EVALUATION SUMM ARY:
l l 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment i
important to safety previously evaluated in the safety analysis report is not increased because the test line was not pressurized beyond its design rating. The safety injection system and its containment isolation valves remained within the requirements of the Technical Specifications at all times.
i l 2. The possibility for an accident or malfunction of e different type than any evaluated previously in the I
safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l there were no changes to any parameters upon w hich Technical Specifications are based.
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SPP 97-131 DESCRIPTION:
This procedure, " Scat Leakage Test of IS18948C and ISI8956C," was written to use level changes in the IC accumulator to measure seat leakage through the check valves after flow was passed through the valves during an earlier test on the ISI8819C check valve.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the test line was not pressurized beyond its design rating. The safety injection system and its containment isolation valves remained within the requirements of the Technical Specifications at all times.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the test line was not being used in a manner that was inconsistent with its design.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there were no changes to any parameters upon which Technical Specifications are based.
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4 SPP 97-137 f
DESCRIPTION:
This procedure was performed to record the normal baseline frequency response of the loose parts monitoring (LPM) system at Mode 5 following the installation of replacement steam generators (RSGs) and tle resultant modifications to the LPM system performed under DCP 9500394. This procedure impacted the RSGs near j tle LPM sensors with known masses and record the results at panel IPA 441.
! SAFETY EVALUATION
SUMMARY
! 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety presiously evaluated in the safety analysis report is not increased because the test l does not require plant operation different from an analyzed configuration. No modifications or
! adjustments of systems, structures, or components (SSCs) were made.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the plant was operated in a manner that has already been l analyzed. No modifications or adjustments of SSCs were made.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this test does not affect any parameters upon which Technical Specification are based. The LPM system is required to be operable in Modes I and 2; The test was performed in Mode 5 I
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SPPs97-150 and 97-151 DESCRIPTION:
These procedures verified the necessary functions to satisfy the modification testing requirements for the interposing latching relay in the control logic for the OA and OB deep well pumps and turbine bearing oil i pump installed under DCP 9600264. The test verified all circuit functions in addition to the reactor l protection functions modified under the DCP.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment imponant to safety previously evaluated in the safety analysis report is not increased because the ,
reliability of the ultimate heat sink remained unaffected for both units during the test performance. )
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the tests were perfonned with the affceted equipment i inoperable and not required to support ultimate heat sink functional requirements.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the changes do not affect any parameters upon which Technical Specifications are based. The reactor protection logic impacted by the tests is not required during the mode (5,6, defueled) in which the test was performed.
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SPP 97-156 DESCRIPTION:
This procedure isolated the Unit 0 station air compressor (SAC) and receiver and slowly bled the pressure from the receiver until the SAC auto-started on low receiver pressure. The SAC was in stand-by per station procedure BOP SA-1.
SAFETY EVALUATION
SUMMARY
1 i
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment '
important to safety previously evaluated in the safety analysis report is not increased because the Unit 0 SAC and receiver were isolated from the station air system. The SAC had no interaction with any other plant equipment.
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because the Unit 0 SAC and receiver were isolated from the station air system and the plant. No new failure modes were introduced.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not alTect any parameters upon which Technical Specifications are based, q l
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Administrative Technical Requirements Amendment 11 DESCRIPTION:
The sample analysis frequency in Administrative Technical Requirements Table 3.12-1 was changed from weckly to biwcekly for radioiodine canisters at radiological environmental monitoring program (REMP) radioiodine and particulate environmental sample stations.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety previously evaluated in the safety analysis report is not increased because no i buildmgs or equipment is affected by the change. The REMP monitors environmental conditions j outside of the site boundary to verify compliance with release rate limits.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this sample frequency change does not impact UFSAR accident-related systems, structurcs, and components.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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Administrative Technical Reauirements Amendment 12 DESCRIPTION:
The lower limit of detection (LLD) for tritium in Table 4.12-1 was revised in conjunction with a change to Table 12.5 3 in the Offsite Dose Calculation Manual. The LLD for tritium was changed from 200 pCi/l to 2000 pCill to allow in-house sampling of environmental surface water. In-house sampling equipment is not sensitive enough to detect 200 pCi/l of Tritium. A note was added to the Table to ensure that Off-site vendors meet the original LLD of 200 pCi/1.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment l important to safety previously evaluated in the safety analysis report is not increased because no buildings or equipment is afTected by the change. The 2000 pCi/l LLD is an order of magnitude less than the 20,000 pCi/l required by 40 CFR Part 141 for the reporting level for tritium in drinking water. ;
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the f safety analysis report is not created because this LLD requirement does not impact UFSAR accident-related systems, structures, and components (SSCs).
