PY-CEI-NRR-0979, Safety Evaluation Summary Per 10CFR50.59(b)(2) 1988
| ML20236C941 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/31/1988 |
| From: | Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| PY-CEI-NRR-0979, PY-CEI-NRR-979, NUDOCS 8903220384 | |
| Download: ML20236C941 (281) | |
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Attachment 3 PY-CEI/NRR-0979 L I Page 1 of 278 PERRY NUCLEAR POVER PLANT SAFETY EVALUATION
SUMMARY
PURSUANT TO
., 10 CFR 50.59(b)(2) 1988 l
8903220384 PDR 881231 R ADOCK 05000440 PDC (,]
Attachment 3 PY-CEI/NRR-0979 L-Page 2 of 278
.SE No.: 88-001 Source Document: DCN 2029 Description of Change Revise P&ID drawing (D-302-103) for the Condensate System (N21) to more clearly illustrate the actual configuration of the existing _ turbine exhaust hood spray piping.
Summary
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I. No. Hinor drawing modifications clarify position of existing turbine exhaust hood spray piping with respect to low pressure turbines A, B and C. II. No. There is no physical change in the location of the turbine exhaust hood spray piping, therefore, no possibility for an accident or malfunction of a different' type than previously evaluated in the FSAR is created. III. No. The Technical Specifications are not affected by this change. 1 SE No.: 88-002 Source Document: DCN 2068 l l Description of Change Revise an HPL number for a fire damper on drawing D-912-608 in the Controlled Access HVAC System (H21). Summary I. No. This is an HPL number change. There is no change to system design or function. The parameters upon which the accident analysis in the FSAR was based are not changed. II. No. Malfunctions of a different type are not created, since there is no change to the system design, function, or components. III. No. The margin of safety as specified in the Technical Specification is not reduced.
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Page 3 of 278 SE No.:' 88-003 Source Documents' DCN 2083 Description of Change , Change the Auxiliary Building Ventilation System (M38)' diagram to. -l indicate location of splitter dampers'which are already installed in the ! plant. i Summary I. No. The addition of splitter dampers to the system diagram is not a physical change to the plant. The dampers are. indicated on the duct layout drawings and vere part of the original plant design, therefore accident. analysis is not affected. II. No. The drawing change is not a physical change to the plant. Since i these dampers were part of original plant design, different ' accidents / malfunctions vill not be created. The addition of damper locations to system diagram do not affect the
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III. No.
' Technical Specifications.
i SE No.: 88-004 Source Document: DCN 2079 Description of Change Add MPL number to several Radvaste Building Ventilation System (M31) ! drawings. Summary I . No .' Addition of HPL numbers to drawings is not a physical change to the plant design, therefore accident analysis is not affected. LII. No. Addition of MPL numbers to drawings is not a physical change to the plant design, therefore different accidents / malfunctions vill not be created. III. No. The addition of MPL numbers to drawings does not affect Technical Specifications. l
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Attachment 3 PY-CEI/NRR-0979 L Page 4 of 278 SE No.: 88-005 , Source Document: DCN 2030 l Description of Change Incorporate editorial changes on N62, N64, N27, R48 and G50 System P&ID and elementary drawings. Summary I. No. Addition of notes does not increase the probability of occurrence of
- i. an accident or malfunction of the equipment to the safety previously l
evaluated in the FSAR. II. No. As this is a drawing change only, the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR is not created. I III. No. The drawing update does not change the system function as defined in the Technical Specifications. SE No.: 88-006 Source Document: DCN 2067 Description of Change Correct drawing references on one-line diagrams on the Instruments System (R41). Summary I. No. This DCN revises drawing references only. It does not increase the probability of an accident or malfunction of equipment important to safety. II. No. As this DCN updates drawing references only, no possibility of a different type of accident / malfunction is created by this change. III. No. The margin of safety as defined in the bases for any Technical Specification is not reduced by this DCN, as it revises drawing references only, s
4 Attachtint 3 PY-CEI/NRR-0979 L Page 5 of_278
.SE No.: 88-007 Source Document: DCN 2064
. Description of Change.
Add valve symbols and MPL numbers to P&ID drawings B-814-047 and D-302-221 on the Turbine Building Closed cooling System (P44).
' Summary I. No. Addition of previously installed valve MPL' numbers to drawings B-814-047 and D-302-221 vill facilitate location of equipment, and vill not increase the probability of occurrence or the consequences of an accident previously evaluated in the FSAR.
II. No. No newfaccidents or malfunctions are created. The plant configuration (P44 System) vill be accurately depicted on design drawings. III. No. Addition of valve symbols and MPL numbers to drawings B-814-047 and D-302-221 does not affect the Perry Plant Technical Specifications. SE No.: '88-008 Source Document: DCN 2073 i
. Description of Change Revise vendor drawing 4549-20-089-1 for the Division 3 Diesel Generator Lube Oil System to reflect minor editorial changes-to the vendor information.
Summary l I.~No. This is a minor editorial change that_ adds / corrects vendor ) information for system components; therefore, the probability of j occurrence or the consequences of an accident or malfunction of l equipment important to safety.previously evaluated in the FSAR (Section 9.5.9.4) is not increased. II. No. Since this is an editorial change that has no effect on system l components, the possibility for an accident or malfunction of a i different type than previously evaluated in the FSAR is not created. III. No. This is an editorial change that has no effect on the margin of safety as defined in the bases for Section 3/4.8 of the Technical Specifications. l
i Attschmant 3 PY-CEI/NRR-0979 L Page 6 of 278 SE No.: 88-009 Source Documents- DCP 86-0937, Rev. O DescriptionofChande ( .i Add temperature indicators to charcoal adsorber-vault to monitor vault
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temperature both locally and remotely, in the Offgas System (N64). ! Summary I. No. Adding temperature indication vill not increase the probability of malfunction. Installation of the temperature instrumentation vill assist in ea-ly detection of operational malfunctions, but does not affect the otability of such malfunctions since it is passive monitoring .natrumentation. Temperature indicators vill monitor the charcoal adsuruer vaults internal room temperature to verify proper operation of the refrigeration units which cool the vaults. The consequences of system rupture or a seismic event are not increased by adding passive temperature monitoring instrumentation. The refrigeration units are not considered important to safety. -The consequence of failure of the refrigeration units would decrease,- 1
-because remote temperature indication and hi/ low vault temperature !
annunciation vill provide a more expeditious indication of possible malfunctions, thereby preventing or decreasing the. consequence of an equipment failure. II. No. Clarifying the FSAR (11.3-2, Sheet 2) to reflect new temperature l indicators vill not create a new type of accident or malfunction. The new instrumentation vill passively monitor the' charcoal adsorber vault room temperature. This change does not contribute to events or disturbances that are considered potential initiating causes of threats to the fuel and/or the reactor coolant. pressure boundary. III. No. Margin of safety as outlined in Section 3/4.11.2 " Gaseous Effluents" is not affected or reduced by adding temperature indication, which passively monitors the offgas system charcoal adsorber vaults. l l I __mm_. . __._-__m___-m_..____.___m _ _ _ _ _ _- __.__
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( PY-CEI/NRR-0979 L Page 7 of 278 SE No.s. 88-010 Source Document: DCP 86-0937, Rev. O Description ~of Change Install temperature sensing devices and remote indication in.the Offgas System (N64) vault A. I Summary. 1 I. No. This change provides additional-temperature detection, thus 1 decreasing the probability of a malfunction of equipment and increasing monitoring capabilities for prevention of fire in the j A vault. j l II. No. The change vill not increase the possibility of an accident or , malfunction of any type. It provides additional monitoring of temperature in vault A of the Offgas System. III. No. The offgas vault temperatures are not addressed in the Technical Specifications. SE No.: 88-011 : Source Document: DCN 2051 . 1 Description of Change Update drawing of the Offgas System, Drawing D-912-622, Revision P, to l delete a continuation arrow. i Summary I. No. This DCN updates the drawing and FSAR Figures 9.4-10, Sheet 1 of 2 and 9.4-26 to depict the actual field installation. -i The original work was completed and the installation was never as-built on the drawings. The sample line that is to be removed from the documents listed above is now being taken off of the radiation sample line that runs to the offgas vent isokinetic sample panel, in lieu of sampling directly from the offgas vent itself. This change does not alter the basic function of the sample line, therefore the original design basis remains the same as previously l analyzed in the FSAR. , II. No. See Item I above. ; III. No. Since the sample line provides a sample that is from the offgas vent, the system operability has not changed, therefore the margin of safety defined in the bases of the Technical Specification is not changed or reduced. 1
Attachment 3 PY-CEI/NRR-0979 L Page 8 of 278 SE No.: 88-012 Source Document: PAP-0113, Rev. O Description of Change Cancel the administrative controls covering the activities of the Nuclear Test Section during the initial test program on Perry Unit 1. Summary I. No. All Nuclear Test Section activities required for the initial test program for Perry Unit 1 are complete. Therefore, cancellation of PAP-0113 (Nuclear Test Section Organization and Responsibility) vill not result in an increase in the probability of occurrence or consequences of an accident or malfunction previously evaluated in the FSAR. II. No. This procedure cancellation does not create or result in the possibility of an accident or malfunction of a different type evaluated previously in the FSAR. III. No. The margin of safety defined in the Technical Specifications is not affected by this procedure cancellation. SE No.: 88-013 Source Document: DCP 87-0273, Rev. O Description of Change Reroute the existing underground fire protection lines around the new Maintenance Support Facility, and provide a supply for a sprinkler system into the new facility. Summary I. No. The operating condition of the underground fire protection water supply is not changed. Rerouted main vill be able to provide adequate water to all systems. II. No. There are no potential initiating causes of threats to the fuel and the reactor coolant pressure boundary. III. No. Only administrative aspects of fire protection are covered in the Technical Specifications. l
Attachment 3 PY-CEI/NRR-0979 L Page 9 of 278 SE No.: 88-014 Source Document: NR HM05 2871, Rev. O Description of Change i Evaluate the nonconformance report for damage to several reinforcing bars in the Radvaste Building. Summary I. No. The damaged reinforcing bars in the Radvaste Bldg. 623'6" slab are acceptable as is based on calculations. The calculations show that the structural integrity of the slab is not compromised. II. No. Since the structural integrity is not impaired, the possibility for an accident or malfunction of a different type is not created. III. No. Since the integrity of the concrete structure is not impaired, the margin of safety defined in the bases of the Technical Specifications is not reduced. l SE No.: 88-015 Source Document: DCP 86-0929C l Description of Change Install a sealant retention ring and inject sealant to eliminate the Feedvater System Valve IN27-F0560A leakage. Summary I. No. Valve IN27F0560A remains in compliance with ASME Section III (NB) requirements. General Electric has evaluated the impact of the sealant upon reactor components, water chemistry, and flow. The sealants X-36*A, X-36*B, and G-Fiber
- have been found to have no adverse effects on safety, functionality or integrity and are therefore, acceptable for leak sealing at Perry.
II. No. No new accidents or malfunctions are created based on the reason provided for Item I above. III. No. The reason provided in Item I above indicates the margin of safety is not reduced. Technical Specification requirements / limits are not changed. I
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Page 10 of 278 SE No.: 88-016
' Source Document: DCP 86-0609, Rev. 0 De'scription ofLChange .
-1 Install new Instrument Air (PS2) Distribution System. j
'l Summary 1 I. No. The only accident or malfunction-discussed in the FSAR for'the- .
Instrument Air System is the " Loss of Instrument Air" discussed in a section 15.2.10 and.15A.6.3.3. The probability of occurrence of this accident is not increased since the new, velded, stainless steel distribution system vill be more reliable, i.e. less prone to joint failure. The consequences of this accident-remain the same, V i.e.'all safety-related equipment fails to a safe position, the MSIV's close and the. plant trips (reactor scram on MSIV position). II. No. No new accidents or malfunctions are created by the installation of the new Instrument Air Distribution System. The new distribution system is basically the same as the old system design, except for the use of more reliable materials and better on-line maintenance provisions (more system valving). , III. No. . The Technical Specification bases do not address the P52, Instrument .i Air System. i SE No.: 88-017 l
. Source Dncument: DCP 86-0629E, Rev. O Description of Change Install and modify the Floor and Equipment Drains System (P68) piping for !
the I&C hot shop. Summary I. No. Minor drain modification and added inputs have no impact on any i equipment important to safety. II. No. The scope of this DCP serves to allow collection of discharges from the existing inservice inspection equipment drain with the added hot shop sink, ice maker and humidifier drains. All inputs are hardpiped and therefore no new accident or malfunction possibilities are created. III. No. Drain line modifications do not affect the Technical Specifications. Therefore, this DCP does not reduce the margin of safety as defined in any bases for the Technical Specifications.
Attschmint.3 ' PY-CEI/NRR-0979 L l.R Page 11 of 278 SE No.: 88-018 Source Document: DCP 87-0569, Rev. O Description of Change Upgrade the' radio link to Lake County-Sheriff's Dept. from 39.58 MHz to 800 MHz; add radio phone in Radwaste Control Room and in CEI Room of the
-Technical Support Center.
Summary I. No. The radio system is a nonsafety system and a malfunction of this equipment vill not'cause an accident. Upgrading the radio link to the Lake County Sheriff's Dept. from a 39.58 MHz to an 800 MHz' radio 2 link improves the reliability of the link due to better equipment. J technology. - A malfunction of the two additional radio phones or the 800 MHz link I will not affect the operation of the existing radio phones or the
. plant radio system. The radio phones are stand alone units with separate power supplies which interface with the plant radio system for receipt and transmission of radio signals only. The 800 MHz
-link equipment is separate from the plant radio system. Therefore ;
the reliability of the radio system or any other equipment important '
'to safety is not affected.
II. No. A malfunction of the 800'MHz radio link and two additional radio phones will have the same consequences as failure of the 39.58 MHz radio link'and other radio phones. The malfunction vill affect only those components of the entire communication system. Therefore, the possibility for an accident or malfunction of a different type than previously evaluated in the FSAR is not created. III. No. There is no change to Technical Specification Section 3/4.9.5. a
u i Attachm2nt 31 PY-CEI/NRR-0979 L , i Page 12 of 278 SE No.: 88-019 Source ~ Document: FSAR CR 88-060 Description of Change t Evaluation of an FSAR. change request concerning a Chapter 5 Question and Response to NRC Question 440.4 Items 6.a and b, regarding safety / relief valve, testing and inspection. Update / revise the FSAR to comply with the
- Safety' Evaluation Report (SER).
Summary 1 I. No. This change updates FSAR to reflect the approved testing frequency for installed valves. II. No. See Item I above. III. No. This change does not reduce the margin of safety as defined in Technical Specification Section 4.0.5. SE No.: 88-020 Source Document: FSAR CR 88-004 Description of Change Evaluation of an FSAR change request to Chapter 12. This change request
. corrects inconsistencies within the FSAR, makes editorial corrections and provides a more accurate description of the radiation monitoring instrumentation.
Summary I. No. The radiation monitoring system instrumentation described in Chapter 12 is either nonsafety or augmented quality and does not perform a function important to safety. This instrumentation is not used in the accident analysis in Chapter 15. The changes in Chapter 12 cre minor in nature and do not change the design function of the equipment, therefore, the possibility for an accident is , neither created nor increased with these changes. ! II. No. The changes in this request do not create the possibility for an > accident not previously evaluated. The changes up-date the FSAR to i describe the as-built system. III. No. The level of detail provided within the FSAR for the radiation monitoring system exceeds the functional and operational requirements of Technical Specifications. The changes to Chapter 12 ; have no impact on Technical Specifications and do not reduce any ! margin of safety. I i j s 1 a c
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j Attachtsnt 3 l PY-CEI/NRR-0979 L l Page 13 of 278 l SE No.: 88-021 Source Document: FSAR CR 87-169 Description of change-Add to FSAR Sections 12.3.2.2.2 and 12.3.5 a description of.the ; Microshield computer program for design modifications,-and the ~ Hieroskyshine computer program for modifications' requiring air scatter calculations. Summary ; I. No. This program merely provides for health physics shielding design input to the DCP process. The modification itself is evaluated to . determine the effect on safety equipment. ' II. No. -See Item I above. l III. No. The Technical Specifications are not affected by this change. SE No.: 88-022 Source Document: FSAR CR 87-170 Description of Change Correct the sensitivity of health physics equipment in FSAR Table 12.5-3. ; i Summary { i I. No. This is not safety-related equipment, nor would the performance of ' this equipment have any consequence on the occurrence or mitigation of an accident previously described. II. No. The modification to the wording in the FSAR to provide for a better description of nonsafety equipment's features vill not result in the occurrence'of a new accident or malfunction. III. No. The information provided for this equipment is not utilized or referenced in the bases for any Technical Specification. !
'Attachmsnt,3 PY-CEI/NRR-0979 L Page'14 of 278 SE No. 023 Source Document: FSAR CR 87-171-Description of Change Change the sensitivity of a personnel monitoring instrument in FSAR
. Chapter 12 to be consistent with the vendor's specification.
Summary-I. No. This is not safety-related equipment, nor would-the performance of ; this equipment have any consequence on the occurrence or mitigation of an accident previously described. II. No. The modification to the wording in the FSAR to provide for a better c 1
, description of nonsafety equipment's features will not result in the ;
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. occurrence of a.new accident or malfunction. [
III. No. The information provided for this equipment is not utilized or referenced in the bases for any Technical Specification. i SE No.: 88-024 Source Document: FSAR CR 88-020
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1 Description of Change i Revise FSAR Chapter 12 to remove the description on the neutron Transversing Incore Frobes (TIPS), as these have been removed from the plant, and replace it with a-description of the gamma TIPS. I Summary f I. No. The newly installed gamma TIPS will help to extend fuel life, increase operating margin,-and improve operating accuracy. This change vill not increase plant power levels,'effect effluents, or offsite radiation levels. It merely updates the FSAR'to reflect current plant conditions. II. No. See Item I above. 1 1 This change does not affect the bases for any Technical III. No. Specification. l i i
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JSE No.: 88-025. Source Document: FSAR CR 88-027-l Description of? Change-Change: FSARlSection 12.3 t'o. incorporate the as-built configuration er the Plant VentilationLSystem;(M11, M14). Summary I..No. . Changing out the roughing and HEPA filters in.non-ESF exhaust e plenums at the design. dirty value rather than twice the initial
~c lean value as stated in FSAR'Section 12.3 vill not affect system-operation or function. The design dirty filter dp values were developed'such.that system flow would be maintained under dirty filter loaded conditions. . Additionally,'this change is more' conservative since these values are less than twice the initial clean values.
Not meeting the HEPA filter. arrangement guideline'of-3 high by: 10 vide as' set forth in Regulatory Guide 1.140 has no'effect on the-ability of the Exhaust plenums to meet their' design intent of filtering. contaminants from the air. 'This guideline.is a maintenance' item to provide easier access to the filters'for change out and is not. required for. system performance. The exhaust' plenums at. Perry followed this guideline, except where space limitations would not allow for it,. consequently not all of our plenums meet the r arrangement guideline.
-Changing:the flows and dilution factors on Table 12.3-12 does'not:
affect plant safety. .The M11 and M14 systems are both nonsafety and these changes have no impact on their ability to meet their design
. function.- The lover. flow rates are already described in FSAR:
l Section 9.4.6.3 (Design' Evaluation of'the M14 System), thus the changes to the Table vill'be in agreement with this section. In addition,-by adding the M11 syster.'to the table for clarification of how the dilution is obtained does not change the intent of the Table. Since the FSAR CR does not change the operation or function of the Plant Ventilation systems from their original design intent, the parameters upon which the accident analysis in the FSAR vere based have not been affected. i II. No. .The FSAR CR does not create the possibility of an accident or L malfunction of a different type than previously evaluated in the FSAR. There~are no components being added to the Plant Ventilation 1 systems, nor are ve changing the operation or function of these systems. I l
T lAttechssntL3 PY-CEI/NRR-0979 L Page 16 of 278'
'SE No. . 88-025 (Continued)
Summary- (Continued) III. No.
. The FSAR CR does'not change or alter the Plant's operation or function in any way. It simply corrects Chapter 12 of the FSAR to agree with the as-built as-designed Plant 1 Ventilation systems. The margins of safety as_ defined in the bases for the Technical Specifications are not affected.
SE No.: 88-026 Source Document: FSAR CR 88-031
, Description of Change Editorial changes to FSAR Sections 9.1, 9.2, 9.3, and 9.5.10 as a result of the review to update the FSAR per 10CFR50.71.
