ML20236Y228
| ML20236Y228 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/30/1987 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20236Y226 | List: |
| References | |
| NUDOCS 8712110187 | |
| Download: ML20236Y228 (51) | |
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LIMERICK GENERATING STATION UNIT NO. 1 ANNUAL PLANT MODIFICATION REPORT JULY 1, 1986 THROUGH JUNE 30, 1987 SUBMITTED TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION PURSUANT TO FACILITY OPERATING LICENSE NPF-39 DOCKET NO. 50-352 8712110187 876306 PDR ADOCK 05000352 R PDR
LIMERICK GENERATING STATION ANNUAL PLANT MODIFICATION REPORT JUNE 30, 1987 This report for Limerick Generating Station Unit No. 1, License No. NPF-39 (and previous License NPF-27), is issued in fulfillment of the reporting requirements of 10 CFR 50.59 (b).
The report covers modifications that were completed during the one year period ending June 30, 1987 including changes made to the facility as described in the safety analysis report.
d For each of the modifications included in this report, the safety ,
evaluation has determined that there are no unreviewed safety '
questions as defined in 10 CFR 50.59 (a)(2) in that (i) the probability of occurrence of the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report was not increased, or (ii) a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report was not created, or (iii) the margin of safety as defined in the basis for any Technical Specification was not reduced.
Note The actual work involved in some of these modifications was started prior to July 1, 1986 but not completed until after July 1, 1986 and before June 30, 1987.
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Docket No. 50-352 LIMERICK GENERATING STATION UNIT NO. 1 ANNUAL MODIFICATION REPORT TABLE OF CONTENTS Item Mod. No. System Page
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84-0018 Control Rod Blades 1 86-0037 Residual Heat Removal Service Water 2 Plant Process Radiation Monitoring 84-0047 Residual Heat Removal 4 85-0378 Various 6 85-0490 Reactor Protection System 7 Uninterrupted Power Supply 85-0491 Turbine Enclosure Structure 9 85-0519 Reactor Enclosure / Refueling Area 10 High Radiation Isolation 85-0521 Radiation Monitoring System 11 85-0523 Containment Atmospheric Control 13 85-0528 Fire Protection 14 85-0549 Reactor Enclosure Chilled Water / 13 Emergency Service Water }
85-0572 Reactor Enclosure / Refueling Area lo Atmospheric Control 85-0577 Spent Fuel Storage 17 85-0611 Habitability and Control Room Isolation 19 Atmospheric Chlorine Detection 85-0659 Fire Protection 21
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85-0663 High Pressure Coolant Injection 22 85-0677 Residual Heat Removal Service Water 23 85-0679 Nuclear Steam Supply Shutoff System 24 85-0692 Core Spray 25 ,
85-0693 Emergency Service Water 25 85-0694 High Pressure Coolant Injection 25 85-0695 High Pressure Coolant Injection 25 85-0696 Residual Heat Removal 25 ,
85-0791 Fuel Storage 26 85-0815 Containment Isolation Indication 27 86-0828 Turbine Enclosure Condensate Backwash 28 Area Dirty Radwaste and Clean Radwaste 85-0845 Containment Atmosphere Control 30 ,
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85-0868 Emergency Service Water 31 86-0876 Source Range Monitoring 32 Intermediate Range Monitoring 85-0902 Overhead Handling 33 86-0925 Spent Fuel Storace 35 86-0929 Nuclear Fuel 36 86-0941 Emergency Response Facility Data System 37 Safety Parameter Display System 86-5019 Residual Heat Removal 39 Fuel Pool Cooling and Cleanup 86-5114 Standby Gas Treatment System 41 I
86-51:"3 Emergency Service Water 42 .
s86-53_'8 Reactor Core Injection Cooling 44 '
86-5523 Radwaste 46 .
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l l Limerick Generating Station l Unit 1 -
Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 1 of 47 Modification No.: 84-0018 .,
l A. System: Control Rod Blade (CRB) brackets B.
Description:
Removal of control rod blade brackets by cutting and grinding them off one inch from the spent fuel pool liner.
C. Reason for Change:
The original design of the CRB brackets was determined to be {
an ALARA concern due to their location on the spent fuel pool {
wall. They are to be removed and a CRB storage rack used in their place.
D. Safety Evaluation Summary: ,
- 1) Does this modification increase the probability of a occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the FSAR is based on the use of CRB storage racks and not on the use of CRB brackets. The modification is being performed prior to the initial pool flooding and r.torage of spent fuel. Therefore, any accidental breach of the pool liner during the ,
performance of the modification can not result in the leakage of contaminated pool water.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any
- evaluated previously in the safety analysis report?
l Answer: No, because the modification will be completed prior to the initial flooding of the spent fuel pool. Any accidental damage to the liner or it surface will be repaired under approved j
repair procedures as required by Specification ,
8031-C-45 for Liner and Accessories for the Spent Fuel Pool, Steam Dryer and Separator .
Storage Pool, Cask Washdown and Storage Area, and Reactor Well, iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the bases of the Technical Specifications do not address any requirements or methods of CRB storage. -
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, '086 THROUGH JUNE 30, 1987 Page 2 of 47 Modification No.: 86-0037 A. System: Residual Heat Removal Service Water (RHRSW)
Plant Process Radiation Monitoring (PPRM)
B.