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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l DCR 970047 pfSCRIPTION:
DCR 970047 revised drawings and UFSAR figures to show the correct design configuration of the j cssential service water cooling towcr (SXCT) basins. The UFSAR changes were initiated via DRP 7-068.
The changes included:
. Revised UFSACigures and added a new UFSAR Figure to show the anti-vortex duct and trash rack structure in tl> V.iCT basin.
. Revised the design drawings to de e, te reference to a normal operating water level at clevation 873'-9"
. Corrected drawing references.
. Deleted redundant UFSAR Figures.
- Replaced 1)FS AR Figures with controlled design drawings.
SAFETY EVALUATION EUMMARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the drawing and UFSAR figure changes did not adversely affect system design bases The design analyses for ultimate heat sink (UHS) temperature is based on the Technical Specification minimum water levels in the SXCT basins. The design analysis for the essential senice water makeup system is based on a minimum usable water level that provides adequate flow through the anti-vortex duct.
The anti-vortex duct / trash rack design has a much larger surface arca than the original box-t3pc trash rack and is less likely to become blocked by debris.
, 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the drawing changes did not alter the design basis or function of any sptem or component. New accidents or malfunctions are not credible.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the UllS temperature analysis is not afTected by the anti-vortex duct configuration. The analysis is based on the Technical Specifications minimum water level in the SXCT basins.
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pCR 970048 DESCRIPTION:
DCR 970048 revised drawings M-39-1 and M-124-1 to reflect the as-built configuration. Valves, OWMXXXXX, ICDXXXXX ,2CDXXXXX, and sample point valves added to drawings. The valves were added to allow hookup of demineralizer trailers to provide additional makeup capacity to condensate storage tanks (CSTs).
SAFETY EVAL,UATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the CST function of supplying auxiliary feedwater following an accident is not affected. The new valves are used to add water to the CSTs. They do not impact the water level in the CSTs. CST level indication is availabic in the main control room for remote monitoring.
- 2. The possibility for an accident or malfunction of a different t3pc than any evaluated previously in the safety analysis repon is not created because, upon loss of CST level, an automatic low suction pressure function supplies essential service water to the auxiliary feedwater system. This event is bound by the current analysis; no new failures are created.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there is no impact on the ability to maintain the required CST level.
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l DCR 970063 DESCRIIrflON:
I This change revised drawing M-48, sheet 16 to reficct a foot valve that was installed on the suction line from the turbine building fire and oil sump to the process radiation monitor pump, OPR05P. The foot valve functions to keep the line primed when the pump is not running.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report was not increased because the
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fire and oil sump radiation monitoring skid continued to prevent the inadvertent release of radioactivity from the plant. There is no failure mode for the foot valve that could increase the probability of a radioactivity release since any loss of sample flow would result in an alarm in the )
control room. The skid not capable of accident initiation. There is no increase in the amount of l radioactivity contained in the fire and oil sump, and there is no increase in the release rate. The skid has no impact on accident mitigation systems.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis repon is not created because the foot valve is an in-line component for the suction of the fire and oil sump process radiation monitor pump. The valve normally has no impact on the operation of the radiation monitor. A failure of the valve would cause the san'c types of malfunctions that the monitor currently experiences, (loss of sampic flow). l 1
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the change does not affect any parameters upon u hich Technical Specifications are based.