Summary I. No. No accident or malfunction to. existing equipment is' involved. The changes'are editorial in nature,.i.e., clarification of existing. text, consolidation / deletion of repetitive material to enhance readability, etc. II. No. No new-accidents or malfunctions are involved. Changes are editorial. III. No.- No-Technical Specification margin or safety is involved. SE No.: 88-027 Source Document: FSAR CR 88-032 Description of Change ~ Editorial changes to FSAR Chapter 12 as a result of the review to update the FSAR per 10CFR50.71.
- Summary I. No. No accident or malfunction to existing equipment is involved. The i changes are editorial in nature, i.e., clarification of existing text, consolidation / deletion of repetitive material to enhance readability, etc.
II. No. No new accident or malfunction is involved. Changes are editorial. III. No. No Technical Specification margin of safety is involved. L i 1 -
Attachz:nt 3 }- PY-CEI/NRR-0979 L l Page 17 of 278 SE-No.:- 88-028 Source Document: MFI 1-88-012 Description of Change Route a hose from valve 1B21-F016 shroud to the dryvell equipment' drain sump. I Summary I. No. 'FSAR Section 5.2.5.4 " Limits for Reactor Coolant Leakage" addresses both identified and unidentified leakage, which cannot exceed a total of 30 gpm, (of which up to 25 gpm can be identified leakage and 5'gpm, unidentified leakage). Due to the inspection performed on valve 1B21-F016, (leak at the body to bonnet seal ring / mechanical joint), this leakage now can be classified as " Identified" rather than " Unidentified". By identifying the leakage the hose can be routed to the equipment drain sump which is established as the " Identified Leakage Sump" per the FSAR. The identified leakage is not reactor coolant pressure boundary leakage. II. No. The possibility of an accident or malfunction of a different type
.than previously evaluated is not increased. _The floor drain sump will still be utilized to detect unidentified leakage, such as a crack in the primary system piping as described in the FSAR, and the-equipment drain sump will still be used to detect equipment / identified leakage as described in the FSAR.
III. No.- The margin of safety as descrlbed in the Technical Specifications is not reduced. The limits of 2S gpm identified leakage and 5 gpm unidentified leakage vill still be adhered to. I
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l _q Attachm:nt 3 :j PY-CEI/NRR-0979 L i Page:18 of 278 I SE No.s- 88-029 " Source Document MFI 1-88-012 J 1
' Description'of Change l Seismic clearance /falldown evaluation for the impact of the temporary shroud around valve 1B21-F016 remaining inside the dryvell'during operation. , ?
Summary: I. No. The shroud was evaluated for potential seismic clearance violations (SCVs) in accordance with FSAR Section 3.2.1'and per calculations FC 36:01.3.2.26.49. No potential SCV/falldown concerns are created. Therefore, the. probability of an accident or malfunction is not increased. _ II. No. No potential SCVs/falldown concerns are created. Therefore, the-possibility for an accident or malfunction of a different type is not created. III. No. Since no potential SCVs or falldown concerns are created, the margin of safety is not reduced as defined in the bases for the Technical Specifications. l 1
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'SE No.s' 88-030 Source: Document - MFI 1-88-013 Des ription'of Change.
- Route"a hose:from valve 1B33-F060B shroud to the drywell equipment drain
. sump.
~ Summary I. No. FSAR Section 5.2.5.4:" Limits for Reactor Coolant Leakage" addresses.-
both identified and unidentified leakage, which cannot exceed a total of 30 gpm,'.(of which'up to 25 gpm can be identified leakage and 5 gpm, unidentified. leakage). Due to the-inspection performed on valve 1B33-F060B, (leak atlthe body to housing gasket / mechanical joint), this leakage now can' be classified as'." Identified" rather than " Unidentified". By -
, identifying.the leakage the hose can.be routed.to the equipment t
. drain sump which is established as the " Identified: Leakage Sump" per the FSAR. The identified leakage is not reactor coolant pressure boundary leakage..
II.;No. The possibility of an accident or malfunction of a different type-than previously evaluated-is not increased. The floor drain sump vill still be utilized to detect unidentified leakage, such as a ._ crack in the primary system piping as described in the FSAR, ande the ' equipment drain sump vill still be used to' detect-equipment / identified' leakage as described in the FSAR. III. No. The margin of safety as tiescribed in the. Technical Specifications is not reduced. 'The'Maits of 25 gpm identified leakage and 5 gpm p ,> unidentified leakage vill still be adhered'to. s
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Attsch2:nt 3 PY-CEI/NRR-0979 L' , Page 20 of 2781 : c SE No.:~ 031- i p Source Documents- MFI 1-88-013
.. j Description of Change !
Seismic clearance /falldown evaluation for~the impact of the temporary. i shroud around valve 1B33-F060B remaining inside the drywell during l- operation. . Summary:
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I . No . - The shroud was evaluated for potential seismic clearance violations (SCVs) in accordance with FSAR Section 3.2.1 and per calculations FC 36:01.3.2.25.49.- No potential SCV/falldown concerns are created.- l Therefore,.the probability of an accident-or malfunction is not increased. II. No. No potential SCVs/falldown concerns are created. Therefore, the possibility for an accident or malfunction of a different type is tnot created. III. No. Since no potential SCVs or falldown concerns are created, the margin of safety is not reduced as defined in the bases for the Technical Specifications.
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Attechm:nt 3 PY-CEI/NRR-0979 L Page 21 of 278 SE No.: 88-032 Source Document: SXI-0017 Description of Change Special Test Instruction which contains similar test requirements to those contcined in FSAR Chapter 14, Test Number 23D for the Startup Test Program. Since the Startup Test Program has been officially completed, this plant procedure vill test the replaced Reactor Feedpump A to the applicable requirements. Summary I. No. FSAR, Chapter 15 describes the most severe feedvater condition as feedveter controller failure at maximum demand and capable of exceeding the-130% NBR feedvater flovrate. This condition _can only be produced if both feedpump turbines are in the auto control mode, which would allow the controller to integrate to maximum controller output demand. Administrative controls will restrict reactor operations to one feedpump turbine in auto operation until successful completion of SXI-017 ("Feedvater Runout Capacity Retest due to Replacement of RFP-A"). This will not allow the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR to be increased. II. No. Administratively controlling reactor operations in not placing both reactor feedpumps in auto flow control until successful completion of this test procedure does not create the possibility for an accident or malfunction of a different type than previously evaluated in the FSAR. Reactor pressure vill be raised /lovered to obtain necessary data at various points in the test. Reactor pressure vill be maintained within Technical Specification limits at all times. III. Ne Since Technical Specifications vill be adhered to, the margin of safety as defined in the bases for any Technical Specifications vill not be reduced by the performance of this test procedure. Also, the acceptance criteria includes provisions for taking up to a 0.02 HCPR penalty depending on the actual runout flow achievable. This will not cause the FV Runout Transient MCPR to exceed the limiting transient.HCPR and therefore does not reduce the margin of ) safety as defined in the bases for any Technical Specification.
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~SE No.: 88-033 Source Document: DCP 87-0460, Rev. O Description of Change Install flovmeter in the. Hydrogen Supply System (N35) to monitor hydrogen supply to the main generator. (I&C Evaluation). ,
Summary I. No. There is no-probability of an increase in occurrence or consequence of.an accident or malfunction of equipment important to safety previously evaluated since the system analysis has shown that failure of the hydrogen system does not compromise-any safety-related systems to prevent safe shutdown, and serves no safety function (FSAR Sec. 10.2.5.3). II. No. The possibility for an. accident or malfunction different than-those previously' evaluated is not increased, because the same design.and installation parameters were taken into account in the evaluation of - 1 this installation. III. No. This installation does not affect the margin of safety defined'in the bases of the Technical Specifications since the system function
-has not been changed or reduced.- This system serves no safety function.
i SE No.: 88-034 Source Document DCP 87-0460, Rev. O. Description of Change Install flovmeter in the Hydrc a n Supply System (N35) to monitor hydrogen j supply to the main generator. (Mechanical Evaluation). j i Summary I. No.. The same piping code (B31.1) is being used so that the probability or the consequence of an accident important to safety is not j increased. The addition of the flow monitor does not alter the i system function. II. No. The same piping code is used sc that no new accident / malfunction is 1 created. III. No. The generator hydrogen supply is not covered by the Technical Specifications. Furthermore, this is not a functional change to the syatem. i' l i L
Attachment 3 PY-CEI/NRR-0979 L Page 23 of 278 SE No.: 88-035 Source Document: DCP 87-0562, Rev. 0 , Description of Change Replace valves 1E12-F563, F564, F606 in the Residual Heat Removal Sysiem (E12). Summary I. No. The modification / alteration to the RHR vaterleg pump (1E12-C003) vent and drain valves in no way affects any component or system which could cause the probability of occurrence of an accident or transient (FSAR Chapter 15) to increase. Replacement of three existing 1/2" diameter Dresser diaphragm globe valves with 3/4" diameter " packed" Kerotest globe valves does not increase probability of malfunction of equipment. New globe valves are more reliable than the existing Dresser valves when performing system testing and filling / venting. The consequences of an accident analyzed in the FSAR are not increased by this removal of existing Dresser valves and replacing them with a " packed" Kerotest valve. This DCP is unrelated to Chapter 15 accidents such as " Inadvertent RHR Shutdown Cooling Operation" or " Failure of RHR Shutdown Cooling". Replacing the existing " passive" valve with a " passive" valve does not negatively affect safety. The consequences of failure of equipment important to safety are not increased by this design change where a Dresser globe valve is being replaced with a Kerotest valve. The new Kerotest valve meets the same design requirements , (ASME III) as the existing Dresser valves. II. No. The proposed clarification to the FSAR vould not create a new type ' of accident or malfunction. This change does not relate to events or disturbances that are considered as potential initiating causes of threats to the fuel and/or the reactor coolant pressure boundary. III. No. The margins of safety as defined in Technical Specifica-tions 3/4.4.9, 3/4.5, 3/4.6.3, 3/4.9.11 are unchanged and unaffected by this proposed modification to the RHR vaterleg pump vent and drain. This DCP vill remove the troublesome Dresser valves and ; allev operators to vent and fill the RHR System without affecting ' reliability or safety. ('.', s. e
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SE No.2, 88-036 Source Document: .DCP.87-0724A, Rev. 0-S . .. . J -Description of Change Add a relay (J13PA7012) to the Division 1 Diesel Generator governor control circuit to enhance governor control reliability. (Electrical Evaluation)..
' Summary: , ,
See Safety Evaluation 88-037. SE No.: 88-037 Source Document: DCP 87-0724A, Rev. O Description of Change
. Add a relay (J13PA7012)'to the Division 1 Diesel Generator governor control circuit to enhance governor control reliability. (Mechanical Evaluation) .,
Summary I. No. The probability of occurrence of an accident or malfunction of equipment important to safety is reduced by this design change. The resulting Division 1 Dioul Generator governor control circuit eliminates the potential for inadvertent mispositioning of the governor's preset position while the engine is in standby condition. This change also prevents failure of the governor's motor operated potentiometer during speed. reset from'(simultaneous) dual actuation by the reset circuit and the manual control switches. The relay added by this change meets or exceeds the' environmental . equipment q'lalification requirements for the original design. This i relay also meets or exceeds the seismic qualification requirements q for the original design. The remainder of-this design change (i.e., viring, separation requirements, etc.) is similar to the existing design. Hence the installation of this design change is equal to the original design, and the function and perforraance of this design )
,is (qual to or.bett.ar than the original design. Thus, the !
probability of a malfunction of equipment with respect to this change is unchanged or reduced compared to that evaluated previously. ) 1 The consequences of an accident or malfunction previously evaluated ! in the FSAR ere unchanged with respect to this design change. Since l the installation, function, and performance of the original design 1 are naintained or enhanced by this change, the Division 1 Diecol Generator's response to an accident is unchanged, and hence the consequences of an accident ao previously evaluated are unchanged.
R l Attschtsnt 3 PY-CEI/NRR-0979 L Page 25 of 278 q SE No.: 88-037 (Continued) Summary (Continued) II.'No.' .No new possibility for an accident or malfunction of equipment of a different type than any evaluated previously is introduced by this
. change, since the design and qualifica' tion of the parts and installation used in this change-are equal to or better than those used in the origina1' design codes / standards and thus. creates no nev i potential for malfunctions not previously evaluated. !
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'III. No. 'The margins of~ safety as defined in the bases for Technical Specifications are unchanged with respect to this design change.
SE No.:- 038 Source Document: SCR 0-87-1104 through 1115 ; Description of Change Setpoint parameter revisions / additions for hi-temperature and lov flov , protection for the Control Room Emergency Recirculation System (H26) l electric heating coils. i Summary I I. No. FSAR Chapters 6, 7 and 15 do not reflect analyses related to M26 i System plenum EHC energization/de-energization on associated instrument trip settings. The probability of occurrence / consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR is thus
.not increased. I II. No. The scope of this item is related to a revision of lov flow / auto reset / manual. reset temperature switch setpoints in the conservative direction. No other system equipment is affected. A different type of accident / malfunction than previously evaluated in the FSAR is thus not created.
III. No. The subject setpoint parameters are not described in the Technical l Specifications. l l i
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Attachatnt 3 PY-CEI/NRR-0979 L 1 Page 26 of 278 SE No.'s. 88-039 Source Document: FSAR CR 88-052 Description of Change Revise Chapter 4 of the FSAR'to_ reference the latest approved revision of the General' Electric Standard Application for Reactor Fuel - GESTAR II (NEDE-24011-P-A and US) which describes the core and' fuel design and has been designed to be incorporated by direct reference'within the appropriate sections of the FSAR. Chapter 4 NRC Questions and Responses are also being incorporated. l Summary
'I. No. This revision does not change or increase the probability of occurrence or the consequences, for an accident or malfunction of equipment important to safety previously evaluated in the FSAR because.there are no changes in plant equipment, system design or analyses due to this change.
This referencing change does not delete information or analyses found within the FSAR. Appendix A the " Safety Analysis Report Road Map" (previously approved by the NRC) delineates what and where information is found in GESTAR, and what information must be retained'in'the FSAR. Therefore, there is no change in the current FSAR analysis results. II. No. This revision does not create'a possibility for an accident or malfunction of a different type than evaluated previously in the FSAR because there is no change in the plant equipment, system design or analysis due to this referencing change. III. No. There are no changes or reductions in the margins of safety as defined in the bases for any Technical Specification. Referencing to the-appropriate sections of GESTAR II does'not involve any changes to the current FSAR analyses results thus, the safety margins are maintained. 1 I l
a Attachm:nt 3 PY-CEI/NRR-0979'L r Page 27 of 278 SE No.: 88-040 -l Source Document FSAR CR 88-044 , i
. Description of Change !
Revise FSAR Section 2.3.5.1 to' correctly identify the locations of the Perry effluent release vents. Summary I. No. Although there are changes to the identified effluent vent locations there are no corresponding changes in dispersion calculations because the specific release points are contained within the region of the original points and/or are very close to the original points. In addition, both sets of release points are subject to building . vake inflaence of either of the two large buildings -- containment and turbine building. Therefore, the distance to the site boundary W can be. measured-from the closer of the two buildings, as was done originally. Thus, because there are no changes in distances from those buildings to the site boundary, there are no changes in the dispersion estimates, and consequently the probability of an accident previously evaluated in the FSAR is not-increased. II. No.- Dispersion estimates do not change as a result of this correction, therefore, the possibility of an accident or malfunction different than any previously evaluated is not created. III. No. Dispersion estimates do not change as a result of this correction, therefore,'the margins of safety as defined for any Technical Specification bases is not reduced. i
Attachm nt 3 1 PY-CEI/NRR-0979 L-Page 28 of 278 SE No.: 88-041 Source Document: FSAR CR 88-045 Description of Change Delete from FSAR Section 2.3.3.1, reference to devpoint measurements taken at 60 meters to ensure consistency with the data available from the seven year data set. The devpoint measurements have not been required or taken for several years. ; Summary I. No. The deletion of references to devpoira measurements taken at a height of 60 meters in the FSAR does not increase the probability of , occurrence or the consequences of an accident or equipment ' malfunction previously evaluated in the FSAR. II. No. The deletion of references in the FSAR, to devpoint measurements ! taken at a height of 60 meters does not create the possibility for : an accident or malfunction of a different type than previously i evaluated in the FSAR. III. No.- Deletion of references in the FSAR to dewpoint measurements taken at , a height of 60 meters does not reduce the margin of safety as ! defined in the bases for any Technical Specification. SE No.: 88-042 Source Document: FSAR CR 88-046 I Description of Change Revise FSAR Section 2.3.3.3 to provide information regarding'the meteorological data recovery rates for the seven year data period. Summary I. No. Meteorological data recovery rates are within the limits established by the NRC, therefore, the probability of an accident or equipment malfunction is not increased as previously evaluated in the FSAR. II. No. A change in meteorological data recovery rates d>es not create the possibility for an accident or malfunction of a different type than evaluated previously in the FSAR. III. No. Meteorological data recovery rates remain within the limits set by , the NRC and therefore, do not reduce the margin of safety as defined [ in the bases for any Technical Specification. I
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;SE No.: 88-043
, Source Documents- .FSAR CR 88-047 j
Description of Change Add'a paragraph-to FSAR Section 2.3.3.2 to clarify the methods for meteorological-data reduction. Summary I. No. , Clarification of the method used for meteorological' data reduction
-does not increase the probability of an accident or malfunction of 'i equipment previously evaluated in the FSAR.
II. No. -Data reduction of meteorological data does not create.the-possibility for an. accident or a malfunction of a different type
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than any evaluated previously in the FSAR. I i III. No.. -The margin of. safety as defined in the bases for.any Technical i s Specification'is not' reduced by clarification or minor changes to I the methodology.for meteorological' data reduction. I SE No.: 88-044 , Source Document: FSAR CR 88-048 Description of' Change Correct FSAR Section 2.3.3.1 regarding precipitation measurements-that were in error due to problems caused'by the tipping bucket' rain gauge. Summary I. No. The rain gauge is not a safety-related instrument and therefore,.any errors in. recorded precipitation values using the rain gauge do not increase the probability or consequences of an accident or malfunction of equipment important to safety,.previously evaluated in the FSAR. II. No. See Item I above. III. No. This change does not affect the margin of safety as defined in the bases for any Technical Specification. I i I l 1 l j j L___--.----_
Attcchssnt 3 PY-CEI/NRR-0979 L \ Page 30 of 278 N SE No.: 88-045 \ Source Document: FSAR CR 88-049 L
. Description of= Change l
Include new information to FSAR Section 2.3.1.2.2 relative to the recurrence interval of tornado strikes at the. Perry site. Summary I. No. This change provides new data on the probability of tornado strikes at the Perry site. It decreases the probability of an accident or-malfunction of. equipment important.to safety, because the
~
y probability of a tornado strike is-less frequent than previously evaluated in the,FSAR. l.
\ II. No. .See' Item I abo ~ve.
. .\ .