Description:
Addition of a Hi-Hi radiation warning light to the RHRSW loop
'A' return on the remote shutdown panel 10C201.
C. Reason for Change:
To provide a redundant means of monitoring for the presence of high radiation in the RHRSW.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
l Answer: No, because the indicating light added by this modification provides supplemental status information to the operator regarding the RHRSW process radiation monitoring system. A series resistor limits current flow to 40 ma per light in the 125 VDC indicating light system. In the event that a light fails to a direct short, from the line side to the common side, the series resistor will prevent a current transient that would otherwise result in the loss of other devices powered frem the same circuit. Should there be a failure of the series resistor followed by a short in the light assembly, then the supply fuse could blow to protect the power source. This loss will be less than the loss analyzed in the Control Systems Failure Evaluation Report prepared by Dr. S. Slivinsky of General Electric Company, November 1983, Document No.
176784. The conclusions of this report identify that the above failure will be bounded by the failure evaluation in the PSAR, Chapter 15. As stated in the FSAR, RAI (Request for Additional Information) 421.47, the loss of any circuit of the remote shutdown
( panel will not prevent safe shutdown. FSAR l Section 7.4.2, 3.11.2, RAI 421.10 and RAI 421.47 were reviewed in making this
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 3 of 47 determination. This safety analysis is valid for all MSC status lights on panel 10C201.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safet3 Analysis Report?
Answer: No, because as stated above, the indicating light added by this modification does not l
affect the safety function of any system.
This indicating light simply advises the operator of PHRSW high radiation.
(iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
Answer: No, because this modification increases the safety of the plant by providing a redundant means of monitoring for the presence of a high radiation condition in the RHRSW. Sections 3/4.3.7.1 and 3/4.3.7.4 were reviewed to make this determination.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 4 of 47 Modification No.: 84-0047 A. System: Residual Heat Removal (RHR) System B.
Description:
Deletion of the RHR pump operating interlock from each alarm logic to allow the high/ low pressure alarms to function regardless of pump operating status.
C. Reason for Change:
To enhance the safety and reliability of the plant by providing continuous monitoring of the RHR discharge line pressure regardless of the pump operating status.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because a control room alarm will alert the operator of a significant pressure increase in those portions of the RHR piping indicative of gross leakage from the high pressure reactor coolant system past selected containment isolation valves. Corrective action can then be taken by station personnel to prevent overpressurizing the low pressure-portions of the RHR pump discharge piping.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because this modification will provide continuous monitoring of the low pressure portions of the RHR pump discharge piping. A control room alarm will alert the operator of a significant pressure increase in those portions of the RHR piping, indicative of gross leakage from the high pressure reactor coolant system past selected containment isolation valves. Corrective action can then be taken by station personnel to prevent over pressurizing the low prassure portions of the RHR pump discharge piping.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 5 of 47 iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because this modification provides an improved method for monitoring leakage from the reactor coolant pressure boundary past talected containment isolation valves. This -
naproved method will result in an increased margin of safety by providing continuous monitoring of the RHR pump discharge piping pressure.
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Limerick Generating StaLion Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 6 of 47 Modification No.: 85-0378 A. System: Various B.
Description:
This modification will add a water seal volume, called a head chamber, to the vents of various level transmitters that are used to measure reactor vessel water level.
C. Reason for Change:
This head chamber will be used to prevent air from being introduced into the transmitter during calibration.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Rcport?
Answer: No, because the head chamber is isolated from the detector during all operation conditions, except calibration of the instrument itself.
The head chamber is not a concern for seismic events, because the analysis shows that it will not overload any rack or mounting.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because the devices are normally isolated from the process liquid by redundant isolation valves.
(iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
Answer: No, because installation of these head chambers does not affect instrument operability as discussed in the basis of the technical specifications.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 7 of 47 Modification No.: 85-0490 A. System: Reactor Protection System (RPS)
Uninterrupted Power Supply (UPS)
B.
Description:
This modification involves replacement of under and over voltage relays, modifying the breaker shunt trip circuits to include a presently spare main contact as an individual circuit interlock and replacement of the control fuse with smaller rated, faster acting fuses.
C. Reason for Change:
This modification will assure that current to the shunt trip coil is interrupted when the breaker opens. The 35A control fuses will be replaced with 6A, fast acting rectifier type fuses. This will reduce the possibility of inverter damage from a short circuit in the relay sensing circuitry.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malf unction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because the modification provides a change in the RPS/UPS protective relay reset voltages but does not change the trip setpoints. The harmonic filter modules will reduce the relay sensitivity to waveform harmonics and assure consistent tripping results between the three power sources. The new fuses will better protect the RPS inverters from damage caused by a short circuit in the relay sensing circuitry. The reliability of the shunt trip coil circuit is improved. FSAR Section 7.2.1.1.3 was reviewed to make this determination.
(ii) Does this modification create the possibility of an zecident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Ibport?
Inswe r : No, because the RPS/UPS protective relay setpoints are unchanged and the improved shunt
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 8 of 47 trip coil circuit imp: oves the probability of achieving the safety function.
(iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
Answer: No, because the relay protective function and trip setpoints are unchanged. Technical Specification 3/4.B.4.3 was reviewed in making this determination.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987
- Page 9 of 47 Modification No.: 85-0491 A. System: Turbine Enclosure Structure B.