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105 L.
i DCR 97(X)93 l
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l DESCRIPTION:
1 UFSAR Figure 9.3-2, sheet 2 was revised to reflect the as-built configuration of the Unit 2 auxiliary steam boiler.
l SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment 1 L important to safety previously evaluated in the safety analysis report is not increased because auxiliary j steam supply for the boilers is not addressed in any accident.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because adding the as-built of the auxiliary steam supply does not l change boiler operation. No new failures are introduced.
l 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l the change does not afTect any parameters upon uhich Technical Specifications are based. )
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DCRs 970247 and 960026 DESCRIPTION; The M-55 series of drawings was revised to reflect the as-built routing of the instrument air lines in Unit I containment and make minor changes to other instrument air drawings. Drawings in the M-54 series (station air), M-60 series (pressurizer) and M-63 series (fuel pool cooling) were also resised due to the interface these drawings have with the M-55 scrics.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis repon is not increased because the instrument air system is not described in any analyzed accidents. The changes do not impact the function of the instrument air system continues to provide dry, oil free air for plant equipment. There are no changes to accident initiators or precursors.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated presiously in the safety analysis report is not created because the instrument air system is not required to function during or after an accident. No new failures have been created.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not afTect any of the parameters upon u hich Technical Specifications are based.
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DCR 97029I DESCRIPTION:
The containment heavy load path was revised to include the pressuriter in Mode 6 with the reactor coolant system vented through minimum 2-square inch vent path or while defueled to perform maintenance.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety pres iously evaluated in the safety analysis report is not increased because the afTected components do not perform any safety function during Mode 6 or in defueled condition.
Calculation BYR97-451, Revision 0, evaluated every component in the pressurizer coffin area. This activity does not impact any accident evaluated previously. The analysis indicated that this activity has no impact on consequences of an accident nor any impact on the off-site dose release
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the affected componems are not required for the modes for u hich the procedure applies. T his activity does not affect adversely impact accideut-related systems, structures and components (SSCs).
- 3. The margin of safety, as defined in the basis for ar.y Technier) Specificanon, is not reduced because the change does not alTect the parameters upcn w hich Technical Specifications are based.
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Work Reauests 940014881 throuch 940014890 l
DESCRIPTION:
These work requests installed temporary mechanical line stop equipment, including hot tapping machine, l sandwich valve, stopple plugging machine, and plugging head on the essential sen ice water (SX) system
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cooling tower underground return piping. They also installed a temporary working platform below riser j piping on out-of-senice cooling tower cells. I I
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SAFETY EVALUATION SUMM ARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because the SX mechanical draft cooling tower return piping is not an accident initiator and does not act as a
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radiological release path during any accident. The temporary installations did not adversely impact reactor primary systems, pressure boundaries, or in-plant radiological systems. Operation of the SX cooling tower basin was not afTected because at least six cooling tower cells remained available, and SX system function was not impacted. The impact ofline stopping equipment and working platform was evaluated by calculation and found acceptable. The line stopping equipment was scismically restrained to prevent adversely impacting nearby safety-related piping or equipment. The working l
platform was scismically qualified to ensure that it did not impact the cooling tower structure. The i line stopping equipment and working platform did not affect the consequences of a cooling towcr malfunction because the temporary equipment would not impact the ability of the cooling tower to perfonn postaccident cooling. j
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously i- the safety analysis report is not created because piping system failure and system redundancy were considered as part of the original system design. The scismic working platform served as a foreign material exclusion barrier, preventing cooling tower materials from dropping into the tow er basin, where they could have potentially restricted the supply of SX water to the plant. In addition, underwater divers were on standby, to immediately remove any foreign material that may have fallen past the platform and into the basin. Contingency materials were available to install blind flanges in the unlikely event that line stop equipment leakage became excessive.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the line stopping equipment was capable ofisolating SX piping at system design pressure and temperature. The temporary line stopping equipment was scismically restrained, to prevent potentially exceeding ASME allowabic piping stress levels during a scismic event. The NRC resiewed and approved a temporary relief request to ASME Code requirements. During the temporary installation period, SX cooling tower basin levels were maintained above Technical Specifications limits.