III. No. Because the'new data suggests that the probability of a tornado strike at the Perry' site would,be less frequent than previously evaluated, the margin of safety as defined in the bases for any Technical. Specification is not reduced. SE'No.: 88-046 Source Document: FSAR CR 88-050 Li Description of Change Incorporate into FSAR Section 2.3.2.1.7 information regarding station pressure at the Perry site as compared to station pressure measured in Cleveland. Summary I. No. The incorporation of information regarding station pressure at the Perry site into the FSAR has no impact on safety equipment and i
-therefore, does not increase the probability of occurrence or the !
consequences cf an accident or malfunction of equipment important to j safety previously evaluated in the FSAR. II. No. Same as Item I above. III. No. This change has no effect on the margin of safety as defined in the bases for any Technical Specification. 1
Atttchm:nt 3 PY-CEI/NRR-0979'L Page 31 of 278 l ' SE No.:- 88-047 Source Document: FSAR CR 88-051 L Description of Change Change FSAR Sections 2.3.2.1, 2.3.3.1, 2.3.3.3 and 2.3.4.1, Tables 2.3-6 thru 2.3-30, Figures 2.3-1 thru 2.3-17, and Appendix 2B and 2C to correct l the available meteorological data base from a three year data source to a seven year data source. This represents long term conditions at the Perry site.' ' Summary I. No. The long term meteorological conditions onsite at Perry determined from the 7 year data base were consistent with those identified in l the 3 year data base. Therefore, the probability of occurrence or consequences of an accident or malfunction of equipment to safety previously evaluated in the FSAR have not increased. II. No. Because the 7 year site data is consistent with the 3 year data, the possibility for an accident or malfunction of a different type than evaluated previously in the FSAR should not exist. III. No. Because 7 year site data is consistent with the 3 year data, therefore, the margin of safety as defined in the bases for any Technical Specification is not reduced. SE No.: 88-048 Source Document: FSAR CR 88-056 Description of Change , Incorporate editorial changes to FSAR Sections 2.1 through 2.4 as a result of review to update the FSAR per 10CFR50.71. Summary I. No. No accident or malfunction to existing equipment is involved. The changes are editorial in nature, i.e., clarification of existing text, consolidation / deletion or repetitive material to enhance readability. II. No. No new accident or is malfunction involved. Changes are editorial. III. No. No Technical Specification margin of safety is involved.
l Attachunt 3 i PY-CEI/NRR-0979 L Page 32 of 278 ; SE No.: 88-049 ] Source Document: FSAR CR 88-057 Description of Change Delete seven 0&Rs from FSAR Sections 2.1 through 2.4, because they are _l not necessary or have been superseded by new information and FSAR .j changes. ! i ' Summary 1 I. No. This change only deletes Chapter 2 Q&Rs that contain information ! which has subsequently been superseded or is not necessary. This i. change does not affect any design bases accident or malfunction of equipment.- The change is editorial in nature._ ; II. No. This change does not affect accident analysis because it only deletes Chapter,2 0&Rs which contain information which has been superseded or is no longer necessary or applicable._ The change is editorial in nature. III. No. The margin of safety for any Technical Specification is not affected by this editorial change. SE No.: 88-050 Source Document FSAR'CR 87-138 Description of Change Revise FSAR Section 9.1 to show correct fuel hoist load liniit. Summary I. No. GE Procurement Spec and Vendor Manual states that the fuel hoist lifting limit is 1100250 lbs. This falls well within the FSAR requirements for the fuel rack's ability to withstand a pull up . force of 4,000 lbs. Testing of the load cell and force control ' switch is required prior to lifting of fuel. The hoist is equipped ) with a gauge which shows how much weight is on the hoist cable. ! There is no change to equipment installed in the field. This change has no effect or impact on Sect 15.7.4 of FSAR. II. No. The hoist is equipped with a gauge which tells the operator how much weight is on the cable. Assuming a load cell failure, the configuration is such that it will trip the hoist before 1100 lbs is 1 lifted. Testing of the load cell and holst cutoff is performed prior to any 7.ifting of fuel to assure proper operation of hoist j cutoft. III. No. The bases of the Technical Specifications do not address fuel hoist lifting capacity.
l< b Attechm2nt 3 h PY-CEI/NRR-0979 L j
) Page.33 of 278 j l
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\SENo.: 88-051 i <- Source Document: FSAR CR 87-139 i i
Description of Change Correct the explanation of Condensate Storage Tank (CST-Pil) system ' alarms and handling of overflow occurrences in FSAR Section 9.2.6.3. I Summary i ! I. No. This change to the CST alarm setpoint and the method for handling overflow occurrences do not have any effect on equipment that is important to safety. II. No. Nothing new from an accident or malfunction standpoint has been created by this change. The alarm description clarification simply i explains the actual " normal water level". Routing water to radvaste once overflow has occurred is a plant decision that has no impact, since transfer now'(via flex hose to Aux. Boiler Bldg. drains) and later (via hardpiped line off of 1P11-F531) involve routing water to the existing floor drain system. III. No. Technical Specifications applicable to.the Pil system are 3/4.5.2 "ECCS-Shutdown" and 3/4.5.3 " Suppression Pool". Both of these -; involve the required minimum inventory needed for.HPCS/RCIC systems and are unaffected by this change. l i i l 1 l I i i l a s l\
l AttachEsnt 3 PY-CEI/NRR-0979 L , Page 34 of 278 i SE No.: 88-052 : Source Document: FSAR CR 87-140 Description of Change Revise FSAR Section 9.2.7.2 to describe the grade of piping used in the i Service Water System (P41), detail the codes that this piping meets, and ! indicate the number of Service Water pumps required for each Unit. Summary I. No. The evaluated item does not physically change the plant, it only provides additional detail that better describes what presently l exists. All piping impacted by the above item is nonsafety and not required for the safe shutdown of the reactor. Previously postulated consequences of an accident are not impacted, since piping grade of service water piping does not change expansion joint design, therefore, an expansion joint rupture and resultant turbine building of flooding as detailed in the P41 safety evaluation (Section 9.2.7.3 of the USAR) are not impacted. Thus, no evaluations exist that would be impacted by this additional detail. II. No. Evaluated item does not physically change the plant, as it only. provides additional detail that better describes what presently exists. Since previous design does not change,.all considerations with respect to that design do not change. Therefore, the possibility of a new accident or malfunction does not exist. III. No. No margins of safety are reduced by this change. l
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! i AttachmInt 3' l PY-CEI/NRR-0979 L Page 35 of 278 SE No.: 88-053 l Source Document: FSAR CR 88-005 l I
l Description of Change Revise FSAR Section 9.1.4.1 on design bases for the Fuel Handling System, j to change the wording describing the fuel grapple's position of " fully 1 retracted" to " normal up" position when referring to the position at ! which adequate shielding exists. l l Summary f I. No. During normal operation of the fuel grapple the " normal up" position ' of the fuel hoist provides adequate water shielding over a grappled fuel bundle, whereas the " fully retracted" position does not. Redundant limit switches prevent the possibility of raising radioactive material out of the water. There is no change to the plant resulting from this change, and the consequences of an accident or malfunction are not increased. 1 II. No. The " normal up" position of a loaded fuel grapple does not create a j different accident or malfunction. Adequate water shielding is ' still maintained. III. No. Operability requirements in Technical Specification Section 3/4.9.6 are not affected by this change. In the case of a dropped bundle from " normal up," the 4,000 ft/lb impact energy is not exceeded ; (Technical Specification Section 3/4.9.7). j k l l
' Attachm:nt 3 .
PY-CEI/NRR-0979 L Page 44 of 278 SE No.: 070 !
' Source Document: DCN 1273, Rev. 0 3
Description'of' Change i Update Fire Protection System (P54) drawing D-914-001 to reflectias-built 4 configuration and to add reference match marks for continuation'onto nev l drawing'D-914-014.and -015. 4- Summary i I. No. There'is no increase in.the probability of occurrence or consequences of an accident or malfunction of equipment'important.to' safety because the operating condition of the water supply is not changed. 1 II. No. See Item I above. ; III. No. .No margins of safety are reduced by this change. SE No.: 071 Source Document: DCN 1911, Rev. O Description of Change Show toilet trailer configurations on FSAR Figure,9.2-16' drawing D-302-382, Potable Water Supply (P71), and identify / correct HPL numbers on the drawing. Summary ; I. No. Updating the P71 Potable Water Supply P&ID does not alter the description of the system as described in the FSAR. II. No. Correcting MPL numbers and showing toilet trailer locations has no effect on the safe operation of the. plant and does not-create the possibility for an accident or malfunction.of the plant. III. No. The Potable Water Supply System is not described in, and does not affect, the Technical Specifications. 1 i l l
i Attachment 3 PY-CEI/NRR-0979 L Page 45 of 278.-- ( I
'SE No.: 88-072 Source Documents. DCN_2103, Rev. O Description of Change Revise Auxiliary Steam System (P61) drawing D-302-054 to delete a vent
' location. The actual vent and valve were removed per DCN 1987, which neglected to remove former location on drawing. i Summary.
I. No. . Placement of vent on auxiliary boiler feedvater piping in a different location does not affect any safety-related equipment. II. No. The function of the. vent remains the same for'this line. Its i location, relative to other lines, has no effect on the plant. ; III. No. The Auxiliary Steam System is not addressed in the Technical Specifications. SE No.:- 88-073-Source Documents. FSAR CR 88-061 i Description of Change-Add to FSAR Section 11.4.2.2 a description of the newly installed dry active vaste (DAV) sorting equipment. Summary I. No. Equipment utilized for the sorting of solid vaste material has no relationship to systems important to safety. II. No. The failure of this equipment could not bring about an accident or malfunction as described in the PSAR, nor could it. create a new or different accident, since this system has no physical relationship (process or proximity) to any other system even remotely related to a safety function. l III. No. This equipment does not involve a parameter that could impact any l bases as found in the Technical Specifications. l. l-l
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f' Y f . 4R Attachmant'3 K ' ' i- "r 'PY-CEI/NRR-0979 LL "h , Page 46Lof?278 SE Nois; :88-074 .
. .-p Source' Document: ' FSAR CR 87-173
' Description 'of -Charige
-This change describes lthe UpdatedLSafety Analysis Report for. Unit 1 and
. clarifies'the current status of Unit:2. ,
. Summary-I. No. This change describes the USAR for. Unit l'and does not in'reasec the-
. probability of occurrence or-the consequences'of any accident.
II.'No. .See. Item I above. m
.III. No.- This change ~does not affect any margin ofDsafety as defined in thel bases for Technical. Specifications.
< SE No.: 88-075 Source Documents- FSAR CR 87-177' Description of Change
. Change FSAR Appendix 1B.to. add information which satisfies or' documents-closure of the license conditions.
Summary I. No. ..The. changes to Appendix 1B of the FSAR are based on correspondence
'between CEI and the USNRC that documents submittal and/or acceptance of information related to license commitments. The submittal of this information to the USNRC and/or acceptance by the USNRC does not increase the probability.of occurrence or consequence of an' accident or malfunction of equipment important to safety.
II. No. The submittal and/or acceptance of this'information does not create. t the possibility for an accident or malfunction of a different type than previously evaluated.
-III. No. The information does not reduce any margin of safety as defined in Technical Specifications.
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;j~ , ~ :SE No.i tj88-076 . .
- ' Source Document:', .FSAR CR.87-172 '
;j
.. Description'of Change 4 l >
' Update FSAR Sections 13.2.4.and 13.2.6 on general employeeltraining.' 'l
, Summary 1 9
y - I . '. No '. . This' change deals'only with personnel training.JIt is.. consistent:
~ .vith NUREG 0800 (13.2.2), Regulatory Guide.l.8; Rev.~.1, NUREG 0737,
-ANSI.18.1-1971,.10 CFR 50, and 10 CFR 55. This change does,not alter any' accident analysis nor impact ple.nt-safety.
1 1
~II. No'.' LSee Item I above.'-
1 This. change.will not impact the bases for any Technical.
- iIII. No. .
-Specification.-
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<- 'SE No.:- 88-077 ~
n ' Source Documents' -FSAR CR 87-158-Description'of Change-Update:FSAR Sections. 7.2.2.2, 7.3.1.1.2.b.7 and b.3, Table 7.1-4 and-L Figure 7.6-1(5) regarding the description of.the Main Steam Line Radiation Monitors and associated logic. Summary-I.'No. No accident or malfunction to existing equipment is involved. The-- changes are editorial:in nature, i.e.,; clarification:of existing-text, consol#.dation/ deletion of repetitive material to enhance readability, etc. E II.'No. No new accident or malfunction is involved. These changes are editorial, i 1.III. No. No Technical Specification margin of safety is involved because the' .; changes are editorial. ! Il l I
Attachment 3 PY-CEI/NRR-0979 L Page 48 of 278 SE No.: 88-078 Source Document: FSAR CR 87-159 I Description of Change Update FSAR Table 7.1-4 to provide correct range for the Emergency Closed Cooling (P42) system loop flow instruments. Summary i' I. No. The current instrument flow range stated in FSAR Table 7.1-4 is considered to be a typographical error (0-2600 vs. 0-2500 gpm). Regardless, reduction of the instrument flow range span provides slightly better indicator resolution to validate emergency closed cooling system flow rate (post-accident rated flow-1854 gpm). Revision of the indicator scale span also has no impact on FSAR Chapter 7 or 15 safety analyses. Based on previous discussion, it is concluded that the probability of occurrence / consequences of an accident or malfunction of safety related equipment previously evaluated in the FSAR is not increased. II. No.- No other systems or components described in the FSAR are impacted by the indicator range change. A different type of accident / malfunction not previously evaluated in the FSAR is thus not
. created.
III. No. Emergency Closed Cooling System required flow rate is not described in the Technical Specifications. e
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'Attachmint 3 i PY-CEI/NRR-0979 L Page.49 of 278 SE No.f 88-079' Source Documents , FSAR CR 87-160=
Description of Change Revise FSARLSectionL7.2.2.3 and Table-7.2-2 to exchange the main steam line isolation and the turbine stop valve limit switch .setpoints for the analytical limits. Summary I. No. The limit switch settings should'be expressed as analytical limits vs..setpoints. 'The plant instruments will be set to the setpoints which pre. based on the analytical limits. The proposed changes are considered administrative as the actual settings for MSIV and Turbine Stop Valve Limit Switches'and APRM upscale alarm (Not in "Run", mode) setpoints will not change. Use of analytical limits for the limit switches in lieu of setpoints is consistent with other FSAR description formats and is preferable from an administrative standpoint. since setpoint values are 'more subject to change 1 ll l (conservative' direction). Revision of the APRM upscale alarm value l' is appropriate since it is consistent with the table heading " Trip .l l Point Range". No FSAR Chapter.7 or 15 analysis is impacte.d by the ! L subject changes. It is concluded that the probability of occurrence / consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR is not impacted. 'i II. No. This change only changes the FSAR to specify the analytical limit vs. the setpoint. No change to the' plant is required. The scope'of the proposed. changes is limited to the items described in I above. I No other systems or equipment are impacted by the subject changes. i A different type of accident or malfunction than previously evaluated in the FSAR is thus not created. III. No. These limits are not discussed in the Technical Specifications and i this change does not affect the setpoints used in the plant. I l
i Attachm:nt 3 j.,
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PY-CEI/NRR-0979 L Page 50 of 278 SE No. :: 88-080 Source Documents .FSAR CR 87-161' Description of Change i Update FSAR Sections 7.3.1.1.2 to clarify that RCIC isolation also occurs from high main steam line tunnel ambient and delta temperature. Summary-I. No. This change is consistent with the FSAR Section-7.4' description on RCIC and FSAR Chapter 6 description.- There.is no impact to FSAR Chapter 15 analysis. Therefore, this change does not increase the probability of occurrence / consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR. II. No. The. plant has not changed. This change is a clarification of actual field conditions. III. No. The margin of safety as defined in the bases for any Technical Specification.is not'affected by this. change. l SE No.: 88-081 Source Document: FSAR CR 87-162 i Description of Change j i Update FSAR Section 7.3.1.1.2 to add the RHR isolation valves to the main steam line drain valves that.do not operate in pairs.
' Summary j
-I. No. The added "RHR Isolation Valve" description accurately reflects thel !
-trip logic reflected in the plant design and is considered more conservative'(1:2 vs. 1:2 twice) from a design standpoint. There is also no conflict with FSAR Chapter: 15 analysis or with the Technical Specifications. Therefore, the probability of occurrence /
consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR is not increased. , l II. No. No other systems or equipment are impacted. A different type of I accident or malfunction than previously described in the FSAR is not created. III. No. No Technical Specification bases or requirements are affected by this change. {
= _ - - _ _ _ _ _
Attachment 3 PY-CEI/NRR-0979.L Page 51 of 278
-SE No.: 88-082 Source Document: FSAR CR 87-164 Description of Change Update FSAR Sections 7.6.1.11.2 to delete reference to an SRV low-lov setpoint alarm that does not exist.
Summary I. No. The low-lov setpoint annunciator was deleted since low-lov setpoint initiation indicating lights on-H13-P601-19B provide sufficient low-lov setpoint indication to the Control Room operator. Deletion of this alarm does not increase the probability of occurrence or the consequences of an accident or malfunction of equipment previously evaluated in the FSAR. II. No. The deletion of the annunciator does not create a new disturbance that would impact fuel or reactor coolant pressure boundary, therefore, no new accident or malfunction is created. III. No. The low-lov setpoint annunciator is not described in Technical Specifications, therefore, the margin of safety is not reduced. SE No.: 88-083 Source Document: FSAR CR 87-165 Description of Change Revise FSAR Table 7.5-1 (Display Instrumentation for Safety-Related Systems) to reflect actual field conditions. Summary I. No. The indicator range change for ECC Loop Flow from 0-2600 to 0-2500 gpm still envelopes the post-accident rated flow of 1854 gpm. The indicator range change for ESV flow to the heat exchange from 0-8000 to 0-10000 gpm still envelopes the post-accident rated flow of 7300 gpm. Therefore, it is concluded that the probability of occurrence or consequence of an accident or malfunction of safety-related equipment previously evaluated in the FSAR is not increased. II. No. These indicator range changes do not create a new disturbance that vould impact fuel or reactor pressure boundary, therefore, a different type of accident / malfunction than previously evaluated in the FSAR is not created. III. No. These indicators are not described in Technical Specifications, therefore, the margin of safety is not reduced.
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' Page'52 of 278 SE No.: 88-084 .
Source Documents- . FSAR CR 87-166
-Description of Change .-
Revise FSAR'Section 7.7.1.8.b on the Process Computer System description to reflect actual field conditions. i i Summary; [
~
I. No., These, changes provide'an updated description of Perry's: Process.
. Computer System. This system as noted-in FSAR Section 7.7 does not'
. provide any functions that are essential for the safety of the plant. Also, no FSAR Chapter-15 analyses take. credit for the-function of the Process Computer System. It-is therefore, concluded that these' changes do not increase the probability of occurrence / consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR.
II. No. There is no impact to other systems or equipment discussed in the FSAR. A different type of accident / malfunction than previously described in the FSAR is thus not created. III. No. .The Process" Computer' System is not addressed in the Technical Specifications and therefore no margins of safety are affected by this change.- l
- SE No.:- 88-085 Source Documents .FSAR CR 87-167 Description of Change Revise FSAR Figure,7.4.2 (Standby Liquid Control System (SLC)' Functional Control Diagram) to delete references to position indication for test
. loop of SLCS valves,~and add pump and valve numbers.
Summary , I. No. Revision of the figure is consistent with other FSAR section descriptions on SLCS. FSAR Chapter 15 analysis is not impacted by this figure update. Therefore, the probability of occurrence or the consequences of an accident previously evaluated in the FSAR is not increased. II. No. There is not impact to other plant systems or equipment. A different type of accident / malfunction than previously described in the FSAR is not created. l III. No. This change.does not affect the bases of the Technical 1 l Specifications. i L l .
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, PY-CEI/NRR-0979 L: l Page 53 of 278
~SE No.: 88-086
' Source Document: L FSAR CR 88-014- j l
- Description of Change ]
1
. Update FSAR Sections 7;3.1.1.1.1, 7.3.1.1.1.3 and 7.3.1.1.1.4.to q incorporate time delays into the starting logic for LPCS and HPCS motors j during a LOCALvith offsite power available. 1 1
.SummaryL I. No.' This change has no effect on'the overall operation of the systems or.
on the required response time of 37 seconds for LPCS and 27 seconds ; for HPCS. With the 15 second_LPCS' delay, this pump vill-be'up to- ! speed withinJ20 seconds, and with the 10 second HPCS delay this pump l
.will be up to; speed within 15 seconds. These are vill within the 37 j and 27 second requirements. Since all criteria are still met for h these systems, no new types of accidents or malfunctions are created and the probability or consequences of any accident is not
. increased.
'II. No. See Item I above. j III. No. This change does not affect the response time of 37 seconds for LPCS' and 27 seconds for HPCS as stated in Technical Specifications Table 3.3.3-3.
i SE No.:- 88-087 j
. Source Document FSAR CR 88-016 Description of Change -
a Correct FSAR Section 7.3.1.1.10.d.3 (Pump Room Cooling System - l Instrumentation and controls) to reflect as-built condition of the j Emergency Pump Area Cooling System (M28), and to document that the .l Emergency Closed Cooling System (P42) pump initiates the M28 system. Summary I. No. The correct application of the M28 and P42 instrumentation clarifies the FSAR description. Any post-accident analyses are not affected, r and therefore, the probability of occurrence of an accident is not increased, i II. No. By correcting the FSAR description to reflect as-built conditions of l the plant does not create any new accident or malfunction. ! l III. No. The Technical Specification bases are not affected by these l corrections to the FSAR. l j
Attachmsnt 3 PY-CEI/NRR-0979 L-
~Fage 54 of 278 j,
'SE No.: 88-088 Source Document: FSAR CR 88-017 Description of Change Update FSAR: Sect' ions 7.3 to clarify 1that,the Dryvell Cooling, Containment Cooling, Containment and Dryvell Purge and Vent Systems are not
' classified as safety-related, nor ESF. References to these systems are deleted, because Section 7.3 discusses only ESF systems.
-Summary I. No. This change clarifies FSAR Section 7.3 to delete references to the systems discussed above. The systems are discussed as nonsafety.in Section 7.3 and Chapter 9. Consequently, no change to the system-design or design evaluation is required.