Description:
Addition of a steel stairway form turbine enclosure elevation 239' to static in %rter room 453, elevation 254'.
C. Reason for Change:
To provide improved access for the fire brigade.
D. Safety Evaluation Summary: '
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because this modification is not part of any safety related system, nor is this ~
modification located in a safety related area. ,
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because even though the stair is attached to the safety related area boundary at elevation 254' there is no possibility of a detrimental affect on safety from any failure of the connection, iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications? ,
Answer: No, because this modification is not part of any system subject to the Technical Specifications, o
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 10 of 47 Modification No.: 85-0519 A. System: Reactor Enclosure / Refueling Area High Radiation Isolation System B.
Description:
Replacement of existing double banana jack test adapters with high temperature double banana jack adapters in panels 10C606
& 10C633 for surveillance testing of Reactor Enclosure / Refueling Area high radiation isolation system.
C. Reason for Change:
To eliminate the need for disconnecting the wires from the relay for surveillance testing.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the replacement banana jacks perform an identical function as the original equipment.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the existing double banana jacks and the high temperature double banana jacks used for replacement are not evaluated in the PSAR.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the existing double banana jacks and the high temperature double banana jacks used for replacement are not defined in the basis for the Technical Specifications.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 11 of 47 Modification No.: 85-0521 A. System: Radiation Monitoring System B.
Description:
Addition of single banana jacks test adapters in panels 10C606 and 10C633 for surveillance testing of Reactor Enclosure / Refueling area high radiation monitors.
C. Reason for Change:
To enable technicians to monitor the D.C. amplifier output voltage in the indicators and trip units without the need to disconnect wires from the terminal blocks or remove the cover of the trip unit during survei31ance testing.
l l D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the only test adaptor failure which could impact circuit operation is a short to ground at the test jack. This failure would result in loss of power to the radiation monitors and subsequent safe isolation of the Reactor Enclosure / Refueling Area (due to fail safe circuit design).
Channel redundancy provides additional l
assurance of eafe system operation in the event of high radiation. No credible failure of the test jack will prevent successful system operation, ii' Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original Reactor Protection System (RPS) design. The only test adapter failure which could impact circuit operation is a short to ground. This is discussed in question 1.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 12 of 47 iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original RPS design. These requirements include, but are not limited to, seismic and environmental qualification, separation criteria, quality assurance, and testability. There is no effect on bus loading.
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Limerick Generating Station Unit 1 i Annual Plant Modification Report
! JULY 1, 1986 THROUGH JUNE 30, 1987 Page 13 of 47 Modification No.: 85-0523 A. System: Containment Atmospheric Control (CAC) System B.
Description:
Replacement of the current 5-50 cc/ minute 15% 5 turn needle valve flow meters in panels 10S205 and 10S106 with flow meters having 1 '00 cc/ minute 15% range with a 15-turn needle valve for control.
C. Reason for Change:
To improve the control of reagent gas flow in the drywell hydrogen peroxide analyzer panels.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the basic function of the reagent gas flow meters is not changed.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the operating functions of the reagent flow meters themselves and/or the CAC System do not change.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
I Answer: No, because this modification will not reduce the margin of safety as defined in the basis for any Technical Specifications because changes to the Technical Specifications are not required. The design of this modification l meets the applicable requirements of the i original Containment Atmosphere Control System including but not limited to testability, seismic and environmental qualification, fire protection and quality assurance. There will be no increase in the area combustible loading as a result of this modification. There will be no change in bus loading as a result of this modification. Flow control and flow meter reliability will be improved by this modification.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 14 of 47 Modification No.: 85-0528 A. System: Fire Protection System B.
Description:
Installation of access doors in HVAC duct work.
C. Reason for Change:
To allow for visual inspection of seventeen class I fire dampers.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because this change does not affect operation of the various HVAC Systems in which these fire protection dampers are installed.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the addition of the access doors does not change the function of the HVAC ductwork as previously described in the FSAR.
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iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because this modification does not affect the integrity of the safety related ductwork.
The access doors are installed in accordance with safety related design specifications.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 15 of 47 Modification No.: 85-0549 A. System: Reactor Enclosure Chilled Water (RECW)
Emergency Service Water (ESW)
B.
Description:
Installation of piping, valves and fittings to facilitate local leak rate testing (LLRT) of HV-13-108, HV-13-109, HV-13-110 and HV-13-111 without the need to drain the RECW and ESW systems.
C. Reason for Change:
To provide a means to perform the above LLRT's during power operation which avoids scheduling problems during refueling outages and to avoid the need to drain the RECW and ESW Systems prior to performing LLRT's.
l D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the current system has several vents, drains and isolation valves' identical to those proposed in this modification. The FSAR analysis already includes these system items.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the existing previously evaluated system contains vent, drains and isolation valves identical to those proposed in this modification.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the Technical Specifications do not contain requirements pertaining to manual vents, drains and isolation valves on line penetrating the containment.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 16 of 47 Modification No.: 85-0572 A. System: Reactor Enclosure / Refueling Area Atmospheric Control B.
Description:
Add test switches and jacks adapters in panels OACl2A and 1 OBCl24 and annunciation in panels 10C881 and OOC 881 for surveillance testing of the Reactor Enclosure / Refueling Area Differential Pressure Instruments.