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l Work Reauest 97000953 I l
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DESCRIPTION:
A temporary scaffold was crected to support maintenance activitics on valve 2FWOO9D due to congestion I near the valve. The scaffold was supported by the feedwater piping on either side of the valve.
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SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because affected components were capable of withstanding the additional loads due to the scaffold for both normal and scismic loads. The scalTold was constructed in a manner that would prevent any adverse interactions with other components during a scismic event. In addition, the feedwater valve was closed and out-of-service, thereby climinating the potential for inadvertent opening of this valve. There were no l changes to the analyzed accidents.
I 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the l safety analysis report is not created because the affected components were capable of withstanding the l additional loads due to the scaffold for both normal and scismic loads. The scaffold was constructed in a manner that would prevent any adverse interactions with other components during a scismic event.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect the parameters upon which Technical Specifications are based.
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1 Work Reauest 970019152 DESCRIPTION:
This work request isolated and removed portions of piping associated with replacement of the regeneration waste drain tank (RWDT). It was necessary to operate some systems differently than described in the UFSAR when the tank was out of service. The safety evaluation included the alternate activitics that were in place while the lines were out of service and the structural integrity of the pipe subsystems when they were no longer connected to the tank.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report was not increased because temporarily removing the RWDT reduced the probability of a liquid radwaste leak. The number of tanks that wcre potential sources ofleakage was reduced. Interim opcmtion without the RWDT did not increase the consequences of an accident since the RWDT does not function to limit releases or mitigate the consequences of releases. The total volume of contaminated water generated in the station did not change. Gidy the stwage location and flow paths were changed.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because all equipment was used in a manner that was consistent with its design and intended function. All liquid normally directed to the RWDT was processed using alternate flow paths that already exist or temporary alternate flow paths to systems that were capable of accepting this water. Inadvertent flow to the RWDT was prevented by closing and taking inlet valves out of service.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.
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Work Rcouest 970027541 DESCRIPTION: 1 A temporary cover was installed over the spent fuel pool to prcTent foreign material intrusion during work activitics.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the fuel handling building and equipment are not affected by the change. There was no adverse effect on fuel pool cooling and fuel building ventilation systems. No fuel was transferred with the barrict cover in place; thus the probability and consequences of the bounding accident, dropped fuel assembly accident, are not increased.
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- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety anal3sis report is not created because the temporary cover does not adversely impact UFSAR '
i accident-related systems, structurcs, and components (SSCs). The addition of the cover does not introduce any adverse interactions between any SSCs.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon u hich Technical Specifications are basel i 4
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BAP 2000-3 Series Procedures DESCRIPTION:
BAP 2000-3 scrics procedures were resised to proside more flexibility in recording parameters and to allow use of a computer spreadsheet for tracking criticality analysis parameters.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analysis report is not increased because transferring the resiew of actual versus minimum required burnup from the deleted procedure to a free-formatted form required to contain the same parameters has no effect on dilution flow paths.
The probability of a misplaced fuel assembly does not increase since the same review of the same parameters is being performed, yet with increased ficxibility to accommodate various configurations.
The change to the format used during fuct assembly movement planning has no effect on those systems or processes dealing with criticality consequence mitigation.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no change is taking place other than giving the preparer and reviewer of fuct assembly configuration strategics more flexibility in how they organize and document their resicw. This cannot create a new accident.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based. The assumptions in the spent fuel pool criticahty analysis continue to be met. l l
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Temporary Prosedure 97-0-208 for BOP RC-4a DESCRIPTION:
Procedure BOP RC-4a was changed temporarily to allow the use of the pressurizer auxiliary spray system (via the ICV 8145) to slowly spray down the pressurizer during draining reactor coolant system (RCS) to support steam generator replacement (SGR) activitics. The procedure change was revised to decrease the local arca dose from the pressurizer surge line by extended flushing of the line.