~II. No. Because this change clarifies Section 7.3, it has no effect on FSAR analysis and no possibility for an accident or malfunction of a.
different type is created. No system or design requirements ~are changed. LIII. No. The Technical' Specifications bases are not affected by this change. SE No.: 88-089 Source' Document: FSAR CR 88-011 Description of Change i Revise FSAR Sections 10.4.3 (Turbine Gland Sealing System) to correct i steam seal pressure so that it will agree with Figure 10.1-10. j i Summary I. No. Since-Steam Seal is a nonsafety system and since this change is only a clarification to the system description, there is no probability of occurrence of an accident or malfunction of equipment important to safety. II. No. See Item I above. III. No. The Technical Specifications are not affected by this change. l' 1 ____.m______-___
1 g Attachm:nt 3' l PY-CEI/NRR-0979 L Page 55 of 278 j SE No.: '88-090 Source Document: FSAR CR 88-012 l Description of Change Update FSAR Section 10.4.5.3 to correct the operating sequence for vinter-startup/vinter operation of-the cooling tower, also to correct Section 10.4.5.2. for the location of the hypochlorite injection.
-Summary I. No. Correcting the sequence for vinter startup/ operation of the cooling tower or correcting the location of hypochlorite injection into the Circulating Vater System have no impact on any safety-related components.
II. No. Same as Item I above. III. No. The Circulating Vater System is nonsafety-related and is not addressed in the Technical Specifications.
-SE No.: 88-091 1 Source Document: FSAR CR 88-013 ,
I Description of Change i I' Update FSAR Section 10.4.1.6.d and Table 15.2-11 to change setpoints for condenser vacuum alarm, turbine trip, and MSIV isolation to be consistent with design documents, the Technical Specifications and plant instrumentation. Summary I. No. Loss of condenser vacuum is analyzed in Section 15.2.5. Turbine trip and MSIV isolation setpoints are in the range stated in Table 15.2.11. This setpoint change does not increase the probability of occurrence of an accident or malfunction of equipment important to safety. II. No. See Item I above. III. No. This change makes the setpoint for MSIV isolation in the FSAR consistent with Technical Specification 3.2 and Bases 3/4.3.2. l
Attechmtnt 3- x l PY-CEI/NRR-0979 L Page 56 of 278 SE No.: 88-092 Source Document: FSAR CR 88-062 Description of Change l Various minor editorial changes to FSAR Chapter 10'as a result of reviev ! to update the FSAR per 10 CFR 50.71. ! l Summary i I. No. No accident or malfunction to existing equipment is involved. The ; changes are editorial in nature, i.e., clarification of existing ! text, consolidation / deletion of repetitive material to enhance readability. q II. No. No new accident or malfunction is involved. Changes are editorial. III. No. No Technical Specification margin or safety is involved because the j changes are editorial. i SE No.: 88-093 Source Document: FSAR CR 87-168 i Description of Change Delete from FSAR Figures 7.6-8 and 7.6-10 (Redundant Reactivity Control - System (RRCS)) reference to RVCU isolation from RRCS signal. Summary I. No. The changes to FSAR Figure 7.6-8 vere initiated under General l Electric's Design Control Program which addresses impact to FSAR analysis. Revision of the figure is consistent with FSAR I Sections 7.3 and 7.4, the Technical Specifications (Table 3.3.2-1), ; and the current field configuration. In addition, since the RWCU
-isolation function on SLCS initiation is retained, there is no ,
impact to FSAR Chapter 15 analysis. It is therefore, concluded that i the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previous evaluated in the FSAR is not increased. II. No. There is no impact to other plant systems or equipment. A different type of accident / malfunction than previously described in the FSAR is not created. j j III. No. The Technical Specifications (Table 3.3.2-1) are consistent with these changes. Therefore, the margin of safety defined in the ' Technical Specifications is not reduced. l l __ - - - - - - - 3
Attachm nt 31 b PY-CEI/NRR-0979 L
. Page,57 of 278-SE No.: 88-094 Source Documents FSAR CR 88-071 v.
Description of Change-Update FSAR Section 7.3, Figure 7.3-9 (Suppression Pool Makeup System Logic Diagram) to clarify;the diagram and correct valve designations.
' Summary-
.i I. No. -Updating-the logic diagram to agree with the plant design drawings does not increase the probability of an' accident.
II. No. The plant is not changing so a new accident or malfunction is not created. III. No. System design does not change, so the margins of safety stay the l same. SE No.: 88-097 i I Source Documents MFI 1-88-052 Description of Change Add' stainless steel tee flush connections to the inlet / outlet sample a lines of the Radvaste to ESV Radiation Monitor OD17-J0007. Summary I. No. Flush connections do not affect the operation of the Radiation Monitor-and does not increase the-occurrence or the consequences of. an accident. II. No. The Radiation Monitor is not discussed in FSAR Chapter 15 accident analysis. Flush connection do not increase the possibility of an accident. III. No. The flush connections do not alter the ability to monitor and control the retest of liquid radioactive material. l 1 1 _ _ - - _ - - - - - - - - - - - - - - - )
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'Attechmant 31 PY-CEI/NRR-0979 L' H3 Page 58 of 278 ,
b l SE No.: .88-100 .
.. Source Document DCN 2109 l -. 4 1
Description-of Change 'i Correct' discrepancies of MPL's between system P&ID and the' elementary l l ' diagram on~the Nuclear Boiler System (B21). i l l
, Sum'mtry
\
I . No .- This change-does not increase the probability of an accident or malfunction'of any equipment. This'. item is associated with MPL tag. _ j number changes only on the B21 System P&ID. l I'
'II. No. .This-is a drawing change only and vill not create any possibility for an accident or equipment malfunction. q
+
. l III. No. .This' drawing ~ change is not part of any Technical Specification. l SE NO.: 88-101 Source Document: DCN 2110 Description of Change Editorial drawing change which assigns MPL OM21-F0628 to fire ~!
damper FDCC750 on the Control Room HVAC (M25) system P&ID 912-610 and-the
. Motor Control Center Switchgear and Miscellaneous Area and Battery Room
. Exhaust.HVAC (H23/24) systems P&ID 912-609.
i
' Summary l
I. No. Adding an MPL number to a P&ID drawing does not increase'the I probability of occurrence or the consequences of an accident or-
' malfunction of equipment important to safety previously evaluated in the FSAR. j II.:No. Addition of an MPL number to the P&ID's does not create the f possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR.
III. No. Adding an MPL number does not reduce the margin of safety as defined in the bases for the Technical Specifications. There is no change to the function or operation of either the M23/24 or M25/26 systems.
r AttschmInt 3' PY-CEI/NRR-0979 L I Page 59 of 278 j 1 SE No.: 88-102
. Source Document: DCP 86-09290, Rev. O Description of Change 'l Inject sealant and install sealant retaining ring on Feedwater (N27) ]!
system first Maintenance Isolation Valve IN27-F0560A to eliminate bonnet leakage. This evaluation analyzes the effect on the piping analysis of the additional weight. Summary I. No. There is no increase in the probability of an accident or ; malfunction evaluated in the FSAR because the design requirements ! committed to in Chapter 3 of the FSAR are met. The addition-of this weight on the valve vill not affect the consequences of an accident l or malfunction.- ' II. No. There is no effect on the systems which could result in a different E type of' accident, that is the valve weight is not an input to any ; accident or malfunction evaluated; E III.'No. There is not a change to the design margins which are the basis of the Technical Specifications. There is no change to the calculated stress levels. l I d ] 1
Attachmsnt 3
'PY-CEI/NRR-0979 L Page 60 of 278 q SE No.: '88-103' 1
,.. Source Documents .FSAR CR 87-115 Description of Change-l Evaluation of an FSAR change request which revises notes.3 and 10 l regarding the performance of Type C leak rate tests and the test j methodology for various valves as shown in Table 6.2-40,-Primary Reactor' j Containment Penetration and Containment-Isolation Valve Leakage Rate Test J s
List. Summary I . lio . A test pressure of 15 psi or less does not. provide a' sufficient force to alterLthe seating characteristics of the valve. Thus, the l test pressure applied to either the inlet or the outlet will provide , equivalent results.
~
3 Section XI of ASME Boiler and Pressure Vessel-q Code " Rules for Inservice Inspection of Nuclear Power Plant Components" paragraph IVV-3423(d), specifically permits differential i pressure' tests in this manner, for valves (except check valves) if l the function differential pressure is 15 psi or less. ThisLehange j
\ meets the requirements of 10 CFR 50 Appendix J for Type C< tests i since, as stated above, equivalent results vill be obtained. 1 i
II. No. Based on the evaluation for Item I above, an acceptable LLRT in the direction opposite normal flow, where the function differential pressure is 15 psi or less will repeat itself when the flow is in , the normal direction. Therefore, no new malfunction is created. ! I III. No. Based on the evaluation for Item I above, operability of the tested valve is not affected. Leakage criteria as stated in the bases of the Technical Specifications are not changed. ; l l 1 l i i l 4
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-Page 61 of 278 .
SE No: 88-104 'l Source Document: FSAR CR-88-038 Description of Change 1 Evaluation of an FSAR change-request to Section 8.2.2.1.e to consider the failure of breaker S-622-PY-TIE prior to Unit 2 operation.
)
Summary I. No. Originally breaker S-622-PY-TIE was not required prior to Unit 2 i operation. Its installation prior to Unit 2 operation provides more fault isolation capability and improves the overall reliability of a the offsite power system. Improved power system reliability vill not increase the probability of occurrence or the consequences of accidents. This breaker addition will improve the overall response to power system malfunctions (faults). 1 II. No. See. Item I above. III. No. This change will have no effect on the Technical Specification ' requirement (3.8.1.1.a) for two independent circuits between the l offsite transmission network and the Onsite Class 1E distribution j system. ; i I I l ( t E_______________ _ 1
1 q Attschmint 3 'l PY-CEI/NRR-0979 L Page 62 of1278 J SE No.: 88-105 Source Documents. FSAR CR 88-039 Description of Change Evaluation of a FSAR change request to Section 8.3.1.1.2.8 to correctly. ] indicate that the High Pressure Core Spray (HPCS-E22) pump does not have " an undervoltage trip.
- Summary I. No. The system design of not having an undervoltage trip of the H1'gh Pressure Core Spray (HPCS) Pump improves the overall reliability of the system and remove a potential malfunction. Should~the HPCS Pump be running and a Loss of Power to Bus EH13 occur the. bus will be cleared from the offsite source and re-powered by the HPCS diesel
- generator. With the undervoltage trip the pump breaker would'also trip and automatically close on voltage restoration by the diesel generator. This. extra trip and close is unnecessary since this load is not sequenced on to the diesel generator but is a time zero load.
The extra trip and re-close present an opportunity for this pump to not be re-energized and should be avoided. .This change does not increase the probability of occurrence or consequences of an accident or create the possibility of a new type of accident. II. No.- See Item I above. III. No. Technical. Specifications do not discuss undervoltage trips of individual loads. Table 3.3.3-1 Item D discusses loss of power to the entire bus. l
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Attschmznt 3 PY-CEI/NRR-0979 L j Page 63 of 278 :! 1 SE No.: 88-106 Source Document: FSAR CR 88-040-Description of Change Evaluate a clarification to FSAR Section 8.3.1.1.2.9 to indicate'that more than one division's viring may exist within a Motor Control
. Center (HCC), switchgear, or a unit substation-cubicle.
Summary ; I. No. There vill be no detrimental effect on safety because where more' t
'than one division of non-safety viring with divisional viring-exists, separation is still accomplished in accordance with~our _;
commitments to Regulatory Guide 1.75. This must be occasionally
~ '
done for nonsafety interfaces to safety systems or multi-divisional ~ signals such as the LOOP signal. II. No. See Item I above. 4 III. No.- Electrical separation is not covered in the Technical Specifications. SE-No.: ' 88-107 1 Source Document: FSAR CR 88-042 Description of Change Evaluate a change to FSAR Section 8.3.1.1.2.11.a.5 which describes i additional protection for the Class 1E 4.16 kv feeder breakers. Summary I. No. The additional protection described in this section improves the overall reliability of the Class 1E power system. Feeders with smaller size current transformers (CT's) may experience CT i saturation with~ severe faults, which may impair proper fault ' sensing. Additional protection provided by 400/5 CT's and relays vill assure the fault is sensed and the feeder breaker tripped if l this occurs. The addition of.these relays vill not increase the probabilities or consequences of any accidents. II. No. This change does not introduce new malfunctions, but eliminates one potential malfunction and improves the overall reliability of the Class 1E power system. III. No. Class 1E feeder breaker protection is not discussed in the Technical Specifications. l l I I - _-__- -.
.t Attschmant 3-PY-CEI/NRR-0979 L Page 64 of 278 l SE No.: 88-109 Source Documenti FSAR CR 87-152 Description of Change j i
Evaluation of an FSAR change request to Section 6.4.2.4 concerning the- i effect of changing the variable flow rate to a. constant, higher-(more l conservative) flow rate in the smoke clearing mode for the Control Room ] and Control Room Emergency Recirculation.(M25/26) HVAC systems. q
. Summary I. No. Changing the variable flow rate for the Control Room Ventilation system in the smoke clearing mode to a constant flow rate does not l reduce the safety function of the system. As presently written the purge flow rate is variable up to 100%'of system flow (30,000 CFM).
Increasing the purge flow to a constant 100% system flow is more conservative. Thus, there is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR. II. No. Changing the flow rate of the M25/26 system from variable to constant in the smoke clearing mode does not reduce the safety I function of the Control Room Ventilation system nor of the plant. It does not increase the chances of an accident of a different type than previously analyzed, j III. No. This change does not alter the operation of the M25/26 system as- ) i described in the Technical Specifications. There is no change to the operation of the plant as described in the Technical Specifications. 'Therefore, margins of safety are not reduced. l I
d T c{
> - I,. Attachm nt 3 7y 4 _
PY-CEI/NRR-0979 L' ) Page 65 of 278 M' i 88-111; SE No.:' ' Source Document: ' FSAR CR 87-154 1 Description.of Change-Evaluation of'an FSAR change' request to Section 6.5.3.2.2 which updates the design description based on test data for'the-Annulus Exhaust Gas-
. Treatment (AEGTS-M15) system.
Summary. ,
' I . . No . ' -The FSAR change request does not involve a change to the-operation or function of the AEGTS System. Its contents bring the FSAR Section 6.5.3.2.2 writeup in agreement with approved design-documents to more accurately reflect the as-built configuration of.
the plant'. Increasing the leakage into the Annulus from 400 CFM to'550 CFM i
'during normal-operation and from 700 CFM to 850 CFM during an accident.will not increase the probability of occurrence or the~
consequences of an accident or malfunction.of-equipment.Important to. safety:previously evaluated in the FSAR. Each AEGTS Train has the capability of handling up to 2000 CFM leakage in the Annulus
~
(4000 CFM with both trains operating) and still maintain the required:-0.40 inch water gauge (WG) differential pressure to the outside atmosphere.. The increase in leakage is still vell within the 2000 CFM capacity of each AEGTS Train and will have no effect on system operation. In addition to the above, more information is being added to the-FSAR to clarify how the AEGTS system senses'the annulus differential pressute. The design intent of the system is to maintain the j Annulus at -0.40 inch VG with respect to its surroundings. The . ! extra' detail to be added does not change the operation or function j of the AEGTS system and is required to more accurately describe how the differential pressure is measured. II.-No. This change request does not create the possibility for an accident l or malfunction of a different type than those previously evaluated ! in the FSAR. There are no components being added to the M15 system. i nor is its function being changed. ! III. No. The FSAR change request does not change the operation of the plant l or the M15 system as described in the Technical Specifications. l 1
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Attachmsnt.3 PY-CEI/NRR-0979 L Page 66 of 278
.SE No.:; 88-113 Source Document: FSAR CR 87-156-Description of Change Evaluation of an FSAR change request to Section 6.4.2.4 involving changes to Tables 6.5-1, 6.5-2 and 6.5-3; which are comparisons of the Control Room Emergency _ Recirculation (M26), Fuel Handling Area Charcoal Exhaust (M40), and Annulus Exhaust Gas Treatment (M15) systems with !
Regulatory Guide 1.52. The table changes add O&R responses concerning-the monitoring of pressure drops and flow rates for the M15, M26 and M40 engineered safety features (ESP) exhaust systems. i Summary i I. No. The change request incorporates DSER ETSB 6.5-2, 6.5-3, and 6.5-4 1 into the FSAR to better clarify our conformance to Regulatory Guide 1.52 position 2.g for the M15, M26, and M40 systems. This I clarification conforms with what is already described about these i systems in Section 7.3.1. The operation or functioning of these i systems as presently described in the FSAR is not altered. Pressure drops are locally monitored and administratively checked daily by plant operators and any unacceptable flow rates result in an alarm ! in the Control Room. Thus, there is no increase in the probability of occurrence or the consequences of an accident or malfunction important to safety previously evaluated in the FSAR. l II. No. There are no components being added or changed in the ESF exhaust , systems nor is the operation of these systems being changed. The changes to Tables 6.5-1, 6.5-2, and 6.5-3 agree with Section 7.3.1. Therefore, there is no increase in the possibility of an accident of a different type than previously analyzed. III. No. There is no change to the operation or function of the ESF exhaust systems as described in the Technical Specifications. There is no change to the plant operation as described in the Technical Specifications.
Attatchmrnt 3 PY-CEI/NRR-0979 L Page 67 of 278 SE No.: 88-114 4 Source Document: FSAR CR 87-174 Description of Change i Evaluation of an FSAR change request to Section 9.5.4.4 to update the t diesel fuel oil specifications table to the requirements of ASTM Standard Specification for Diesel Fuel Oils D-975-77 and ANSI Fuel Oil Systems for , Standby Diesel-Generators N195-1976. -l Summary I No.. The change reflects the actual required analyses and limits as described in Technical Specification 4.8.1.1.2.d for diesel generator fuel oil. II. No. Operation under the Technical Specification limits will not create a different type of accident or malfunction. III. No. Diesel generated power is required to supply safety-related , equipment with electricity to achieve safe shutdown and mitigate ! accidents. Operation with fuel oil in the required bands as defined by the Technical Specifications will not reduce the margin of-safety. !
)
SE No.: 88-115 Source Document: FSAR CR 88-024 i l Description of Change Evaluation of an FSAR change request which updates Section 9.5.4 to . reflect the as-built design.- The description of the volume of the fuel 2 oil storage tanks for the Division 1 and 2 standby diesel-generators is being changed to.also address additional capacity beyond operation of the i associated diesel-generator for seven days. This additional capacity provides for diesel-generator operability testing. The description of the location of the Diesel-Generator Fuel Oil Transfer System eductor inlets relative to the location of the fuel oil storage tank fill pipe is to be changed from an exact dimensional distance to a description of relative position within the storage tank. This description is accurate for both eductors within the tank and is also applicable to the Division 3 Diesel-Generator Fuel Oil Storage and Transfer System. ; The description of the operation of the fuel oil transfer pumps is being changed to show that the primary pump is stopped at the day tank LO-LO level setpoint and then the secondary pump is automatically started. The secondary pump's stop setpoint remains at the day tank LO-LO-LO level. j i
Attschmsnt 3-PY-CEI/NRR-0979 L Page 68 of 278 SE No.: 88-115 (Continued) i Description of Change (Continued) i l The description of the operation of the motor driven booster pump is being modified to state that the booster pump will automatically start ! upon engine driven pump failure, only if a diesel-generator emergency i start signal is present. Upon stich an auto start, it is normally stopped using manual controls on the local control panel.
.The description of the standby diesel-generator fuel oil bypass function l is expanded to describe both the fuel oil bypass header and its i connecting piping to the day tank in addition to the Fuel Oil Drip Vaste Return System already described. l 0
Summary
-I. No. The probability of occurrence of an accident previously evaluated in !j the FSAR is not affected by the changes described above.