C. Reason for Change:
Surveillance testing of the Reactor Enclosure / Refueling Area Differential Pressure Instruments requires the lifting of leads. This modification will eliminate the need for lifting -.
leads and the question as to the continui.y of the leads reconnection.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the addition of test switches, test jack adapters and relays does not affect the system performance as described in the FSAR.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the addition of test switches, test jack adapters and relays is in accordance with the design requirements applicable to the original Reactor Enclosure 1 Refueling Area HVAC design. These requirements include but are not limited to, seismic and environmental qualification, separation, criteria, quality assurance, and testability. There is no effect on bus loading.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the newly installed test switches, test jack adapters and relays will not affect the safety related function of the systems in which they are being installed.
I,imerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 17 of 47 Modification No.: 85-0577 A. System: Spent Fuel Storage B.
Description:
Install a special multi purpose storage rack in the north-west corner of the spent fuel pool. This free standing rack has no attachments to the pool and is designed to store control rod blades (CRB), control rod blade guides, and up to five defective spent fuel canisters. To allow for future flexibility, the rack is physically capable of storing spent fuel assemblies on a temporary basis.
C. Reason for Change:
To permit an improved method of storing fuel in the spent --
fuel pool.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because the PSAR is already based on storage of CRB's and defective fuel in the special storage rack. '
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because the special storage rack is a passive structure which interfaces only with the pool floor and the items to be stored.
This interface is similar to that of the existing spent fuel storage racks. The rack will be installed prior to the storage of spent fuel in the pool, so there is no radiological hazard, and it will be lifted and handled in accordance with the requirements of NRC NUREG-0612.
(iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
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b b Limerick Generating Station
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~9; Annual' Plant Modification Report' I JULY 1, 1986 THROUGH JUNE 30, 1987 I
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Page 18 of 47 Answer: No, because the storage rack will not affect the subcriticality of stored spent fuel. The i storage rack will not affect the ability to maintain water level in the spent fuel pool as identified in section 5.5., " Fuel Storage Design Features" of the Technical Specifications. 1 I
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 1
Page 19 of 47 b Modification No.: 85-0611 A. System: Habitability and Control Room Isolation System Atmospheric Chlorine Detection System
'B.
Description:
' Replacement of the channels C and D atmospheric chlorine monitors.-
C.. Reason for Change:
Improve reliability of the chlorine detection system and L ' reduce the number of spurious main control room HVAC isolations.
D..' Summary of Safety Evaluation:
(1)' Does this modification increase the probability of occurrence or consequences of an accident or malfunction of. equipment important to safety as previously' evaluated-in the Final Safety Analysis Report?
' Answer: No, because the replacement chlorine monitors will perform the same functions as the existing equipment. The design of meets the requirements of.the original Habitability and Centrol Room, Isolation System.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
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Answer: No, because the monitoring and protective j functions of the chlorine monitors themselves l and/or the Habitability and Control Room a Isolation System do not change.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 20 of 47 (iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
Answer: No, because the new model chlorine detectors perform the identical function as the previous equipment but with a faster response time and a longer required maintenance interval. The new model chlorine detectors also meet the original equipment specifications including, but not limited to, testability, seismic and environmental qualification, electrical channel separation, fire protection and quality assurance.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 21 of 47 Modification No.: 85-0659 A. System: Fire Protection System -
B.
Description:
Addition of rotating red beacon hazard lights in the inverter room to activate on a Unit 1 carbon dioxide discharge.
C. Reason for Change:
These new warning devices, which activate on a Unit 1 Carbon Dioxide (CO2) discharge, will serve as a supplement to the existing horn in the Unit 1 Cable Spreading Room, l D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because this modification affects only non-safety related equipment. The wall penetration required for this modification will be sealed to restore the fire wall rating. Analyses also show that even the presence of a 4" diameter opening (0.087 square feet) adequate steam flooding protection would be provided should the worst case high energy line break in that area i occur.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because this modification affects only non-safety related equipment and will not impact the operation of any safety-related equipment.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
l Answer: No, because the CO2 discharge warning devices l addressed in this modification are not discussed in the Technical Specifications.
Additionally, this modification affects only non-safety related equipment.
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Limerick Generating Station Unit 1 Annual Plant Modification Repcrt JULY 1, 1986 THROUGH JUNE 30, 1987 Page 22 of 47 Modification No.: 85-0663 A. System: High Pressure Coolant Injection (HPCI)
B.
Description:
Removal of existing welded connections for HPCI pressure safety valve PSV-56-lF020 and their replacement with flanged connections.
C. Reason for Change:
To allow ease of removal of valve for testing and to maintain radiation exposure of personnel ALARA.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because this modification does not affect the function of the associated equipment related to safety. The flanges are passive components of the valve assembly whose primary safety function is to mitigate the consequences of an accident.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because flanges are used on many other pressure safety valves and have been evaluated previously in the FSAR.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because this modification does r>t affect the function of the associated equipment related to safety. The method of connection of the pressure safety valve is not referenced in the basis of the Technical Specification.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1936 THROUGH JUNE 30, 1987 Page 23 of 47 Modification. No. : 85-0677 A. System: Residual Heat Removal Service Water (RHRSW)
B.