SAFETY EVALU4IlON
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the use of auxiliary spray is allowed, as long as the maximum spray water temperature of 320 *F is monitored. In Mode 5, this temperature is not a concern.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because if the auxiliary spray system should fait, draining and inventory control would still be available through normal charging flow paths.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because Technical Specifications action statements already apply to the temporary lincup. No other parameters are affected.
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1 Er_ogedure BOP RH-6 l
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1 Operating procedures wcre revised to allow manual or local operation of residual heat removal (Ril) system cold and hot leg isolation valves in Mode four, 1
SAFETY EVALU ATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because manual or local operation of the Ril component of emergency core cooling system does not initiate an esent.
l The consequences of an accident ia Mode four are not increased because the components arc l availabic. The " stable reactivity and limited core cooling requirements" local or manual operation can mitigate the consequences of an accident.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the l safety analysis report is not created because manual or local operation of the valves is not an initiating event, and with the limited core cooling requirements RH can be used as previously evaluated.
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- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because l
the probability of a LOCA in Mode 4 is considered unlikely and the flew path can be manually realigned.
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1/2BOS SX-sal Procedure Revisions PESCRIPTION:
Procedures 1/2BOS SX-SA1 provide operator instruc'. ions for flushing the essential service water cross-ties between thejacket water coolers associated with opposite train dicsci generators. These procedures were revised to provide additional guidance related to administrative controls to maintain both trains' diesel generator operable throughout the flushing evolution.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the administrative controls implemented by the procedure revisions do not affect the dicscl generator's ability to function in mitigating the consequences of accidents.
- 2. The possibility for an accident or malfunction of a dilTerent type than any evaluated previously in the safety analy sis report is not created because the operability of both train's dicsc1 generator is maintained throughout the flushing evolutions.
l 1. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because I
the change does not affect any parameters upon which Techr:ical Specifications are based.
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1/2BVS 13.4-lb DESCRIPTION:
Procedures were revised to clarify rod drop requirements. Specifically, the requirement to perform statistical calculations for two standard deviations on rod drop times with the associated requirement to drop outlying rods three more times was replaced with a requirement to qualitatively assess the rod drop times with historical data and re-drop the rods as appropriate. The previous requirement was a UFS AR requirement for Initial Startup Testing and is not required for subsequent plant operation. The requirement was clarified in the UFS AR via DRP 7-027.
SAFETY EVALUATION
SUMMARY
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- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this change is consistent with the safety analysis report. The safety analysis report required the 2-Sigma criteria only for initial stanup testing; therefore, removal of this requirement at this time does not introduce an increase in any presiously evaluated probabilitics or consequences. The performance of rod drop time measurements is not a precursor to any of the evaluated accident. Therefore, the ;
climination of some repeated testing cannot increase the probability of any of these accidents. j The rod drop times for all rod control cluster assemblics are still confirmed to be less than the assumed time required by Technical Specifications. Decreasing the repetition of the rod drops cannot 1 increase the time for a rod to drop, but it can help prevent excessive equipment degradation due to less wcar and tear.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because rod drop testing retains the same methods as previously evaluated and used. The only change is a reduction in the repetition of some tests.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because rod drop times are still confirmed to be within the Technical Specification limits.
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Procedures 1/2BVS DG-8 DESCRIPTION:
New procedures 1/2BVS DG-8 were written to provide guidance for the performing engine analysis for the diesel generators. This analysis imulves temporary connections and intrusive testing. The procedures control the temporary configuration changes and equipment manipulations such that the testing does not impact dicscl generator operability.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because these procedures ensure that dicscl generator operability and reliability is maintained throughout the performance of the test.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the operability of the dicscl generator is unaffected by the performance of the tests.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon uhich Technical Specifications are based.