The additional storage volume of the fuel oil storage tank is the result of a calculation which shows the amount of storage volume l vhich is' unusable, the amount required to support the associated i emergency diesel-generator for seven days of continuous operation at , designed emergency loads, and the remaining volume of the total ! 90,000 gallon capacity. It is this remaining volume which is used for operability testing. This additional volume has no direct effect on the reliability of the Emergency Diesel-Generator Fuel Oil ! Storage and Transfer System, as it is the result of no physical change to the system. The location of the Diesel-Generator Fuel Oil Storage Tank. System eductors with respect to the fuel oil storage tank fill pipe remains unchanged. Hence, the Diesel-Generator Fuel Oil Storage and Transfer System's response during any operational or accident conditions vould be unaffected, also, t The modification to the day tank level setpoints which control the j fuel oil transfer pumps was implemented in accordance with the ! standard site procedures and manufacturer's recommendations. These setpoint changes' effect on equipment reliability is therefore identical to the original design. , The change to the control of the motor driven booster pump results from no physical change to any control circuitry. This change is merely a clarification of the existing qualified design and has no effect on the motor driven booster pumps' operation or reliability. The change to the description of the Fuel Oil Bypass System is an expanded description of the original design and has no effect on equipment operability or reliability. This Fuel Oil Bypass System } design was part of the originally supplied diesel-generator assembly i
.(- l s 1 Attschmtnt 3 i PY-CEI/NRR-0979 L Page 69 of 278 SE No.: 88-115 (Continued)
Summary (Continued) from the manufacturer and has-been reviewed and approved by the'NRC via the Delaval' Diesel-Generators Owners Group Design Review and Quality Revalidation' Report. Hence, none of the above changes affect equipment reliability and the probability of occurrence of a malfunction of equipment evaluated previously is unchanged. II. No. As demonstrated in Item I above, the changes maintain the reliability, qualifications, redundancy and the ability for the equipment / system to perform its original designed function. .Since no new design type is introduced by these changes, and all of the . original design requirements are maintained, no potential for a il malfunction of a different type than any evaluated previously is .{ introduced by these changes. j III. No. The margin of safety as defined in the bases of Technical Specification Section 3/4-8 refers to the reliability of the onsite power supply. As demonstrated above, this reliability is not compromised by the changes herein and hence the margin of safety is not reduced. SE No.: 88-116 !. Source Document: FSAR CR 88-025 Description of Change The scope of this FSAR change request can be categorized into the following items: The description of the flow loop of the Standby Diesel-Generator Jacket Vater Cooling System is clarified to more accurately depict the system components and their functions. No physical changes are introduced by this description as it is based on the system diagram l vhich appears in FSAR Figure 9.5-9. The description of the use of ethylene glycol as a component of the engine jacket water chemistry is being modified to reflect its i optional usage when conditions prescribe rather than a continuous application. f The description of the jacket water keep-warm temperature is being E changed from an approximate median temperature to the minimum j keep-warm temperature to provide acceptance criteria for acceptable jacket water keep-warm performance. 1
@y >
o AttachmInt 3 ' q, PY-CEI/NRR-0979'L Page 70 of 278 SE No.s. _88-ll6l(Continued) Summary I.;No. The changes'to the' description of the components in.the Engine' Jacket Water System flow loop and descriptions of their_ function 1 are only_a~ clarification of the'orginial descriptions and have n'o-effect on equipment operability, or reliability. This Jacket Water System design has been previously rev.ieved and approved by the NRC ]L
-via'FSAR Figure 9.5-9 and "The Delaval Diesel-Generator'Ovners Group l Design Review and Quality Revalidation Report."
The change to the diesel-generator jacket water chemistry to use- ' .i ethylene glycor on an as-needed basis rather than a continuous i application has no negative effect on the reliability of the standby ; diesel-generators or the Diesel-Generator Jacket-Water System j components. The engine manufacturer recommends ethylene glycol to q be_ addod to the' jacket water only in the event of severei veather i conditions. k The original' diesel-generator building design predicted room
' temperature _to approach 40 degrees F. Operating experience shows-that even during severe weather, diesel-generator _ room cooling is ;
required to maintain average room temperature belov 80 degrees F ! because;of the engine keep-warm system. l
" The change in the description of the Jacket Water Keep-Varm System to reflect the minimum keep-warm temperature is in accordance with-the manufacturer's recommendations and has no physical effect on the diesel-generator or the Diesel-Generator Jacket Water Cooling ;
System. The minimum keep-watm temperature establishes minimum : Jacket Vater Keep-Varm System performance. Since manufacturer's {' recommendations-are being observed with-this change, equipment reliability is not affected. 1 As demonstrated above, none of the subject changes affect equipment ! or system reliability. Hence the probability of occurrence.of a
~
malfunction of-equipment as evaluated previously is unaffected by , the subject changes. j In the event of an accident, the plant's response to mitigate its ; consequences vould be unchanged and thus the consequences of the ; accident would not be affected by the changes discussed here. II. No. The subject changes maintain the equipment and system reliability, qualifications, redundancy, and function of the original design. 1 Since no new type of design is introduced by these changes and all of the original design requirements are maintained, no potential'for a malfunction of a different type than any evaluated previously is introduced by the subject changes. L
Attechmant 3'
, PY-CEI/NRR-0979 L d Page 71 of 278' 1
SE No.: 88-116 (Continued)
)
Summary (Continued)- )
. l III. No. The margin'of safety as defined in the bases of Technical 1 Specification Section 3/4-8 refers to the reliability oflthe onsite 1 power.-supply. This reliability is not compromised by the changes i herein and hence the margin of safety is not reduced. ;
SE No.: 88-117 ; Source Document: FSAR CR 88-026 l Description of Change '
-l
.The scope of this FSAR change request can be categorized into the
-following' items: }
The description of the Standby Diesel-Generator Starting Air System ! minimum operating pressure'is being changed from a numeric value to-the term " minimum operating pressure" and the value of the maximum operating pressure is being-deleted. This is.being done.to : precisely describe the system conditions without specifying a .
- numeric value which'is subject to change based on operating needs.
This change has no effect on system design parameters and its implementation has no physical effect on the Starting Air System'or ; its components. ;. The description of the starting air devpoint'is being revised from the mesimum capability of the air' dryer (lovest possible devpoint),- l to the-l maximum allovable devpoint based on the Standard Review Plan I Secticji 9.5.6. This change establishes acceptance criteria for air ~1 dryer performance. j s The description of the advantages of the desiccant type of air dryer. ; compared to'a refrigeration type of air dryer is being deleted as it is not required per the Standard Review Plan Section 9.5.6. 1 The description of the air dryer active components is being modified to include both active purge valves, the safety relief valve, and k the drain trap. ! l The discussion of the component function sequence during an engine start is being changed to clarify that starting air is admitted to the engine's cylinders vice the power cylinders. The description of the location of components manufactured to D.E.M.A. standards is being changed to clarify that these components are installed on the diesel engine and not on the auxiliary skid or generator.
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I dA - .Attschitnt 3-
.PY-CEI/NRR-0979 L Page 72 of 278 j 1
- SE No.t- 88-117 (Continued) .
li Description of Change (Continued)_ The description of the cranking capacity of the Starting Air System
- is being changed to specify the cranking cycle's duration as sufficient to successfully start-the' diesel-generator,.rather than three seconds. The capacity of the Air Start System is based upon-engine start-attempts, not upon three second cranking cycles.-
1
~- Summary I I. No. The changes to the description of.the-starting air operating pressures maintain the original design. requirements of the Starting.
Air System. This change involves nominal system operating -l conditions and has no physical effect on the system vith respect to ! equipment reliability or the ability of the system to meet it's design performance requirements.. All original design parameters , applicable to this system remain intact. The change to the description of the starting air devpoint reflects ;
- the' system design requirements as stated in the Standard Review Plan l Section 9.5.6. A change from nominal operating devpoint to the !'
design requirement has no effect on equipment reliability, as the design' requirements govern acceptable equipment performance. The change to delete discussion of the advantages of the' desiccant i type of air dryer compared to the refrigeration type of air dryer has no effect on the physical design and is not required to support : the Starting Air System safety analysis per the requirements of the
~
Standard Review Plan Section 9.5.6. The change.to the description of the starting air dryer, further -i delineating the active components has no effect on the reliability of the Standby' Diesel-Generator Starting Air System. The change to the description of the standby diesel-generator component function sequence during an engine start is merely a 1 , clarification. The Air Start System function to admit air directly ; to the engine's cylinders was part of the originally qualified design supplied by the manufacturer. l The change to the description of the location of the Starting Air System components manufactured to D.E.M.A. standards is a clarification of the originally qualified design supplied from the engine manufacturer. This Starting Air System design has been previously reviewed and approved by the NRC via FSAR Figure 9.5-10 and "The Delaval Diesel-Generator Owners Group Design Review and l Quality Revalidation Report." ' ' ' ' - - - ' 1
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- 4. PY-CEI/NRR-0979 L Page 73-of 278 ,
' SE No.:. 88-117-(Continued)- j i
Summary (Continued) i i II. No. The subject changes. maintain the equipment and system reliability, -l qualifications, redundancy, and function of the original' design. ]
- Since no new type of design is introduced by these changes andlall' {
of the original design requirements are maintained, no potential for j a malfunction of a different type than any evaluated.previously 10 ' introduced by the subject changes. III. No. The margin of safety as defined in the bases of Technical- -l Specification Section 3/4-8 refers to the reliability of the onsite 'l power. supply. This reliability is not compromised by the~ changes herein and hence the margin of safety is not reduced. SE No.: 88-118 i Source Document: FSAR CR 88-064 Description of Change This FSAR change request revises the description of the flov loop of the Standby Diesel-Generator Lube Oil System'to more. accurately describe the : system's components and functions, including: '
- l. The primary lube oil flow path through the lube oil heat exchanger, ] '
the duplex filter'and lube oil strainers, and the engine including the bearings and back to the' sump.
- 2. Maintenance of constant lube oil pressure on the main lube oil header with pressure regulating valves, e
- 3. The lube oil flow path through the lube oil heat exchanger shell and maintenance of lube oil temperature by regulation of the Jacket I Vater System temperature.
- 4. Reference to Table 9.5-8 for the capacity of the lube oil heat exchanger.
- 5. The integral strainer in the lube oil sump tank.
- 6. The preheating lube oil flow path through an electric heater and then through a filter and a strainer, to the engine and bearings and back to the sump.
- 7. The clear marking of valves and entry points used during recharging of' lube oil to prevent entry of foreign materials.
i
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.k AttachmInt 3 .
j FY-CEI/NRR-0979 L' ! 4 Fage 74 of 278 ] L ! SE No.: 88-118 (Continued)
. Description of Change (Continued) i The. Turbo Charger Frelubrication System as' described in the DR/QR Report and as shown in FSAR Figure 9.5-11 is being'added to address system ;
function and operation to minimize turbo charger bearing wear. This. 6 system is designed and installed in accordance with manufacturers recommendations.
' Summary 1 I. No. The components in the Engine Lube Oil System flow loop are as I originally supplied from the manufacturer. The Lube 011 System i design has not been changed. .i These FSAR changes are a clarification of the original descriptions and have no effect on equipment operability, or. reliability.
The. change in the description of the lube oil flow path to that E describing' flow through the heat exchanger, filter, strainers and throughout the engine including the bearings and back to the sump is consistent with the system as depicted on FSAR Figure 9.5-11. Lube oil flov through'the lube oil strainers and throughout the engine does not represent a physical change to the diesel-generator as-installed. , 1 The change in the description of how constant lube oil pressure is l maintained on the main lube' oil header with pressure regulating valves is consistent with the system as depicted on FSAR y Figure 9.5-11. The engine main lube oil header provides oil l throughout the engine as well as to the engine bearings and does not- l represent any physical change to'the diesel-generator as installed. j i The change in the description of how regulation of Jacket Water System temperature maintains Lube 011 System temperature is j consistent with FSAR Figures 9.5-11 and 9.5-9 as well as the i' diesel-generator vendor manuals. Jacket water temperatures are L, controlled by a thermostatic control valve. This does not represent , a physical change to the diesel-generator as installed. ! The revision to the text deleting the description of the capacity of the lube oil heat exchanger and-referencing Table 9.5-8 has no effect on the capacity of the heat exchanger. Elimination of redundant technical information vill prevent future FSAR reference / revision inconsistencies. The change in the description of the lube oil sump tank to include the integral strainer is consistent with the system as depicted on l FSAR Figure 9.5-11 as well as in the related diesel-generator vendor l manuals. The addition of the integral strainer to the sump tank i description does not represent a physical change to the 1 diesel-generator as installed.
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=Page 75 of 278' "
SE No.'s 88-118 (Cont'inued) Summary'(Continued)' The change:in the description of the Lube'Oll~ Preheating System to ' incl 0de the keepvarm strainer downstream of the filter and to-
- clarify'the supply'of lube oil to the bearings and other portions of the. engine is consistent with FSAR Figure 9.5-11. Since the j strainer is a functioning component in.the Lube 011' Preheating i System and the11ube oil path already includes other portions of the
_ diesel-generator engine as well as the bearings, this'does not represnt.a physical change to the diesel-generator as. installed. . The change in the description of how valves and entry points used j during recharging of lube oil are clearly marked.rather than color .l coded' represents no significant impact on the intent of this section '
.of the FSAR. The utilization of clearly marked entry points is ';
considered to be superior to the color coding system previously described to' prevent entry.of foreign materials. The-addition of the Turbo Charger Prelubrication System is described and recommended in the DR/0R Report and already'shown in detail in i FSAR Figure 9.5-11. This system functions to minimize' turbo charger ; bearing wear incurred during engine starts by providing a constant : lube oil drip rate to the bearings. f None'of these changes adversely affect equipment or system reliability. Hence the probability of occurrence of a malfunction of equipment as evaluated previously is not increased by the subject i changes.- II. No. The subject changes maintain the equipment and system reliability, i qualifications, redundancy, and-function of the original design.
-Since all of the original design requirements are maintained, no potential for a malfunction of a different type than any evaluated previously is introduced by these changes..
III. No. The margin of safety as defined in the bases of Technical Specification Section 3/4-8 refers to the reliability of the onsite power supply. This reliability is not compromised by the changes herein and hence the margin of safety is not reduced.
Attachment 3 PY-CEI/NRR-0979 L Page 76 of 278 SE No.: 88-119 Source Document: FSAR CR 88-065 Description of Change The scope of this FSAR change request is as follows: The description of the design standards by which the Standby Diesel-Generator Combustion Air Intake and Exhaust System is designed, is being changed to include ASME Code, Section III, , Class 3. The evaluation of the potential for recirculation of engine combustion products into the air intakes is being changed to state ' that significant recirculation cannot occur. Recirculation of engine combustion products is minimized by features of the design, however, operating experience has shown that some minor recirculation nay occur. The description of the preventive maintenance for the intake air filters is being changed from "the filters vill be changed on a periodic basis" to "the filters vill be cleaned on a periodic basis", because the standby diesel-generator intske air filters are oil bath filters and not disposable paper filters. Summary B I. No. The addition of ASME Code, Section III, Class 3, to the list of design codes used for this system is a clarification of the original qualified design. FSAR Figure 9.5-12 details the critical piping of the Intake and Exhaust System as Safety Class 3. Section 3.2 of the FSAR specifies Safety Class 3 piping and components to meet or exceed the requirements of Quality Group C and the ASME Code, Section III, Class 3. Hence, this design code's applicability to parts of the Diesel-Generator Intake the Exhaust System has been previously reviewed and approved by the NRC. Since no change has been made to the physical design or design requirements of this system, the reliability of the original design is maintained. The change to the evaluation of the possibility of recirculation of engine combustion products is a clarification of the text. The fact that minor recirculation of combustion products has been observed during diesel-generator operation under certain severe weather conditions has no effect on the basis of the original FSAR evaluation. In order for diesel-generator performance to deteriorate, more than 13.2 percent of the exhaust gas would have to l be recirculated. Therefore, any recirculation less than 13.2 percent does not degrade diesel-generator performance and, as a result, does not interfere with the diesel-generator's ability to perform its safety function. Although the Diesel-Generator Combustion Air Intake and Exhaust System design does minimize the
m,. . i 1 Attachmsnt'3; 1 PY-CEI/NRR-0979 L u
-Page 77 of 278 ll P.
l
!SE No.: 88-119 (Continued). 1 i
Summary (Continued)' possibility of recirculation of combustion' exhaust products, some i insignificant recirculation has been observed. .However, diesel-generator performance has not.been observed to be affected. " 1 Since the Diesel-Generator Combustion Air Intake'and Exhaust' System-has been' verified to adequately. support diesel-generator preoperational andJoperability testing,; including severe weather conditions, it.can be concluded that the; design minimizes
. recirculation:to the extent that:it maintains the: system. design requirements. 'Hence,, minor' recirculation is not. considered, significant and does not affect diesel-generator reliability, j
-availability or operability.
The change to the description of the intake air filters with respect
~ to-cleaning the filter instead of replacing the filter elements has been previously' reviewed:and approved by the NRC as'part of the "Delavall Diesel-Generator 0wners Group Design' Review and Quality.
. Revalidation Report".- This' change has no effect on equipment
. design,.' reliability, or qualification.. The probability.of occurrence of a malfunction of equipment as evaluated previously..is- j unaffected by Lthe subject' changes. j II. No.. The subject changes maintain the eqiiipment and system rel'iability,:
qualifications, redundancy, function and: performance of the: original design. . Since no new type of design is flitroduced by, these changes ,. and all of the original design requirements are liaintained, no potential for a malfunction of a different. type than any evaluated prulously is introduced by. the subject changes. III. No.. The margin of safety as defined in the bases of Technical Specification Section 3/4-8 refers to the reliability of the onsite j power supply. This reliability is.not compromised by the changes herein and hence the margin of safety is not reduced. 3 I q l
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y . PY-CEI/NRR-0979 L- ; Page 78'of 278. 1 4,r ) SE NoJ 120 . j p
. Source Documents.
FSAR CR 88-067 ] ' Description of Change The scope of this~FSAR change request is as'follows: The description of the functioning of the Jacket Water Keepvarm System components is being changed to delete mention of the.
-temperature regulating valve, as it performs'no active function when the HPCS diesel engine is not operating. 'It is also being changed to remove any inferences that- the jacket water is force circulated during keepvarm conditions, as there is no jacket water keepvarm I pump..
1 The. description of the Jacket Water' System. standby temperature, the
, engine lov temperature alarm and the operating characteristics of the Jacket .
descrfbe th,eVater Keepvarm original system design and are beingdiscrepancies to eliminate clarified to.better due to
~ minor variances in operating temperatures.
The design codes for the HPCS Diesel Jacket Vater Cooling System l piping are being deleted from this section and referenced in
~
4 Table 3.2-1 to minimize duplication of information. Summary I. No. 'The change of the description of the Jacket Water Keepvarm System- ! with respect.to the function of the temperature regulating valve is a clarification only. The Jacket Vater'Keepvarm System normally l' operates at.about 110 degrees F. The temperature regulating valve is designed to regulate jacket water temperature during engine operation to 170 degrees F. Hence, the temperature regulating valve ! does not actuate under keepvarm conditions. This valve design was 1 part of the original qualified Jacket Vater System design. This change is editorial in nature and has no_effect on the equipment or system with respect to reliability, function, performance, or qualification. j The change to delete the description of the system temperature maintained by the jacket water heater removes a specific description of the minimum Jacket Vat r System temperature. Minimum jacket vator temperature is not a condition which is required to ensure HPCS diesel engine operability. There is no alarm which annunciated a lov temperature jacket water condition. Instead, engine availability is determined by lube oil temperature. In order to delete the minimum jacket water temperature, this change clarifies the description of the operation of the Jacket Water Keepvarm System, particularly with respect to its interaction with the Lube Oil Keepvarm System. This change has no effect on the Jacket Water l System design shown in FSAR Figure 9.5-16 which was previously
g Attachment 3. PY-CEI/NRR-0979 L Page 79 of 278 T SE No.: 88-120 (Continued).
' Summary.(Continued)
I
. reviewed'and approved by.the NRC. This change maintains the original ~ system design performance requirements. .Since.this change l
.makes no physical design changes and maintains the original design i performance requirements, this change has no^effect on system or component reliability, performance, function, or qualifications.
The design codes applicable to'the HPCS' Diesel-Generator Jacket
" Water System piping are described in the Safety Evaluation Report Supplement #1.(NUREG-0887) in Section 9.6.6. This discussion.is-being incorporated into Table 3.2-1 as part of this FSAR. update.
This clarification of design codes based on what is published in ; Perry's " Safety Evaluation Report" represents an editorial change which has no physical effect on the design. The design codes- , applicable to.the skid mounted components remain unchanged. .Thus, the reliability, function, performance, and qualification of the. original design is not.affected by this change. l , 1 None of'these changes affect equipment or system. reliability. Hence 'l the probability of occurrence of a malfunction of equipment as evaluated previously is unaffected by these changes. II. No. These changes maintain the equipment.and system reliability,
. qualifications, redundancy, and function of the original design.
Since no new design is. introduced by these changes and all of'the original design requirements are maintained, no potential for a malfunction of a different type than any evaluated.previously is introduced by these changes. { l III. No. The margin of safety as. defined in the bases of Technical !
. Specification Section 3/4-8 refers to the reliability of the onsite power supply. This reliability is not compromised by the changes herein and hence the margin of safety is not reduced.
)
i I I-
i 3 1 Attachmsnt 3 , PY-CEI/NRR-0979 L -1 Page 80 of 278 SE No.: ~88-121 Source Document: .FSAR.CR 88-068 j Description of Change This FSAR change request updates the Section 9.5.9.5 description of the flow loop of the HPCS Diesel-Generator Combustion Air Intake and Exhaust System'to more accurately describe the system's components and their ; functions as'follows:
- 1. ' Removing the reference to crankcase! vent lines for-those components
. classified as Safety Class 3, Seismic Category I or j nonsafety-related. I 2.--The air-intake filter as having an' integral silencer rather than inference to a separate silencer component.