Description:
This modification involves the lowering of the low flow setpoint from 4 gpm to 2 gpm for the common RHRSW radiation
, monitors OAS578, OBS578, ICS578 and IDS 578.
l C. Reason for Change:
The current low flow setpoint of 4 gpm is very close to the maximum flow rate through the sample skid and this modification is required to prevent max flow rate annunciations.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated In the safety analysis report?
Answer: No, because the accidents evaluated in the FSAR do not involve any sequences which involve an isolation of the RHRSW due to the RHRSW radiation monitors. Additionally, the low flow alarm on these monitor do not provide any isolation of the RHRSW.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the reduction of the low flow setpoint to 2 gpm does not affect any isolation function of the RHRSW.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the reduction of the low flow setpoint to 2 gpm still allows for an adequate sample travel GPM time to the monitor (the delay time due to sample flow for the radiation monitor is shorter than the time required for the slug of increased radioactivity to reach the isolation valves).
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30,.1987 Page 24 of 47 Modification No.: 85-0679
. . 1 A. System: Nuclear Steam Supply Shutoff System (NSSSS)
B.
Description:
Replacement of the Agastat TR relays in the NSSSS panels with Agastat ETR relays.
C. Reason for Change:
To avoid potential problems with these relays in the future, the Agastat TR relays will be replaced with Agastat ETR relays.
D. Safety Evaluation Summary:
1). Does'this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the replacement Agastat ETR relays will perform the same function in the NSSSS as do the existing Agastat TR relays. Changing the timing ranges of reveal of the relays while leaving the time settings per the existing design will not adversely affect the operation of the NSSSS system but will enhance them as the relays are calibrated more accurately in the center of the ranges.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the replacement Agastat ETR relays will perform the same function in the NSSSS as do the existing Agastat TR relays.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the required operations of the NSSSS as described in the Technical Specifications will not change by the use of Agastat ETR relay in place of Agastat TR relays. Changing the timing ranges of several of the relays to place the time settings !
closer to the center of the ranges will increase the margin of safety as timing relay calibrations are more accurate in the center of the ranges.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 25 of 47 i
Modification Nos.: 85-0692, 85-0693, 85-0694, 85-0695, 85-0696 A. System: Nuclear Valves B.
Description:
To change the material supplied for various components which are part of nuclear service valves.
C. Reason for Change:
The Supplier has requested to change the material.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because all changes made are in accordance with existing plant design criteria and have been determined to be suitable for the extended service.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because all changes made are in accordance with existing plant design criteria and have been determined to be suitable for the intended service.
iii) Does this modification reduce the r.argin of safety as defined in the basis for the Technical Specifications?
Answer: No, since the basis for the Technical Specifications do not address specific material requirements for valves.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 26 of 47 Modification No.: 85-0791 A. System: Fuel Storage Containers B.
Description:
Insertion of a spacer between the container body and lid of eight defective fuel storage containers.
C. Reason for Change:
To correct the length of eight defective fuel storage -
containers that do not accommodate the irradiated growth of fuel. '
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the FSAR does not evaluate accidents or malfunctions of equipment associated with the defective fuel containers.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the longer canister length is accommodated in the design of the rack that will store the canister in the spent fuel pool.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the basis of the Technical Specifications do not address any requirements for defective fuel storage containers.
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1 Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 27 of 47 s
Modification No.: 85-0815 A. System: Containment Isolation Indication System ,
l B.
Description:
l l Adds fuses to safety related power supply circaits.
l l C. Reason for Change:
l l To provide separate fuse protection for each testable check valve solenoid and for its associated bypass valve position -
indication.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or -
malfunction of equipment important to safety as e previously evaluated in the safety analysis report?
Answer: No, because installation of a separate fuse for each of the bypass valve solenoid position ~ ' -
indications will ensure that failure of the unqualified testable check valve solenoids '
will not lead to failure of the associated '
bypass valve position indication without an additional signal failure.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the plant as described in the FSAR will not be changed as result of adding the fuses.
iii) Does this modification reduce the nargin of safety as '
defined in the basis for the Technical Specifications? -
Answer: No, because the basis for the Technical Specifications does not mention the fusing arranger:'-* for the solenoid bypass valves.
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Limerick Generating Station '
Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 28 of 47 .
Modification No.: 86-0828 $
A. System: Turbine Enclosure Condensate Backwash Area Dirty Radwaste (DRW) and Clean Radwaste (CRW) ~/
B.
Description:
This modification covers the isolation of the Unit 2 Turbine '
u 2 Enclosure Condensate Backwash Area dirty radwaste (DRW) and clean radwaste (CRW) sump inlet lines, the installation of internal seals to the Control Structure boundaries, the installation of plugs in Turbine Enclosure and Control Structure floor drains and equipment drains, and welding of plates to the frame about the hatch plugs on Elevation 200'-
0" above the Unit 2 recombiner room (#155) and the removal of temporary barricades to enable the restart of Unit 2 construction activities.
C. Reason for Change:
These seals, plugs, the isolation of the Condensate Backwash .
Area Sumps and other modifications as described in the latest revision to the modification design control package will provide sufficient flood protection to the Control Structure Chilled Water System and replace that currently being provided by the temporary barricades situated in the construction openings required for Unit 2 construction local -
to the turbine building. The purpose for providing flood protection of the Control Structure Chilled Water System is to ensure that flood waters from external sources during Unit 2 construction cannot prevent the safety shutdown of Unit 1.