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Setpoint/Scaline Channe Reauest SSCR 97-016 DESCRIPTION:
The scaling for the steam generator feedwater pump speed control program as a result of the steam generator replacement project. This change revised the gain of the Unit I feedwater pump speed controller differential pressure program due to changes in the feedwater and main steam system flow paths for the replacement steam generators.
SAFETY EVALUATION
SUMMARY
The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because failure of the feedwater pump speed control system is bounded by the failure (open) of a single feedwater control valve. The change does not install any new equipment or alter any existing equipment such that it operates beyond its intended range of operation.
The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because no new or different types of equipment were added by this change. Existing equipment was adjusted to revised calibration values to operate properly following steam generator replacement.
The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which the Technical Specifications are based.
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Serpoint/Scaline Chance Reauest SSCR 97-028 and 97-031 DESCRIPTION:
The Unit I and Unit 2 containment spray additive tank (CSAT) LO-2 level alarm setpoint was revised.
As a result of the steam generator replacement project, containment recirculation sump pil calculations were revised to address increased Unit I reactor coolant system volume. In addition, the revised containment pH calculations included a more rigorous evaluation ofinstrument uncertainty for the amount of sodium hydroxide added from the CSAT. As a result of this analysis, the CSAT LO-2 level setpoint was reduced to assure a minimum volume of sodium hydroxide is added to the containment spray system following an accident.
SAFETY EVALUATION
SUMMARY
The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis repon is not increased because the CSAT LO-2 level alarm is a passive instrument cannot initiate an accident, and the revised setpoint results in adding a larger volume of sodium hydroxide to the containment spray system in order to bound minimum recirculation sump pH requirements following a loss of coolant accident (LOCA). Fission product removal capability was not changed since a larger volume of sodium hydroxide is available to the containment spray system following a loss-of-coolant accident (LOCA).
The possibility for an accident or malfunction of a difTerent type than any evaluated previously in the safety analysis report is not created because the CS AT level instrumentation was designed for variable setpoint adjustment to meet containment post LOCA pH requirements. The CSAT LO-2 level alarm only provides indication to operators that the required volume of sodium hydroxide has been added to the containment spray system and the tank can be manually isolated. Upon actuation of this alarm, the containment pH requirements will be met based on design basis calculations. j The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the volume of sodium hydroxide delivered to the containment spray system is based upon the initial CS AT levels allowed by the Technical Specifications. The Technical Specifications requirements for initial CSAT level were used as the basis for calculating the CSAT LO-2 level setpoint. I 120
Setpoint/Scaline Chance Reauests SSCRs97-04I and 97 042 DESCRIPTION:
The time delay associated with the diesel generator starting air system air dryers and compressors was changed from 90 seconds to 180 seconds. These changes permit additional time for the air drycrs to i I
stabilie.c before their associated air compressor starts. The alarm air dryer high temperature annunciates if the air dryer refrigeration system does not achieve a stable state (Iow refrigerant compressor suction temperature) prior to the compressor starting. These changes minimite the nuisance alarms received in the control room. The UFSAR was revised via DRP 7-125 to reflect the change.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the starting system operation in the emergency mode. The mode of operation during an accident, is unafTected by the time delay change. The time delay function is bypassed in the emergency mode.
- 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis repon is not created because these changes do not impact dicscl generator reliability.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because j the che.nges do not affect any parameters upon which Technical Specifications are based.
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l f On-site Resiew 97-003 l
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This On-site Review pro ided guidance to the operations department concerning the impact of the dicsci
- generator ventilation system on dicscl generator og
- rability. The compensatory actions and discussions in l this On-site resiew were subsequently incorporated in operating procedures, annunciator response procedures, and operating surveillances.
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SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the actions discussed in the On-site Review were intended to maximize dicscl generator reliability and availability w hile prosiding conservative guidance on u hich to base operability determinations.