'The evaluation describing the effects of various gases, mediums, etc. on the HPCS Diesel-Generator performance is being revised and clarified to more accurately and thoroughly describe these conditions as follows:
- 1. Recirculation of hot exhaust gases into the HPCS Diesel-Generator Combustion air intake vill occur but will not be significant.-
- 2. Reference to Section 9.5.8.3 for additional safety evaluation of the HPCS Diesel-Generator Combustion Air Intake and Exhaust System with respect to the effects of fire extinguishing mediums,, recirculation of diesel combustion products, or sudden release of stored gases.
onsite. Summary i I. No. Crankcase vent lines for the HPCS Diesel-Generator exist as an integral,' engine-mounted system designed per DEMA standards for I scavenging crankcase vapors, removing oil liquids, and recycling them'back into the Combustion Air System. Since Figure 9.5-12 does not detail engine integral conponents for this system, this minor i editorial revision to the description provides consistency with the l FSAR figure without physical change to the HPCS diesel-generator equipment as installed. The change to the description of the air intake filter to include the integral silencer provides consistency with the system as depicted on FSAR Figure 9.5-12 as well as related HPCS Diesel-Generator Vendor Manuals. The addition of the integral silencer to the air intake filter description does not represent a physical change to this Diesel-Generator system as installed. The change to the evaluation of the possibility of reN* lation of ! engine combustion products is a clarification to the .. The fact that minor recirculation of combustion products has been observed during diesel-generator operation under certain severe weather l .-__ -.- _-- _- - - _ _ _ _ _ _ _ _ _ - - _ . _ . _ _ _ . _ _ _ _ . _ _ _ _ - - _ . . . _ - _ - _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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'Page 81 of 278 1
u, 'SE No.'s 88-121 (Continued)' ! L . Summary (Continued) . I l conditions has no effect on the basis'of the original FSAR. evaluation. In order for diesel-generator' performance to deteriorate, more than-13.2 percent of the exhaust gas would haveLto 3 be recirculated.. Therefore, any recirculation.less.than 13.2: percent does not degrade diesel-generator performance and, as as j result, does not interfere with'the' diesel-generator's ability to -t V perform its. safety function. 'Although the HPCS Diesel-Generator Combustion Air. Intake'and Exhaust System design does: minimize the
-possibility;of recirculation of combustion exhaust products, some insignificant recirculation'has been observed. .However, diesel-generator-performance has not been observed to'be affected.
Since the HPCS' Diesel-Generator Combustion Air Intake and Exhaust System has been verified to adequately support diesel-generator preoperational.and' operability testing, including severe weather
- conditions,..It<can.be concluded that the design minimizes recirculation to the extent that it'maint'ains the' system design
. requirements. Hence, minor recirculation is not considered 'j significant and does'not affect diesel-generator reliability,' '
availability or operability. The addition of a reference to Section 9.5.8.3 for.further discussion 1of the HPCS Diesel-Generator Combustion Air Intake and
. Exhaust System with respect to the effects of: fire extinguishing
' mediums,. recirculation of diesel combustion products or sudden
~
release of stored gases onsite provides expanded safety H considerations made when evaluating all aspects of' system. .. Interaction and malfunctions that could impact operation of the HPCS ) Diesel-Generator. Cross reference is being added to reinforce the ' safety eveNation for the HPCS Diesel-Generator Combustion Air - Intake and L:haust System and does not represent any physical' change i to the system or associated systems in the FSAR.
~
i None of these changes affect equipment or system reliability for the
- . HPCS-Diesel-Generator Combustion Air Intake and Exhaust System.
Hence, the probability'of occurrence of a malfunction of equipment q as evaluated previously is unaffected 'by the subject changes. II. No. The subject changes maintain the equipment and system reliability, qualifications, redundancy, function and performance of the original design. Since no new design is introduced by these changes and all b of the original design requirements are maintained, no potential for a malfunction of a different type than any evaluated previously is l introduced by these changes. III. No. The margin of safety is defined in the bases of Technical ! Specification Section 3/4-8 refers to the reliability of the onsite power supply. This reliability is not compromised by the changes herein and hence the margin of safety is not reduced. l i l l
Attichmint.3-PY-CEI/NRR-0979,L
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-Page 82;of 278 .;
SE No.: 88-122 Source Documents. DCP 87-0141, Rev. O J
~
. Description of Change Modify the Reactor Core Isolation Cooling (RCIC-E51) system to allow a dual = vater supply, from either the suppression pool or the condensate storage tank to the RCIC vaterleg pump.
. Summary I. No. This design change adds-an alternate water supply,to'the RCIC
. .waterleg pump. This modification vill assure main pump. discharge piping is full of water to prevent vater hammer when the system is
~ lined up to the CST or the suppression pool. Check valve F011 is being relocated to.the CST suction piping to prevent water transfer from.the suppression pool to the~ CST when both F010 and.F031 are o
open. Original construction codes. vill be utilized in this modification.x Actual NPSH of the waterleg pump and main pump exceeds the NPSH i required, therefore' safety-related service is not reduced by this j modification. ,This proposed design change does not negatively .i impact-the capability of the RCIC system.to continue to meet its design bases'as defined'in Section 5.4.6 of the FSAR. , 1 ' II. No. The proposed modification would not create a new type of accident or malfunction. Adding a second water supply to the waterleg pump C003 has no effect on events or disturbances that are considered as potential initiating.causes of threats to the fuel and/or'the reactor coolant pressure boundary. III. No. The margins of safety as defined in 3/4.7.3 of the Technical Specifications are improved by this. proposed design change. The main pump discharge piping system vill remain full during both line ups_(CST or suppression pool). The waterleg pump becomes operable after. transfer of water from CST to suppression pool and L thus maintains RCIC injection piping in standby readiness. Water b hammer damage is eliminated by maintaining injection piping full at all times, including line ups from either CST or suppression pool. ! This modification will increase RCIC reliability as it vill eliminate the securing of the waterleg pump when lined up to the suppression pool. ! l l
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i SE No.:: 88-123 ! Source Document: DCP 87-0565, Rev. O. Description of Change' j Replace'the existing Reactor Core ~ Isolation Cooling (RCIC-E51) waterleg. pump Dresser valves 1E51-F060, F067, F505 and F506 vith Kerotest packed-globe valves.
' Summary I. No. Replacement of two' existing 1/2 inch and one existing 1 inch Dresser 1 Diaphragm Globe Valves with three-quarter inch " packed" Kerotest !
globe valves does not increase the. probability of malfunction of ! equipment. These new globe valves are more' reliable than the l existing Dresser valves when performing system testing and I filling / venting. 1 The consequences of an accident as stated in the FSAR (Chapter 15) are not increased by removing existing Dresser valves and replacing j them.vith a " packed" Kerotest valve. This design change is ! unrelated to Chapter 15 accidents such as "Feedvater Break Outside , containment".. The new Kerotest valve meets the design requirements (ASME III) as- i the' existing Dresser valves. ! i II No. This proposed change vill not create a new type of accident.or malfunction. The replacement valves are considered superior to the original ones. ! III. No.. The margins of safety as defined in Technical Specification 3/4.7.3, i are unchanged and unaffected by this proposed modification to the , RCIC vaterleg piping and pump vent / drain. This design change vill ' remove the troublesome Dresser valves and allow operators to vent and fill the RCIC System (reference SOI-E51) without affecting reliability or safety. l
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i t Attachm:nt 3 PY-CEI/NRR-0979 L Page 84 of 278 SE No.: 88i124 Source Document: DCP 87-0563, Rev. O Description of Change Replace'the existing High Pressure Core Spray (HPC-E22) waterleg pump i Dresser valves 1E22-F515, F516 and F034 with Kerotest packed globe valves. Summary t I. No. Replacement of two existing 1/2 inch and one existing 1 inch Dresser l Diaphragm Globe. Valves with three-quarter inch " packed" Kerotest globe valves does not increase the probability-of malfunction of i equipment. These new globo valves are more reliable than the i existing Dresser valves when performing system testing and ; filling / venting.
-l The consequences of an accident as stated in the FSAR (Chapter 15) )
are not increased by removing existing Dresser valves and replacing ' them with a " packed" Kerotest valve. This design change is unrelated to Chapter 15 accidents such as "Feedvater Break Outside Containment". l l The new Kerotest valve meets the design requirements (ASME III) as I the existing Dresser valves. l I II. No. This proposed change vill not create a new type of accident or malfunction. The replacement valves are considered superior to the original ones. 1 III. No. The margin of safety as defined in Technical Specifications 3/4.3.3, 3/4.5.1, 3/4.5.2, 3/4.7.3 are unchanged and unaffected by this proposed modification to the HPCS vaterleg piping and pump vent / drain. This design change.will renove the troublesome Dresser valves and allow operators to vent and fill the HPCS System ' (reference 50I-E22) without affecting reliability or safety. l L
Attachmant 3 PY-CEI/NRR-0979 L Page 85 of 278 SE No.: 88-125 Source Document: DCP 86-0977, Rev. 1 Description of Change Replace the existing voltage regulator cards for the Intermediate and ; Source Range Monitor (IRM/SRM-C51) channels (in accordance with '
-FDDR KL1-6625) in panels 1H13-P669 thru 1H13-P672 with upgraded regulator cards. These cards would initiate channel "IN0P" function upon loss of i negative 20V DC and/or regulated negative 15V DC. This modification is required to provide an SRM/IRM inoperability signal if the negative 20V DC side fuse clears and is not restored (reference INP0 SER 33-86).
Summary I. No. The proposed design modification revises SRH/IRH channel "INOP" trip logic to initiate an "IN0P" trip upon loss of negative 20V DC or negative 15V DC pover to the SRM/IRM channels. This change vill be specifically accomplished via replacement of the existing ' 15V regulator card in each channel with an upgraded version. Implementation of the proposed change is considered a design upgrade, since the potential for reactor start-up with inoperable l SRM/IRH channels exceeding Technical Specification minimum channel operability requirements vill be avoided through automatic means. This design change is also consistent with the recommendations described in INP0 Significant Event Report (SER) 33-86.
-The probability of occurrence or the consequences of an accident / malfunction of safety-related equipment evaluated in FSAR Chapters 7 and 15 is NOT increased.
II. No. The proposed design change is limited to the modifications discussed above for SRM/IRM "INOP" trip circuitry. No other systems are impacted by this design change. The possibility for an accident or malfunction of a different type than evaluated previously in the FSAR is thus not created. l III. No. The margins of safety are not reduced since SRM/IRM inoperable trip function requirements in Technical Specification Sections 2.0, 3/4.3.3 and 3/4.3.6 are not impacted by this design change. k
s Attachmant 3 PY-CEI/NRR-0979 L Page 86 of 278 SE No.'s 88-126 Source Document FSAR CR 88-037, l I 4 . Description of Change
') 1
-This is'a change to Section 7.3.1.1.8 which adds a reference'to the LOOP
'I starting signal for the Battery Room Exhaust Ventilation system (H24) -1 standby exhaust train and to clarify the description of system operation, j 1
Summary. I I. No. This FSAR change request adds a description of design detail which adds the LOOP start signal description to the LOCA signal description for the Battery Room Exhaust Ventilation System. This change was previously evaluated in System Design document revision of February, 1984 and' incorporated in the plant per ECN-20137-86-348. J ' Adding the LOOP signal makes the system more conservative than
- l. previously considered in the FSAR. Starting the Battery Room Exhaust Ventilation during a LOOP assures adequate ventilation to_ ;
the Division 1 and Division 2 battery rooms. There is no increase ! in the probability of an occurrence or the consequence of an i accident or malfunction of equipment important to safety'not ' previously evaluated. The change request brings the FSAR in agreement with the approved design documents to more accurately reflect the as-built ; configuration. ! II. No. 'This change description does not create the possibility of an ; accident or malfunction of a different type than previously evaluated in the FSAR. No components are being added nor any ; changes made to function. It simply incorporates as-built ! information into the FSAR which makes the system more conservative. t~ l III. No. This FSAR change request does not change or alter the system in any way. The change incorporates the as-built configuration into the i FSAR which will increase the margin of safety. It does not change the plant as described in the Technical Specifications.
l Attcchm:nt 3 l PY-CEI/NRR-0979 L ! Fage 87 of 278 i SE No.:' 88-127 Source Documents' FSAR CR 88-063 Description of Change Evaluation of an FSAR change request to Section 7.3.1.1.2.b.4 and Figure 7.6-1 to reflect the latest revisions and to change over to CEI l drawings from GE drawings. s Summary I. No. The change to the CEI drawings will ensure that the. latest system design is in the FSAR. This change vill bring the FSAR in line with , the as-built condition of the plant. The proposed update of FSAR -! Figure 7.6-1 for consistency with Perry drawings vill bring the figures in agreement with system descriptions and analyses in FSAR , Chapters 7 and 15 and the plant configuration.' No impact on the < FSAR Chapter 15 analyses is brought about by.these changes. Therefore, it is concluded that these changes vill not increase the probability / consequences of'an accident or malfunction of safety-related equipment previously evaluated in the FSAR. II. No. The change is to bring the FSAR in line with the plant. This does not increase the probability of an accident or malfunction. The scope of the proposed changes is limited to'the modifications described above in Item I. There is no impact to other plant systems or equipment. A different type of accident or malfunction than previously evaluated in the FSAR is thus not created. III. No. The changes being made do not affect the bases of the Technical Specifications. SE No.: 88-128 Source Document: FSAR CR 88-091 Description of Change l Evaluation of an FSAR change request to incorporate several NRC Ouestions and Responses (0&Rs) into Chapter 5 USAR text. Summary I. No. No accident or malfunction to existing equipment is involved. ) This change involves appropriately incorporating referenced Q&R's by ] clarification, consolidation, deletion, etc. into Chapter 5.0. ! II. No. No new accident or malfunction is involved. Changes are editorial. III. No. No Technical Specification margins of safety are involved, changes are editorial.
i Attechmrnt 3 FY-CEI/NRR-0979 L Fage 88 of 278 SE No.: 88-129 Source Documenti- FSAR CR 88-092 Description of Change. Evaluation of an FSAR change request to delete several NRC Questions and Responses (0&Rs) from Chapter 7. These Q&Rs either no longer apply, are I not appropriate for incorporation into the FSAR text or contain )' information already included in the FSAR. 1 1 Summary I. No. This change only deletes unnecessary Chapter 7 Q&Rs which contain
! ' irrelevant information with no bearing on accident analyses or information already addressed in the FSAR. Consequently, their removal from the FSAR does not affect any existing accident analyses.
II. No. Because the information being deleted is redundant or not appropriate for the FSAR text, and has already been considered by- ! existing FSAR analyses, no new types of accident or malfunction vill be created by this FSAR change. l. III. No. This change has no effect on the margins of safety for any Technical Specifications. SE No.: 88-130 Source Document: FSAR CR 88-094 Description of Change Evaluation of an FSAR change request to incorporate and delete (because they have n1 ready been included) several NRC Questions and Responses (0&Rs) into Sections 9.1 thru 9.3 of the USAR text. Summary I. No. This change adds 3 Q&Rs to the FSAR text and deletes others because they have already been incorporated into the text. II. No. The information does not create the possibility for an accident or malfunction of a different type than was previously evaluated in the FSAR, since this information was already included in the Q&R section of the FSAR. III. No. No margin of safety for any Technical Specification is changed by this change request. l.
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.!- . Attachmint 3 PY-CEI/NRR-0979 L-Page 89 of 278" Ji j'
,SE No.s. '88-131 gsf
- Source Document: FSAR CR 88-093
-. I
,. Description of Change Evaluation of an'FSAR change request to make various editorial changes to i Chapter 7 of.the FSAR as a result of the FSAR update review per 10 CFR 50.71.
1 Summary I.~No. No accident or malfunction to existing equipment is-involved. The - changes are editorial in nature, i.e., clarification of existing 1 text, consolidation / deletion of repetitive material to enhance l readability, etc. ! II. No. No new accident or malfunctions are involved, the changes are' I editorial. III. No. No Technical Specification margins of safety are involved, the changes are editorial. l SE No.: 88-132 l Source Document: FSAR CR 88-087 j Description of Change Evaluation of an FSAR change request to make various editorial changes to ., Section 9.5 and Appendix 9A of the FSAR. These. editorial changes provide ! clarification of the existing plant configuration as previously analyzed for compliance with regulations. i l Summary ; I. No. The plant fire protection configuration as analyzed in the FSAR does not change as a result of these items. , II. No. Editorial changes only. Does not change any analysis or system ' functions. III. No. Only audit type administrative functions for the program are in the Technical Specifications, for fire protection items. These are not being changed. I I i I i
i Attachmsnt 3 1 PY-CEI/NRR-0979 L Page 90 of 278 SE No.: 88-133 i Source Document FSAR CR 88-088 ! Description of Change Evaluation of an FSAR change request to Appendix 9A.4 (Fire Protection (P54) system description) of the FSAR to' eliminate the automatic closing of fire dampers on smoke detection signals from areas I in the Control Complex. The automatic closing by detectors was described in the FSAR but was later determined to have a limited value on smoke control and possible adverse effects on safe shutdown in the event of i fire. Summary i I. No. The requirements for protection of redundant trains of safe shutdown ; equipment by separation call for 3 hour rated fire dampers in l separation barriers. These fire dampers are designed to close automatically in the event of a fire using fusible links. In certain barriers, the fire dampers were arranged to also close on a
. signal from the area smoke detection system. That is, any single ,
detector in the area vould close several fire dampers in the ! associate HVAC system to isolate the area. However the associated i HVAC systems are not arranged to shut down and with fire dampers l installed instead of smoke dampers, the spread of smoke to other areas would not be effectively prevented.
'However the system as designed could have an adverse effect on plant-shutdown due to spurious actuation of dampers in the HVAC systems for redundant trains of safe shutdown. A fire on one side of a barrier would quickly close associated dampers actuated by detectors in the area of the fire, but the separation fire barriers do not prevent smoke spread through rated fire doors and closed fire dampers. Due to the sensitivity of the smoke detectors, the detectors on the non-fire sides of the barriers could actuate. This would close additional fire dampers, possibly having an adverse effect on operation of HVAC systems required for the train of safe shutdown equipment redundant to that in the area of the fire.
To eliminate the possibility of disabling redundant trains of safe shutdown HVAC equipment, the power supply to the Electrothermal Links (ETLs) was put in a normally open position. This vill allow the ETL to function as a fusible link and close the damper in which it is installed if fire conditions warrant. However simultaneous closing of several dampers is eliminated. II. No. The changes reflect modification to fire protection features / functions in the Control Complex Building, these could not initiate or cause threat to fuel and/or the reactor coolant pressure boundary.
Attachmsnt 3'
'PY-CEI/NRR-0979 L Page 91 of 278 .
1 ' SE No.: 88-133 (Continued) Summary (Continued) l
- - III. No. Only the audit and review of the fire protection program are defined in the Technical Specifications. These are not affected by this change.
SE No.: 88-134 Source Document: FSAR CR 88-089 Description of Change - Evaluate the impact versus FSAR Appendix 9A, Fire Hazards Analysis on changes in usage of certain plant areas; such as the introduction of new shops,. offices and designated storage areas and the resulting changes in combustible loadings. Summary I. No. FSAR Appendix 9A, requires us to minimize storage of combustibles or provide additional protection in the form of suppression or 'j separation in areas containing safety-related equipment and other specified areas such as Radvaste and the Turbine Building._ In-addition certain plant areas have been granted specific deviations from the requirements of Appendix R and Branch Technical ! Position 9.5.1 based on the lack of any in-situ combustible loading in the fire area or parts of the area between redundant trains of safe shutdown equipment. The potential fire exposure to redundant trains of safe shutdown equipment or safety-related equipment presented by the designated storage areas was evaluated. A determination was made as to I whether the maximum amount of proposed combustibles vould increase b the fire hazard to a degree beyond the previously analyzed 3 acceptable limits. Those areas of the plant with fixed automatic sprinkler suppression systems installed contain adequate protection. The FSAR is updated to include the additional loading in the safety-related areas based on the proposed loading. For those areas without fixed suppression systems, the storage vill require containment and limitations in amount stored. In both cases the limiting factors are based on the potential for damage to the equipment in the area. II. No. This FSAR change request reflects modifications to fire protection features / functions in the Control Complex Building. This could not initiate or cause threats to the fuel and/or the reactor coolant pressure boundary.
l Attachmint 3 d PY-CEI/NRR-0979 L. l Page 92 of 278 !