D. Summary of Safety Evaluation:
(i) Does this niodification increase the probability of .
occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
1 Answer: No, because the physical requirements of his modification provide sufficient flood protection to the Control Structure Chilled Water System to ensure that flood water from external sources cannot affect safety-related equipment. FSAR sections 3.6; 15; 2.3; 2.4; and 9.3.3 were reviewed in making this determination. -
(ii) Does this modification create the possibility of an ,
accident or malfunction of a different type than any l
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l, Limerick Generating Station ,
s Unit 1 Annual Plant Modification Report .
JULY 1, 1986 THROUGH JUNE 30, 1987 Page 29 of 47 evaluated previously in the Final Safety Analysis Report?
Answer: No, because all possibilities of an accident or malfunction stemming from this modification have been evaluated. FSAR sections 3.6 and 15 .
were reviewed in making this determination.
9 (iii) Does the modification reduce the margin of safety as defined in the basis for any Technical Specifications?
'~
. Answer: No, because the addition of a combination of I
internal seals and drain plugs an other items to reduce the possibility of flood waters ~ - - - -
entering the Control Structure will only serve ~
to increase the margin of safety. -
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 30 of 47 Modification No.: 85-0845 A. System: Cor.tainment Atmosphere Control System (CACS)
B.
Description:
Add test switches in panel 10C600 and annunciation in panel 10C800 for surveillance testing of the Containment Atmosphere i
Control System Combustible Gas Analyzer Pressure Differential Circuits.
C. Reason for Change:
To facilitate the surveillance testing of the CACS.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original Containment Atmosphere Control System design, ii) Does this modification create the possibility for an accident or malfunction of a different type *han any evaluated previously in the safety analysis report?
Answer: No, because the design of this modification is in accordance with the design requirements applicable to the original Containment Atmosphere Control System design.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because this modification does not require any change in the Technical Specifications.
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Annual Plant Modification Report .
JULY 1, 1986 THROUGH JUNE 30, 1987 tg Page 31 of 47 -.
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Modification No.: 85-0868 , ,
A. System: Emergency Service Water (ESW) ,
B.
Description:
Revision of seating controls from limit switch control to ,
torque switch control for Diesel Generator Heat Exchanger ESW .
inlet motor operated valves HV-11-131A, B, C, D and HV 133A, B, C, D.
C. Reason for Change:
To provide the valves with a more reliable closing method.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report? ,
Answer: No, because this change does not alter the function of the ESW inlet valves. This modification only changes the seating control '
of the inlet stop-check valves from limit switch to torque switch seating, ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysie report?
Answer: No, because changing the seating control of ,
tlie inlet stop-check valves from limit switch ~
to torque switch seating eliminates an undesirable excessive vibration condition in ,
the ESW piping. The function of the ESW piping in not altered by this modification.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the method of seating control of 1 the ESW inlet stop-check valves is not defined ~
in the basis for the Technical Specifications.
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,- 7 Limerick Generating Station Unit 1 Annual Plant Modification Report -
JULY 1, 1986 THROUGH JUNE 30, 1987 l Page 32 of 47 Modification No.: 86-0876 A. System: Source Range Monitoring (SRM) system Intermediate Range Monitoring (IRM) system '
B.
Description:
Replacement of heat shrink and cord grips used on the ;
undervessel SRM .3nd IRM cables with Kellems Cord Grips.
C. Reason for Change: ,
Provide a smooth transition between the flexible cable and /
the rigid guard to reduce cable damage due to flexing, twisting, vibration or mishandling.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or
?-
malfunction of equipment important to safety as Lr' previously evaluated in the Final Safety Analysis ?
Report?
Answer: No, because all design requirements applicable tc the original SRM/IRM cable support design -
and circuitry were applied to this modification. > s (ii) Does this modification create the possibility of an ,
accident or malfunction of a different type than any '
evaluated previously in the Final Safety Analysis Report?
~
't Answer: No, because the function of SRM/IRM cable support provide by this modification does not change from the original design.
Does this modification reduce the margin of safety as (iii) defined in the basis for any Technical Specification?
Answer: No, because SRM/IRM cable support is not referenced in the bases of the Technical Specifications.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 33 of 47 Modification No.: 85-0902 A. System: LGS Overhead Handling Systems B.
Description:
Provides a temporary, removal lifing beam assembly, trolley and hoist for use for maintenance on Control Room Chiller OBK112.
C. Reason for Change:
This modification is necessitated by the previous deletion of the Control Room Chiller Portable Gantry Hoist OOH 514.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because this modification is for maintenance purposes only and does not affect the safety-related function of Control Room Chiller OBKil2. The heavy load handling review of the Control Room Portable Gantry Hoist OOH 514 is considered to be valid for this modification.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because this modification does not introduce any new hazards in the plant nor the potential for interference with safety-related functions, including fire protection and safety impact considerations.
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Limerick Generating Station '.-
Unit 1 Annual Plant Modification Report -
JULY 1, 1986 THROUGH JUNE 30, 1987 .
Page 34 of 47 J
(iii) Does this modification reduce the margin of safety as defined in the basis for any ' technical Specification?