- 2. The possibility for an accident or malfunction of a difTerent type than any evaluated presiously in the safety analysis report is not created because the On-site Review only provided conservative guidance i related to the impact of dicscl generator ventilation system failures on dicsc1 generator operability.
! The guidance did not challenge equipment in such a manner as to create the potential for failures.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect any parameters upon which Technical Specifications are based.
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6G-97-0260 DESCRIPTION:
This safety evaluation was written to evaluate the long-term unavailability of recorder OPDR VA030.
S AFETY EVALUATION SUMM ARY:
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the auxiliary building ventilation systems operates in the same manner as originally intended. Removing the recorder removal does not prevent notification to operations of plugged high-cfliciency paniculate absorber (IIEPA) filters. Other means are available to monitor the HEPA Filters. The ventilation system's operation is not be altered, it still filters air as required. ANSI /ASME N509 1989 no longer specifics a requirement for a recorder in the main control room
- 2. The possibility for an accident or malfunction of a different type than any evaluated in the safety analysis report is not created because the overall ventilation functions are not altered. The system filters air as needed. Other means are available to monitor the IIEPA Filter differential pressures.
- 3. The margin of safety, as defined in the basis for any Technical specification, is not reduced because the change does not alTect any parameters upon which Technical Specifications are based.
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NDIT BYR97-327 DESCRIPTION:
A temporary scaffold was installed to provide a working platform in support of a modification to the essential service water cooling tower (SXCT) basin level switch.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because none of the accidents can be initiated by failure of the SXCT or the temporary scaffold. The scaffold was constructed to scismic requirements to preclude any interaction of the scaffold with system components.
- 2. The possibility for an accident or malfunction of a different type than any evahiated previously in the safety analysis report is not created because the scaffold is scismically constructed to prevent interaction with safety-related plant components and to prevent essential service water system flow path blockage.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which the Technical Specifications are based.
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POSTACCIDENT SAMPLING COMMITMENT pfESCRIPTION:
A safety evaluation was written to clarify the postaccident sampling retraining frequency. Procedures BAP 560-10 and BTP 300-29 and UFSAR Subsection E.21.1.2.1.2 state the Postaccident Sampling System (PASS) retraining is required annually. However, a letter from T. R. Tramm of Commonwealth Edison Company to 11. R. Denton of Nuclear Regulatory Regulation, dated January 5,1984, stated that training procedures used to obtain post-accident samples that were not used in obtaining routine samples, would occur at least every 6 months. A letter was written to the NRC on August 4,1997 which clarified and updated the history of this training frequency issue (Byron Letter 97-0185) .The documentation found in that letter was included in the safety evaluation.
SAFETY EVALUATION
SUMMARY
- 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety presiously evaluated in the safety analy sis report is not increased because the level of PASS training experience was not affected by the change since the chemistry technicians routinely use the panel for sampling and very familiar with its operation.
- 2. The possibility for an accident or malfunction of a different type than any evaluated presiously in the l safety analysis report is not created because the training frequency does not adversely impact the UFS AR accident-related systems, structures, and components.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based. I l
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i OUT-OF-SERVICE 940007543 DESCRIPTION:
A safety evaluation was written to support the extended out-of-service of the Unit 2 positive displacement pump. The extended out-of-scrvice is required since the VT-2 pressure test has not been performed. This test must be performed in order to clear the out-of-scryice.
SAFETY EVALUATION
SUMMARY
l 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this
! pump is not safety related and is not required to be available to support plant operations. On accident l conditions, this pump is not relied upon for safe shutdown of the plant.
- 2. The possibility for an accident or malftmetion of a different type than any evaluated previously in the l
l safety analysis report is not created because analysis allows for the use of a centrifugal charging pump l as an initial condition. The line up of the system in normal operation does not afTect the response of the system that is required during an accident.
- 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because j the positive displacement pump has no safety-selated functions.
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