'l SE No.: 134 (Continued)
Summary (Continued) < III. No. Only the audit and review of the Fire Protection Program are defined- ! in the Technical Specifications. Since this safety evaluation does not involve changes to these functions the margins of safety as defined in the bases are not affected. SE No.: 88-135 i Source Document: FSAR CR 88-090 Description of Change s Evaluate the change to the FSAR Appendix 9A, Fire Hazards Analysis due to
~t he erection of a separate three story Service Building Annex-(office structure) within the Protected Area.
Summary I.'No. The building is separated from other fire areas described in the. -j FSAR. There is-no safety-related equipment in the building. '
'II. No. There are no potential initiating causes of threats to the fuel and 1 the reactor coolant pressure boundary. R III. No. Only administrative aspects of the Fire Protection Program are in the Technical Specifications.
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I l j Attachmsnt 3 I PY-CEI/NRR-0979 L Page 93 of 278 j SE No.: 88-136 Source Document: DCP 88-0002, Rev. O Description of Change i The Automatic Flow Demand Limiter,-(AFDL) (1B33-K650), is a never Foxboro -l version controller that has a built-in limiter circuit which produces a : saw tooth output signal'when limiting. This output signal controls the Reactor Recirculation Flow Control Valves (1B33-F0060A & B). l proportionately, but because of the saw tooth effect, the valves - oscillate making it difficult for the Operator to manage the. process l control. Adding a signal limiter downstream of this AFDL Controller'will l mask the saw tooth effect. Also, adding a limiter downstream of the Remote Manual Station (1B33-K622-9).which is part of the Master Controller , (1B33-K622-8), vill be done.in anticipation of using the never version of j the Foxboro controller. Only the never version is now manufactured by j Foxboro. l 1 Summary l I. No. The design basis of the Reactor Recirculation System as described in ;
.FSAR Section 5.4.1 is not changed by the hardware additions. The ' ;- required design functions of the system remain unaltered. Addition of the Signal Limiters to the Recirculation Flow Controller network does not impact the operating characteristics of the Reactor Recirculation (B33) system instrumentation described in FSAR Section 7.7.1.3.
FSAR Chapter 15.4.5 Safety Analysis is not changed or altered by the design hardware additions. The intended result of this design change is to eliminate Recirculation Flow Control Valve oscillation for better process control. The hardware additions do not change the design basis event of " Recirculation flow control failure with increasing flow" nor the resulting consequences. The probability of occurrence or the consequences of an accident / malfunction of safety-related equipment evaluated in the ; FSAR is therefore not increased. II. No. The scope of this design change is limited to the discussion above. No other systems or components are affected by this design change. l A different type of accident or malfunction than previously l evaluated is not created. III. No. Technical Specifications do not address Reactor Recirculation Flov l Controller hardware. Technical Specifications Sections 3/4.3.4.1 and 3/4.3.4.2 also do not change due to this design change. The margin of safety is thus not reduced, s
Attechmznt-3 PY-CEI/NRR-0979 L L 'Page 94 of 278 . a; SE No.: 88-137-Source Document: FSAR CR 88-069 i
' Description of Change FSAR change to delete resumes from Chapter 13 of the FSAR. ,
Summary'
]
I. No. PNPP will follow:the guidelines of Regulatory Guide 1.8 for' selection.and! training of management personnel as, stated in FSAR- 1 Section:13.1.3.1. In. addition, unit staff members shall meet the qualifications of ANSI N18.1-1971'as stated in-Section 6.3 of-the Technical Specifications. -. Thereftire, removal 'of resumes from. FSAR . Chapter'13 vill not change the qualifications.of staff members, nor will it. change the requirements fdr selection and training. Therefore, there'.is no increase in-the probability of occurrence orL the consequences of an accident or malfunction of equipment important to safety. II. No. See Item I above. III. No. No margins of safety in the Technical Specifications are reduced by this. change. SE No.: '88-138
. Source Document: FSAR CR 88-070 Description of Change i I
FSAR change to delete statements related to operating crev i staffing / composition in Chapter 13 and replace them with a reference to the' appropriate Section of the Technical Specifications, where identical requirements are described. Summary I. No. The staffing level and composition of operatisig crews will meet the requirements as stated in Technical Specifications. Additional requirements not found in Technical Specifications are retained in the FSAR. There is no change in requirements. Therefore there is l no increase in the probability of occurrence or the consequences of j
' an accident or malfunction of equipment important to safety.
II. No. This change does not affect any accident analysis in the FSAR. j III. No. This change does not affect any bases for any Technical Specification. t I l
r Attachmsnt 3 PY-CEI/NRR-0979 L' < Page 95 of 278 I
'SE No.:' 88-139
- Source Documents. FSAR CR 88-066 Description of Change
- FSAR change to Section 9.5.9.1 describing the.as-built condition of-the HPCS Diesel-Generators (DG) and the DG Fuel Oil System.
The description of the volume of the fuel oil storage tank for the 1 Division 3 HPCS Diesel-Generator is being changed.to address the additional capacity (which provides for operability testing) contained in l the fuel oil storage tank. l The description of the operation of,the fuel oil transfer pumps is being changed to show that'the primary pump is stopped at the day tank;LO-Lo
. level setpoint and then the secondary pump is automatically star.t.ed. The l secondary pumps stop setpoint remains at the day tank,.LO-LO-LO . level..
The description of the fuel priming and booster pumps is being revised to i clarify fuel oil. transfer pump capacity.vith respect to the capacity of d the fuel priming and booster pumps. Changes are also being made to clarify the description of the return of excess fuel oil to the storage
' tank. Also each fuel pump has a separate. inlet line'and these lines are routed'to the fuel pumps rather than to the HPCS skid.
Summary j I. No. The additional storage volume of the fuel oil storage tank is the result.of a calculation which shows the amount of storage volume which is unusable, the amount required to support the associated i HPCS Diesel-Generator for seven days of continuous operation at designed emergency loads, and the remaining volume of the total 39,375 gallon capacity. It is this remaining volume which is used for operability testing. The modification to the day tank level setpoints which control the , fuel oil transfer pumps was implemented in accordance with manufacturer's recommendations to further enhance the fuel oil storage and transfer system's reliability. The pump control setpoints are based on day tank level and are now set such that the transfer pumps do not operate simultaneously. The revision to the description for the fuel pumps to clarify pump capacity as well as the clarification of return of excess oil to the storage tank are strictly editorial changes. In both cases, no j physical changes have been made to installed equipment that would l alter either pump capacity or fuel oil transfer / return system ; function.
Attachment 3 PY-CEI/NRR-0979 L Page 96 of 278 No.: 88-139 (Continued) Summary (Continued) The modification of the description of the fuel pump (priming or booster) inlet lines is required to provide consistency with FSAR Figure 9.5-15 and is again an editorial change. In this revision, no physical changes have been made to the fuel oil inlet lines that provide fuel oil from the day tank to the fuel pumps on the HPCS g Diesel-Generator skid that would alter line configuration, or fuel y pump capacity including function. s
} [A Hence, none of these changes affect equipment reliability and the probability of occurrence of a malfunction of equipment evaluated previously is unchanged.
II. No. These changes maintain the reliability, qualifications, redundancy and the ability for the equipment / system to perform its original designed function. Since no new design type is introduced by these changes, and all of the original design requirements are maintained, no potential for a malfunction of a different type than any evaluated previously is introduced by these changes. III. No. The margin of safety as defined in the bases of Technical Specification Section 3/4.8 refers to the reliability of the onsite power supply. As demonstrated above, this reliability is not compromised by the changes herein and hence the margin of safety is not reduced. f ->
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Attachmant 3 PY-CEI/NRR-0979 L Page 97 of 278 SE No.: 88-140' Source Document FSAR CR 88-041 Description of Change Evaluation of an FSAR change request to Sections 8.3.1.1.2.11.a.3 and 8.3.1.1.2.11.a.4.c. This change indicates that for Division 3 solid state rather than electromechanical relays are used for diesel voltage supervision, and for preferred / alternate preferred supply ground protection. i Summary I. No. This change identifies that the diesel voltage supervision relays and preferred / alternate preferred. supply ground protection utilizes i solid state relay protection on Division 3 rather than electromechanical. . The solid state relays provide protection and reliability similar to the electromechanical relays. This protection has been proven suitable for the application by analysis , (i.e., coordination calculations for ground fault relays) and/or by ! testing (i.e., diesel LOOP response testing for the voltage relay). ! Therefore, the Division 3 safety function performance is not affected. II. No. See Item I above. III. No. These relays are not discussed in the Technical Specifications. l 1 l _ _ _ _ . . . . _ _ _ _ _________.________a
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e Attachmtnt 3 PY-CEI/NRR-0979 L 1 Page 98 of 278 i
.SE No.: 88-141 -
l Source Document: FSAR CR 88-098 t Description of Change Evaluation of an FSAR change request that deletes unnecessary Q&Rs that' were not entirely incorporated into the text from Chapter 9, Section 9.5. These Q&Rs included information that was either unnecessary or repetitive. ~ to that already provided in the text. i Summary l I. No. This change request.only deletes FSAR 0&Rs.that contained f unnecessary, repetitive or superseded information that'vas already. adequately described in the text. No systems are changed or l affected by this change request. II. No. .The O&Rs that were deleted did'not change the function or design of any system described in the FSAR. The O&Rs only contained information considered unnecessary or already adequately discussed in the current FSAR text. I
.i III. No. There are no Technical Specification. bases affected by this change l since the 0&Rs being deleted only contained information that was !
unnecessary, repetitive or superseded. i SE No.: 88-142 l l Source Document: FSAR CR 88-018 Description of Change 1
~
Evaluation of an FSAR change request to Section 9.2.1.2 that clarifies part of the Emergency Service Vater (ESV-P45) system description. The-water levels in the ESV standpipes are monitored by pressure indicators. No level instrumentation as formerly implied in the FSAR is used. j Summary l 1 I. No. There are no level instruments to provide water level indication.and i the water levels are monitored by pressure indicators. The " Keep Fill" function still exists. The probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR is not increased. II. No. There are no changes to the system function and no other systems or components described in the FSAR are impacted by this change. A l different type of accident or malfunction not previously evaluated I in the FSAR is not created. l III. No. The Emergency Service Vater system standpipe water level is not i described in the Technical Specifications. l I
l l.. Att'schmint 3 l , PY-CEI/NRR-0979 L ji 4 Page 99 of 278 i SE No.: 88-143 j Source Document: FSAR CR 88-029 )
~ Description of Change l
Evaluation of an FSAR change request to clarify Section 3.6.2.1.7.1. . The i existing text did not address ANSI /ASME B31.1 piping in the high energy containment penetration break exclusion region. Summary I. No. The type of accident which is relevant to this change is a high energy pipe break between and adjacent to containment isolation valves.- Paragraph 3.6.2.1.7.1 gives the rules for postulating the location of such breaks and requirements for allowable' stress in i piping where breaks are not postulated. This. change is only a clarification of these rules regarding the extension of break exclusion zone (i.e., piping between containment isolation valves) to nonsafety piping between the outboard isolation valve and the first torsional and moment restraint as necessary to meet allovable stress requirements. The break exclusion zone described meets the allowable stress requirements of the FSAR and the NDE specified ; assures the quality level described in the FSAR. Therefore, the '
-probability of occurrence of any pipe break is not increased. The probability of a malfunction of equipment associated with the. piping or in the vicinity of the piping or. associated with the containment isolation function is likewise unaffected. The consequences of a pipe break are determined by rules unrelated to rules for postulating the location of the break and stress allowable in piping where breaks are not postulated. Therefore, consequences of any pipe break or associated equipment malfunction are unaffected.
II. No. Tipe break is the type of accident with which this change is co;* :erned. No breaks generically or specifically evaluated in the FSAR are created by this change. Since no additional breaks are created, no new equipment malfunctions are postulated. III. No. Since no new pipe breaks are created and safety margins as determined by piping quality assurance requirements are unchanged, the margin of safety defined in the bases for Technical Specifications is not reduced where such bases include pipe break considerations. __-_m____
Attachmsnt 3 PY-CEI/NRR-0979 L Page 100 of 278 SE No.: 88-144 Source Document: FSAR CR 88-030 I Description of Change Section 3.11.4 of the FSAR describes the effect of loss of ventilation on electrical / mechanical equipment within various environmental zones. This evaluation for Subsection 3.11.4.3 clarifies that a single failure of the associated Standby Diesel-Generator vill result in a divisional loss of power to the associated Emergency Core Cooling Systems (ECCS) pump room, local room coolers. Summary I. No. ECCS is divided into three separate divisions. When one division is lost more than one ECCS system can be lost (i.e., RHR "A" & LPCS). This.is an acceptable condition per the design basis of the plant. Therefore, the statement in the FSAR was in error when stating that no single failure can result in loss of cooling in more-than one ECCS pump room. ECCS pump rooms each have their own unit cooler. When the pump comes on the unit cooler also starts. A divisional loss which is a single failure can disable two ECCS pump room coolers at the same time. However, this being the design basis of the plant it does not increase the probability.of occurrence or the consequences of an accident or malfunction of equipment important to ' safety. II. No. All the accidents and/or malfunctions are based on loss of a division, thus no new or different events are created. III. No. The plant design basis includes an assumed divisional failure while still being able to shutdown the plant, thus the margins of safety within the Technical Specifications are not reduced. SE No.: 88-145 Source Document: FSAR CR 88-116 Description of Change Evaluation of an FSAR change request to make various editorial changes to Sections 3.5, 3.6, and 3.11 of the FSAR as a result of the FSAR update review per 10 CFR 50.71. i Summary See Safety Evaluation 88-131. 1
l AttachmInt 3' . . i W' '
? PY-CEI/NRR-0979 L 1
Page 101 of 278 I2 . SE No.: i88-146 Source Documentt FSAR CR 88-117 j I Description'of Change j 1: ' Evaluation of an FSAR change request-to make various editorial changes to-l' Section 9.5 of the FSAR as'a result of-the FSAR update reviev l.
'per.10 CFR 50.71. '
Summary l- .See Safety Evaluation 88-131. SE No.:- :88-147
- Source Document: FSAR CR'88-111 Description of' Change
.l Evaluation of an FSAR change request to delete Unit 7 figures where they - ;
.are identical.to Unit 1 figures,from FSAR Sections 9.4 and 10. .
o> j Summary I. No. The probability of an accident is not. changed with,the deletion of , Unit:2 figures where they are identical to Unit 1, because Unit 1 l
' figures.are representative of the design intent of Unit 2e ,l .
II. No. 'The possibility for an accident / malfunction-of a different type than previously evaluated is not' created by this change because these. ' Unit 2 figures are identical to Unit 1 figures. j
..'l III. No.= No margin of safety for any Technical Specification is reduced by ,
this change because-Unit 1 figures meet the design intent of Unit 2. '
. SE No.: 88-148 Source Document: FSAR CR 88-112
- Description of Change Evaluation of an FSAR change request to delete Unit 2 figures where they are identical to Unit 1 figures from FSAR Sections 9.1 thru 9.3 and 9.5.10. 7
<F Summary See Safety Evaluation 88-147.
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o' Attacharnt 3 1 l
- PY-CEI/NRR-0979: L: i Page 102 of 278 H SE No.s. 88-149 Source Documents ,
FSAR.CR'87-146
' Description of Change Evaluation of an FSAR change request to add a description of the
' Equipment Dynamic Analysis Software' Package (EDASP) computer program to those. listed in Section 3.9.1 of the FSAR as required by the Standard Reviev' Plan.
Summary I..No. This is a description.of a computer code used to ensure that.the seismic. design of instrument panels meets other FSAR commitments.. ' II.. No.: iki change to the plant as described in the FSAR has occurred. jf
-III. No. No change to.the plant or design margins has occurred. i
.1 SE No.: 88-150 'f c Source Document:- FSAR'CR 88-023 !
'l Description of Change- .
y Evaluation of an FSAR change request to Table 3.2-7 which describes the ~q ASME code-and addenda applicable to reactor. coolant pressure. boundary safety. class.1 equipment.. This change updates the. table to indicate that the Main Steam-(B21) and Reactor Recirculation _(B33) system piping were purchased to tue ASME Section~III 1977 Edition including the Summer 1977 Addenda. Summary' I. No. . Updates FSAR Table 3.2-7, Code / Addenda applicability, to the applicable purchase specifications. . Piping integrity not adversely affected. II. No. No change to configuration or operation. ; III. No. No reduction in design margins. i l
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' SE No.: 88-151 Source, Document: FSAR CR 88-114 Description of Change i l
, Evaluation of an FSAR change request.to eliminate in the General Design Criteria (GDC) assessments of Sections 3.1.2.6.1.1 and 3.1.2.4.12.1 the-discussions of post accident venting to control airborne contamination in the containment. The NRC has evaluated venting for other reasons .I (pressure control and hydrogen control) and has only accepted venting for one purpose - pressure control (see Perry SSER 10, Section 13.5.2.2.1).
Summary I. No. Consequences are improved by not venting. Probability of occurrence and malfunctions of equipment are not affected. II. No. No change to the plant. Procedures are simplified by this H elimination. The NRC via Perry SSER 10 accepted this position. III. No. Post accident dose is reduced by monitoring containment boundary. The margins of safety are increased. l I SE No.: 88-152 Source Document: FSAR CR 88-115
- Description of Change j t
I Evaluation of an FSAR change request to make various editorial changes to Sections 3.1, 3.2 and 3.9 of the FSAR as a result of the FSAR update review per 10 CFR 50.71. 1 Summary 1 See Safety Evaluation 88-131. l l ___._.____.m____.---_-.m. _ _ _ _ J
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.SE No.: 88-153 -
-Source Document FSAR CR 88-097 !
I Description of Change
, Evaluation.of.an FSAR change _ request to Appendix 9A.7-G to include a new deviation. analysis-for Fire Area 1CC-3a'in the control Complex.,
DCP 87-0123A-modified' operation of Reactor Core Isolation Cooling (RCIC) inboard containment isolation valve 1E51-F063 as analyzed for safe shutdown in the event of a fire. Summary, I. No.. E51F063, inboard containment isolation valve for the RCIC System was-previously identified in the safe shutdown analysis as:a DC operated,-normally closed valve which would be required to open.in
.the event of. fire for RCIC'to perform its desired function. As such; all. circuits for this valve and associated instrumentation and control circuits were separated from other Division'2 circuits and equipment so that a fire in any Division 2 area vould not affect.the ability.of this valve to open.
DCP 870123A provided.the electric power supply and associated control circuits:to change the' valve operator'to an AC,.3-phase motor with the valve in a normally open porition. -Since this is the
. desired position for safe shutdown, it is only necessary to protect those circuits or equipment ~ vhich could :cause the valve to spuriously close due to fire induced hot shorts, shorts to ground or open circuits. . For 3-phase power circuits, the probability of getting a hot short on all 3 phases in the. proper sequence to cause.
spurious operation of the motor is considered sufficiently lov as to not require evaluation (Generic Letter 86-10 item 5.3.1). Therefore, the AC power supply circuits for the motor operator do not require protection from the effects'of fire in the fire areas l, ,containing other Division 2 safe shutdown circuits and equipment. Since the control circuits for this vahe could cause spurious operation of the valve, they require separation from the redundant train of Division 2 circuits and equipment. The existing cables from the motor operator located in the Dryvell (Fire Zone IRB Ic) to l motor control center (MCC) ED1B09 in the Division 2 DC Switchgear Room (Fire Area 1CC-4c) were utilized and these circuits have been previously analyzed for adequate separation from the redundant train. The connection of the new circuits to the existing circuits will be inside MCC ED1B09 in Area 1CC-4c. Division 3 circuits, presently protected with a 3 hour vrap in this area, will be utilized for a fire in Area 1CC-4c. l l 1___ _ _ _ _ _ . _ _
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8E-153'(Continued) Summary (Continued)- s Control circuits are run from MCC ED1B09 to MCC EF1B07, Compt. XN, located in Fire Area 1CC-3a. Circuits which require separation from Division 2 in this Area are 1E51C185B and 1R25B626B~in conduit 1R33F1180B. DCP.87-0123D providen a 3' hour wrap on.these conduits from the point they enter the Division 2 Switchgear Room to
.1R24S026.- The circuits-inside-1R24S026; vill be protected with a 1 hour wrap up to the termination points at R42R magnetic'contactor inside the compartment. . In order for this device to. operate in a manner which could cause the contacts of the AC supply to close, a 120 V AC short would.have to occur.across the termination points within the MCC compartment. This bucket.does not contain'any other control: circuits and is separated from other HCCLcompartments by r;tal enclosure. A hot short of proper voltage inside the co.1partment is not considered possible since wires of adequate length and voltage are not present. The 120 V supply to this switchgear could be' disconnected vithin 1 hour so the 1 hour vrap-
.inside the cabinet is adequate protection to' prevent spurious-closure.of E51F063 in the event of a fire in Fire Area 1CC-4a.