Answer: No, because this modi.fication is for maintenance purposes only, which maintains the '
functional reliability of the safety-related equipment involved. This modification is l bounded by the heavy land handling review of ,
I the Control Room Portable Gantry Hoist OOH 514.
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Limerick Generating Station Unit 1 Annual Plant Modification Report /,
JULY 1, 1986 THROUGH JUNE 30, 1987 Page 35 of 47 '
Modification No.: 86-0925 -
A. System: Spent Fuel Storage B.
Description:
Install plugs in ten spent fuel storage rack locations.
C. Reason for Change:
To prevent fuel from being stored in these locations. These spent fuel storage racks were identified as having fuel binding problems.
D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the plugs will have no effect on the ability of the of the storage rack to store spent fuel in a coolable and subcritical configuration.
ii) Does this modification create the possibility for an accident or malfunction of r different type than any evaluated previously in the safety analysis report? ..
Answer: No, because the installation of the plugs does ,
not change or impact the function of the storage rack. The bounding accident would remain the " Fuel Handling Accident" as described in the FSAR Section 15.7.4.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the plugs will have no effect on maintaining subcriticality, they do not ,
increase the storage capacity of the spent fuel pool, and do not affect the ability to maintain water level in the spent fuel pool.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 36 of 47 Modification No.: 86-0929 A. System: Nuclear Fuel
~3 .
Description:
Change over from 100-Mil Thick Zircaloy Fuel Channels to 80-Mil Thick Zircaloy Puel Channels.
C. Reason for Change:
To improve fuel utilization efficiency.
l D. Safety Evaluation Summary:
i) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the margins in the capabilities of the equipment are cufficient to take any expected load increases. Analyses have been completed evaluating the impact of the presence of a mixture of 80 and 100 mil thick fuel channels and 100% 80 mil thick fuel channels. These analyses evaluated the dynamic, nuclear and thermal hydraulic performance of the core.
ii) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the safety-related equipment ability to perform their intended function is not impaired by the placement of 80-mil thick fuel channels in the reactor vessel.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because an assessment was conducted of all affected safety-related equipment to demonstrate that each of these equipment items still retained positive margins when subjected to combinations of seismic and hydrodynamic loads. All applied loadings were shown to be within the code specified allowables for the safety related equipment evaluated.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 37 of 47 Modification No.: 86-0941 A. System: Emergency Response Facility Data System /
Safety Parameter Display System (ERFDS/SPDS)
B.
Description:
This modification consists of providing contact inputs to ERFDS for isolation valve groups 6A, 6B, 7A, 7B, and BA containment isolation command signals.
el C. Reason for Change:
l The algorithm for the " Group Not Isol" event target on the ERFDS/SPDS display formats requires containment isolations valve position status and containment isolation command status. -
D. Summary of Safety Evaluation:
l (i) Does this modification increase the probabil of occurrence or consequences of an accident o malfunction of equipment important to safeti is previously evaluated in the Final Safety Analysis Report?
Answer: No, because the design of this modification meet the applicable requirements of the ERFDS computer including, but not limited to, testability, seismic and environmental qualification, electrical channel separation, fire protection and quality assurance. This modification does not involve a change in the P&ID or Functional Description.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because this modification does not change the design of the plant as described in the FSAR. This modification only provides additional input to the ERFDS.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 38 of 47 (iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification? =-
Answer: No, because the ERFDS computer system is not defined in the bases for any Technical Specifications.
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Limerick Generating Station --
Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 39 of 47 j Modification No.: 86-5019 A. System: Residual Heat Removal / Fuel Pool Cooling and Cleanup (RHR/FPCC)
B.
Description:
This modification is to replace portions of carbon steel RHR/FPCC intertie piping with stainless steel piping.
C. Reason for Change:
The modification is necessary because the existing carbon steel piping intertie may not last the life of the plant.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because the modification removes a possible hazard in the FPCC system by replacing the carbon steel piping RHR/FPCC intertie which may fail before the end of the expected life of the plant. Except for the change in material, the new piping meets all the design requirements applicable to the existing piping. These requirements include, but are not limited to, seismic design criteria and quality assurance.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because this modification does not introduce any new hazards in the plant.
Except for the change in material, the new piping meets all the design requirements applicable to the existing piping. These requirements include, but are not limited to, seismic design criteria and quality assurance.
(iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 40 of 47 Answer: No, because the technical specifications do not address any requirements for piping niaterial or corrosion allowance.
a
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 41 of 47 Modification No.: 86-5114 A. System: Standby Gas Treatment System (SGTS)
B.
Description:
Replacement of the existing power controllers in the SGTS heater controllers in the SGTS heater control panels OAC928 and OBC 928 with a different model.
C. Reason for Change:
To enhance equipment qualification and improve the system reliability.
D. Safety Evaluation Summary:
- 1) Does this modification increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the safety analysis report?
Answer: No, because the new components are a direct replacement and meet all the seismic, redundancy, separation and Quality Assurance
, requirements applicable to the original SGTS.
- 11) Does this modification create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report?
Answer: No, because the new system components will operate identically to those utilized by the existing SGTS.
iii) Does this modification reduce the margin of safety as defined in the basis for the Technical Specifications?
Answer: No, because the new system components will operate identically to those utilized by the existing SGTS and in addition will increase i system reliability.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUKE 30, 1987 Page 42 of 47 Modification No.: 86-5135 A. System: Emergency Service Water (ESW)
B.
Description:
This modification increases the diameter of the portion of the control room chiller inlet header upstream of the fuel pool makeup line from 6 inches to 8 inches.
C. Reason for Change:
The modification is being done to lower the flow resistance in the lines to the condensers so that as the piping ages, sufficient Emergency Service Water flow through the condensers can still be maintained.
D. Summary of Safety Evaluation:
(1) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because this modification makes no functional change to the system; it will operate exactly as before. The increased Moderate Energy Line Break (MELB) flow from the modified ESW lines is still bounded by MELB flows from existing adjacent lines so that the conclusions of the MELB analysis are still valid. Since the replacement piping will be purchased, installed, and tested to the requirements of the codes and specifications governing the existing system, there will be no increase in the probability of an accident or malfunction as a result of I reduced seismic or quality control l requirements. The modification will maintain the system's capability to function as presently designed.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because this modification does not introduce any new hazards. Since there is no
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o e Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 43 of 47 functional change to the system, no accidents or malfunctions could occur in the modified system that could not have occurred and been considered in the present system design.
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l (iii) Does this modification reduce the margin of safety as
- defined in the basis for any Technical Specification?
l Answer: No, because section 3/4.7.1.2 of the Technical Specifications only requires that the ESW system be operable, and system operability ~
will not be reduced by this modification. In fact the margin of safety will be enhanced since with reduced flow resistance, it will be possible to supply the control room chillers with adequate ESW flow even after the piping has aged.
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Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 44 of 47 Modification No.: 86-5328 A. System: Reactor Core Injection Cooling (RCIC)
B.
Description:
This modification replaces the RCIC pump compartment unit cooler 2-inch isolation globe valves, 11-1019 and 11-1021, with 2-inch gate valves.
C. Reason for Change:
The modification is being done to lower the flow resistance in the lines to the coolers so that as the piping ages, sufficient Emergency Service Water flow through the coolers can still be maintained.
D. Summary of Safety Evaluation:
(i) Does this modification increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Final Safety Analysis Report?
Answer: No, because this modification makes no functional change to the system; it will operate exactly as before. The replacement valves will be purchased, installed, and tested to the requirements of the codes and j specifications governing the existing system, i so there will be no increase in the l probability of an accident or malfunction as a result of reduced seismic or quality control requirements. The modification will enhance l the system's capability to function as presently designed.
(ii) Does this modification create the possibility of an accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report?
Answer: No, because this modification does not introduce any new hazards. Since there is no functional change to the system, there is no way for an accident or malfunction to occur in the modified system that could not have occurred and been considered in the present system design.
Limerick Generating Station Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 45 of 47 (iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
- 4 Answer: No, because the Technical Specifications only require that the ESW system be operable, which for the case of valves 11-1019 and 11-1021 means that they are in the open position.
Since the new valves are no more likely not to be open than the old ones, the margin of safety will not be reduced. In fact the margin of safety will be enhanced since with reduced flow resistance, it will be possible to supply the RCIC room coolers with adequate ESW flow event after the piping has aged later ir. plant life.
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Limerick Generating Station Unit 1 ,
Annual Plant Modification Report ,
JULY 1, 1986 THROUGH JUNE 30, 1987 Page 46 of 47 Modification No.: 87-5523 7 A. System: Radwaste B.
Description:
}
This modification adds removable shielding and a steel cover ,
to the existing Unit 3 spent fuel gamma scan port.
C. Reason for Change: ,
Shielding is needed to prevent passible radiation exposure of personnel during spent fuel movement. \ ,
D. SummaryofSafetyEvaGtation:
, 3' -
1 i (i) Does this modification increase che probabilityio,f occurrence or consequences of an accident or N malfuncti'on of equipment important to safety as previcasly evaluated ir thalIinal Safety Analysis Repoet? T 1
Answer: No, because the addition of removable ,
shielding does not involve any safety-related eg ipment. The steel cover and the static ho st post added to the spent fuel pool walls ufll not adversely affect the structural \
integrft.y of the wall. They are designed to .:
Seismid= Category IIA criteria and will not be a hazard to any safety related components located in that area of the plant. The additional weight of the removable BISCO bags will not cause damage of the spent fuel pool liner, since the bags stay in the port, which is emaedded in concrete.~(The. plant fire 3 protection features are got affected by this change, since the bags and the BISCO material N are both nonflammable.'
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(ii) } Doess accident this'or modifdcetion malD2nhcion create of a difth[ possibility ferent of an type than any
. I evqluated previously in the Final Safety Analysis .i l
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Rep' ort? ;i s ,, l, Answer: NGI as discussed \in pc/agtaph IV.A.l., the modification dcea(not introduce any new hazards since it does not involve safety-related equipment and will not affect any l V safety-related equipment.
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Limerick Generating Station -
Unit 1 Annual Plant Modification Report JULY 1, 1986 THROUGH JUNE 30, 1987 Page 47 of 47 (iii) Does this modification reduce the margin of safety as defined in the basis for any Technical Specification?
l Answer: No, because there are no requirements in Technical Specification section 3/4.9
" Refueling Operations" which relate to the ,
spent fuel pool walls or the associated shielding. This modification does not
- adversely affect the capability of safely chutting down the plant when required. --- -
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