II. No. The-change reflects effects of RCIC system design on fire protection analys33< As such it does not address any reactor system operation. III. No. Only tne audit and review of the fire protection program are defined j in the Technical Specifications. i t l 1 i I L I l 1 l
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SE No.: :88-154 -g Source Document: DCP 86-0725, Rev. 4 Descr'iption of Change Install air operated valves upstream of the Solid Radvaste (G51) System Mixing. Tanks inlet isolation valves to bypass the mixing tanks and pump. directly.to the Solidification Liners (shipping liners) from the Backwash i Settling Tanks or the Concentrated Vaste Tanks. This evaluation deletes performance of an Inservice Leak Test (ISLT) to allow partial closure of the DCP. Rework and ISLT to the DCP vere performed under Vork Order 88-0914, Rev. 1. i Summary I. No. Any releases of radioactive material in the Radvaste Building vill i be contained because the building is a seismic structure. Therefore, no increase in probability of an accident exists. II. No. The release of radioactive material in the Radvaste Building has already been evaluated in Chapter 15 of the FSAR. ! l III. No. For the reasons stated in I above, there is assurance that the. ! limits of 10 CFR 20 vill not be exceeded if radioactive material was ! released in the Radvaste Building. 'I l 1 l i
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SE No.s. 88-155. Source Document: FSAR CR 88-118-Description of' Change' '
! Evaluate an FSAR change request to Sections 4.5.1.1 and 4.5.2.1 which corrects discrepancies between the current FSAR and the General Electric materials specifications for control rod drive and reactor components identified during the FSAR update review.
Summary I. No. The update-to the FSAR corresponds to the original specifications. This-is not a specification change. Therefore the probability of ; occurrence or consequences of an accident is not increased. The
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shroud change lists materials actually u2ed and. eliminates matetials not used. General Electric (GE) heat treatment specification P13HYP1, Revision 7, dated May 1979 documented the 6 hours aging and 14% elongation criteria. GE identified the discrepancy between our FSAR' and their heat treatment specification. GE contends that our plant has components tested to their specification. The mechanical property / heat treatment requirements in the GE specification are in compliance with the ASME SA-564-81 Type 630 material specification. This ASME specification requires a 14% minimum elongation and an 1100'F aging heat treatment for 4 hours minimum. The ASME specification allows the time at temperature to be extended'to obtain the required ductility properties and thus would be more conservative. Note that the ASME SA564 specification added the clarification of minimum heat treatment time in the 1981 revision. II. No. This update to the FSAR corresponds to the original material specifications. There are no changes to the original I specifications. There is no change to equipment performance. ; Therefore no accident or malfunction is created. III. No. This update to the FSAR reflects original material specifications. The bases for the Technical Specifications are based on the original specifications. Since the original specifications are not changed, the margin of safety is not reduced.
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Attechmsnt 3' PY-CEI/NRR-0979 L Page 108 of 278 SE-No.: 88-156. { Source Document: DCP 87-123D,'Rev. 1 2 Description of Change Changes in the Reactor Core Isolation Cooling (RCIC-E51) system valve 1E51-F063 operation resulted in a change-in the' circuits and components associated with this valve as analyzed for t:afe shutdown in the event'of a fire. This particular design change was evaluated against Appendix R fire wrap for one hour and three hour barriers on conduit-1R33-F1180B in the Control Complex, Elevation 620'. , Summary See Safety, Evaluation 88-153. SE No.: 88-157 Source Document - FSAR CR 88-123 Description of Change Evaluation of an FSAR change request to Section 8.3.1.1.3.3 to clarify the High Pressure Core Spray (HPCS-E22) diesel generator alarms and interlocks. Summary-I. No. This change request clarified the list of conditions which render the diesel generator incapable of responding to an emergency start signal. The list given in NRC Question and Response (0&R) 430.84 disagrees with the list given on Page 8.3-36. The 0&R lists a manual / auto switch and a regulator switch which render.the diesel incapable of responding to an emergency start. These switches have no effect on emergency starts. Also, the maintenance switch is , indicated as keylock when it is'not, i Each of these differences has no impact on safety for the following reasons:
- a. The control room manual auto switch has diesel start, stop and pull to lock positions and no capability to block automatic
' starts. This is a more " safe" design in that it removes the potential for a mispositioned switch from causing a diesel start failure.
- b. The manual function of the regulator switch was removed during the test program. Manual voltage regulation would not be desirable or practical for the HPCS diesel. This diesel generator is loaded with nearly its entire load in one block and might not respond properly without the auto-voltage regulation. Elimination of the manual capability eliminates I
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o Page'109 of 278-SE No.: ~ 88-157 (Continued) g ' Summary (Continued) the potential of'a'mispositioned switch and removes an-4 -interlock.and its; potential.for malfunction. This change.
. improves-the overall response. probability.
The diesel generator maintenance control switch is not
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c. keylocked as indicated on Page 8.3-36 or in the Q&R. This.. switch is located in the Division 3 diesel room which has limited access. In addition, it is alarmed in the' maintenance positionLas indicated in 8.3.1.1.3.3 Item b.10.' The lack of a > keylock should not have a significant. negative impact-on d safety.* ! d.' The breaker interlock in the starting circuitry is for, ) verification that'the diesel is not already running and connected to the bus. If this breaker is-already closed and. the. diesel is not running it indicates an abnormal situation.' l l Under this condition, a diesel start vould'not be sdvisable.- Because this interlock prevents unnecessary actuation of starting. circuitry,-its effect is positive with respect to j safety. l
- e. The first sentence on Page 8.3-36 is being rewritten for clarity and is considered editorial.
II. No. On Page 8.3-44 alarms have been added for overload or power loss to the' circulating' oil pump, starting air compressor, and generator
. heater. The addition of these alarms has.a positive effect on ,
O safety. These alarms enhance the operator's knowledge of conditions which may lead to diesel generator failures. Since this- l annunciation is not involved with the diesel controls, malfunction , of this annunciation would have no affect on diesel generator ~ l response, j i .III. No. These changes have no effect on Technical Specification 3/4.8 - Electrical Power Systems. y l I j. L _ 2 - -. _ - -
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-Source Documents.
- ~ FSAR'CR 88-124- j
-8 0 : Description of' Change Evaluation of an FSAR change request to incorporate into j Section 3.8.3.1.3 and Table 3.8-11 the'finalLeontainment vessel and lowerJ l regionLdryvell vall design stresses due to the New Loads Adequacy . .
j P, valuation as requested by NRC Ouestions and Responses (0&Re) 220.17 and: q 220.22. 1 Summary I. No. This' change requust is modifying Table 3.8-11 and Section 3.8.3.1.3 to reflect the' final results of the New Loads Adequacy Evaluation of "
- the containment vessel and dryvell structure lover. region anchorage into the Reactor Building foundation mat, respectively. All revised values are.taken from the latest analyses and meet the pertinent ASME Code design allowables and, as such, do not change the design basis of the plant. Therefore,~the probability of occurrence or the consequences of an accident / malfunction of equipment important to i safety as previously evaluated in the FSAR is not increased.
II. No. The FSAR. change.as discussed in Item I above is not a change to-the 4 design basis of the plant and does not create.an . 1 accident / malfunction of a different type than previously~ evaluated i in the FSAR. III. No. - Since all ASME Code design allowables are satisfied, no design basis ; margin of safety from the Technical Specifications is reduced. SE No.: 88-159 ' Source Document: FSAR CR 88-095 Description of Change Evaluation of an FSAR change request to'Section 9.5.2.2.1 which corrects ! the description of the Private Branch Exchange (RSS) telephone' system to 1 state that only one (instead of two) fiber optic cable channel is ! available as a backup to the normal fiber optic channel. Summary I. No. The R55 system is not interconnected with any safe shutdown equipment. Additionally, R55 system redundancy exist's. II. No. The RSS system is not interconnected with any safety or non-safety plant process systems. Sufficient communications exist for any conceivable plant contingency needs. III. No. This change does not affect Technical Specifications.
Attschmsnt 3-PY-CEI/NRR-0979 L W; , Page 111 of 278 SE No.: 88-160 Source Document: FSAR CR 88-099 ! i
' Description of Change'
' Evaluation of an FSAR change request.to Section 8.3.1.2.2 and Table 8.1-2 i to. clarify.the degree of compliance of Class 1E electrical. system testing l to Regulatory Guide (R.G.)'1.22. ,
1 Summary' q I. No. It is neither practical nor desirable to test all of the Class 1E: electric system during reactor operation. R.G. 1.22 recommends testing from the sensor to the actuated equipment with the reactor in operation. .This would require safety related circuit. breakers an'd loads to be declared inoperable to perform these tests and reduced redundancy of safety systems. Testing while the reactor is shutdown allows logic circuits and circuit breakers to operate and i protective relays to be calibrated when much less redundant equipment is required to be operable. Testing while shutdown vill lessen the probability that malfunctions . will degrade plant accident performance.- The overall effect of performing testing while shutdown is positive with respect to l safety.
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'II.LNo. See Item I above.
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.III. No.- Performing the majority of Class 1E electrical system testing during outages does not disagree with Technical Specification requirements. ;
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Attechmsnt 3-PY-CEI/MRR-0979 L Page:112 of 278 SE No.: '88-1'61 Source Document: FSAR CR 88-100 Description of Change 1 1
' Evaluation'of an FSAR change request to Section 8.3.1.1.2 which clarifies ;
that a Loss of.0ffsite Pover-(LOOP) signal:to restart safety-related HVAC :j
~does_ depend on proper operation of relays in both Divisions 1 and 2. '
Summary I . - No . - The LOOP signal by design is not expected to'be operable for all failures in any-single division. The purpose of the signal is to restart safety-related HVAC during a Loss of Offsite Power (LOOP), a
- non-accident condition. ~
The LOOP design as it exists has no significant effect on safety'for the following reasons: j
- a. Should.an accident occur all HVAC is started by the LOCA ,
signal, therefore LOOP signal failure would have no effect.: l
- b. Emergency Service Water to cool the diesel generators starts j vith the diesel'and does not depend on the LOOP signal.
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- c. Further analysis per DAR 222 indicates that there~is sufficient )
time for an operator to restart HVAC systems, should the LOOP ! signal fail II. No. See Item I above. III. No. Technical Specifications do not address the LOOP signal and associated restart of safety-related HVAC systems. l i i
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PY-CEI/NRR-0979 L-Page_113.of 278 SE No.: 88-162 Source Document: -FSAR CR 88-101 [ i Description of Change Eva2uation of an:FSAR change request to Sections 8.3.1.1.3.2.b.3 and ) 8.3.11.3.2.b.10.b which'elarifies'the list of Division 1 and 2 diesel l generator tripping devices. There is no loss of excitation trip. :( a Summary- 1 ' s I. No. This change in diesel trips has no effect on safety. Per the FSAR and Technical Specifications all trips except engine overspeed and generator differential. current are bypassed when an ECCS actuation signal (LOOP) is present. The lack of a loss of excitation-trip l does not affect diesel operability because, with or without the trip, the generator is unavailable (non-functional) when excitation is lost. II. No.. See Item I above. 1 4
- III. No. Technical-Specification Section 4.8.1.1.2.e.7.a specifies that' 1 engine overspeed and generator differential current are the only l trips not bypassed with an ECCS actuation signal. The changes will not affect this.
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Page 114 of 278 J SE No.: 88-163 I Source Document: FSAR CR 88-102-
' Description of Change 1
Evaluation.of an FSAR change request'to clarify Section 8.3.1.1.6.5c & d. with respect to load. sequencing, overload. protection and the draw out ] feature of protective relays. l Summary 'l
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I. No. The technical changes involved in this change request relate to the
" alarm only" function for HPCS motor overload, load sequencing in Division 3 and the-draw out feature discussion in Paragraph d.
Load sequencing does exist in Division 3 for several significant loads as indicated in Table 8.3-1. Additional sequencing detail is
'being added to this table, for Division 3. This sequencing evens out the.overall plant load profile for accident conditions with offsite power available. The load sequencing vill not prevent the HPCS systems from meeting their overall response time of 27 seconds.
Load sequencing, therefore, has an overall positive affect on safety. The HPCS motor is' protected for overloads consistent with O&R 430.81. The setting is high enough to prevent premature trips while allowing proper protection against permanent faults. The lack of overload protection could allow a motor to fail and therefore'be not available. Overload protection properly applied per Q&R 430.81 j vill not remove a motor from service until it is nearly at the l failurn point.. This vill, therefore, not significantly affect the I operability / availability of this motor when needed. l
, Not all Division 3 relays are draw out type, and in addition, a number of other relays are recommended to be calibrated in place.
These relays are calibrated with the equipment removed from service generally during outages. Therefore, the method of' testing draw out/ replacement vs. in place calibration has no effect-on safety. In addition to the previous technical changes, the lengthy discussion on protective coordination in Division 3 was greatly simplified. This is not considered to be a technical change. II. No. See Item I above. III. No. The Technical Specifications do not discuss overcurrent protection or load sequencing of HPCS (Division 3) equipment.
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.SF No.: 88-164 l Source Document: 'FSAR CR 88-103 l
' Description of Change ,
Evaluation of an FSAR change request to Section 8.3.1.4.5 to remove ! requirements for nitrogen pressure maintenance'and monitoring during shipping, storage, and installation of electrical penetrations,s This ; level of' detail does not need to be addressed in the FSAR. j Summary ! u I. No. The requirement to maintain nitrogen. pressure on the electrical s penetrations during shipping, storage and installation is unduly l restrictive. Consultation with the manufacturer, Westinghouse, has verified that this is not required. There can be no effect on safety by-removing this requirement because the penetrations are 1 performing no plant function during, shipping, storage, and j installation. Nitrogen pressure vill be established on any nev { penetrations before installation is completed. j II. No. See Item I above. III. No. Technical Specifications do not address shipping,-storage, and I installation of electrical penetrations. I l I I i l 4 l l l i l l 4 l
Attcchmsnt 3 l PY-CEI/NRR-0979 L-Page 116 of 278 l SE No.: 188-165 Source Document: FSAR CR 88-106 Description of Change ~ s Evaluation of an FSAR change request to Sections 8.3.2.1.3.1'and 8.3.2.1.3.6 which. serves to clarify that batteries may be disconnected from the bus while an' equalizing charge.is being made. This is recognized in 8.3.2.1.2.1 for Division 1 and 2; implied, but not
-explicitly stated for Division 3 and contradicted in Q&R's 430.90 and 430.91. These.0&Rs are'also being incorporated as revised.
Summary I. No. ..The" removal of batteries for equalizing charge has no effect on j safety.due to the availability of Unit 2 safety-related batteries of equal capacity. This allows an equalizing charge with higher voltage than the 140V maximum capability of the connected loads. Manufacturer's have indicated that an equalizing charge of greater than 140V may sometimes be required. Technical Specifications recognize that the Unit 2 batteries may be used for D.C. system operability. This further indicates that there is no effect on safety while operating in this condition. II. No. 'See Item I above. III. No. Technical Specification (3.8.2.1) allows the use of either Unit 1 or 2 batterieu for D.C. system operability. i l i I
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SE No.: 88-166 ! Source Documentt FSAR CR 88-105 g
' Description of Change
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-Evaluation of an FSAR change request to Section 8.3.2.1.2.3 to clarify that all safety-related.D.C. loads do not have to operate at the minimum battery voltage-(105 Vde).
.i Summary ;
I. No. At the time of the Integrated Design Inspection (IDI), it.vas .l' recegnized that all safety-related D.C. equipment was not required to operate'until the battery was fully discharged in two hours to 105 volts D.C. Some loads will operate only at the beginning of the i l- duty cycle'(114 volts de with battery charger unavailable). Further, with a reserve battery charger available it is unlikely that the minimum 105 volts D.C.'would be-reached prior to reserve charger; connection. Due to this analysis demonstrating that D.C. loads vill operate when required, no effect on safety exists. II. No. See Item I above. ~ III. No. Technical Specifications on D.C. power sources (3/4.8.2) do not i address the' minimum battery voltage at which connected D.C. equipment must operate. ! l i
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_,, Page 118 of 278 ; SE No.: ~88-167. Source' Document: FSAR CR 88-107 Description of Change ! r Evaluation of an FSAR' change request'to-incorporate NRC Question and Response (0&R) 430.101 into Table 8.1-2. The Q&R' incorrectly states that circuits from 480 volt unit substation circuit breakers penetrate containment and fails to recognize circuits protected by a fuse and breaker combination. These. deficiencies are corrected.
~ Summary I. No. The 0&R incorrectly states that circuits from unit substation circuit breakers penetrate containment. This is incorrect and none of these exist in the Technical Specifications. This has no effect on safety.- No protection is required because no such circuits exist.
The Q&R does not address circuits protected by a fuse and a circuit breaker in series.- This is permissible per Regulatory Guide 1.63 and adequately protects the penetration. Therefore, this also has ; no'effect on safety. Technical Specifications do recognize circuits ' with a breaker and fuse in series. II. No. See Item I above. i
.III. No. This change request ~ modifies the Table 8.1-2, Regulatory Guide 1.63 discussion to agree with Technical Specification Table 3.8.4.1-1.
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'Attschrent 3 PY-CEI/NRR-0979 L Page 119 of 278 ~ No.s 88-168 Source Document: FSAR CR 88-108 1
Description of Change -1 Evaluation of an FSAR change request to Table 8.2-1 which clarifies that the control of future Unit 2 generator breakers occurs from the CEI Systems Operations Center (SOC) rather than the Unit 1 Control Room.
!Also, several alarms / indications for the preferred power system are corrected in the Table. l ' Summary I No. This change request involves control of the future Unit 2 generator i breakers from the System Operations Center rather than the Plant !
Control Room, lack of Transmission Substation trouble alarm in the Control Room and changes to several computer alarms. None of'these-have any significant effect on plant safety. Sufficient alarms and controls exist for power system operation. The Unit 2 generator breaker remains controlled from S0C until the 1 Unit 2 generator is operable. This is consistent with the treatment , of the Unit 1 breakers during construction. -j A transmission substation trouble alarm is not necessary because the i transmission station is operated primarily by traveling substation ;f operators dispatched by SOC. Should the unlikely need arise for a Perry response, many forms of communication exist between S0C and Perry so that Perry Operations personnel may be notified. -! The changes in computer points provide for all significant buses to I be monitored, the most significant being the EH buses. Sufficient other buses / breakers are monitored to properly operate the power system. Buses TH2 and TH12 are the supplies to the Unit 2 EH buses and are not required for Unit 1. II. No. See Item I above. III. No. Sufficient breaker controls and indications are available to verify Technical Specification power availability requirements.
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' Source Document: FSAR CR 88-109 l 1
Description of' Change Evaluation of an FSAR change request to add an electrical ~ penetration ] (1R72-S032) to Figure 8.3-19 to reflect.the plants as-built' condition. j i l Summary l I. No. Providing additional separation for redundant shutdown circuits >! reduces the probability of total failure of redundant systems; :j II. No. . Improving the reliability of redundant shutdown system does not increase the probability of an accident or malfunction not ! previously evaluated. t III. No. Improving.the reliability of redundant systems will not decrease ! safety margins as defined in the Technical Specifications. ] l SE No.: 88-170 Source' Documents- FSAR CR 88-110 l Description of Change Evaluation of an FSAR change request to update FSAR Figure 8.3-22 to 4 reflect DCP 85-0042. This DCP replaced the maintenance tie bus and l battery charger 2P/50 breakers with 3P/100 breakers which are sized to ' take the battery discharge current. Summary 1 I. No. The battery discharge current is 62A which trips the.50A breaker. ' Replacing the 50A breakers with 100A breakers allows for proper ~ operation of the equipment.
'II. No. Increasing the breaker size to carry battery discharge current doesn't create any increase in the probability of an accident or malfunction of equipment as evaluated in the FSAR.
III. No. Increasing the size of the circuit breakers allows for proper functioning of the breakers as designed by GE. Technical Specifications (3.8.2.1 - 3.8.2.2) do not indicate breaker size. l i J
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,SE No.si 88-171 Source Document: 'FSAR CR 88-122 Description'of Change Evaluation of an FSAR change request to FSAR Figures 8.3-6, 8.3-8 and 8.3-9 to update the Division 1, 2 and 3 Diesel Generator logic diagrams to' agree with the: revised text of Section 8.3.
Summary I. No. The probability of occurrence of a malfunction of equipment evaluated previously in the FSAR is not affected by the changes described for the following reasons: a) A portion of'these changes affect the Division"2 emergency diesel generator functional design. These changes were evaluated previously with respect'to'10 CFR 50.59 requirements as part of safety evaluation 87-0373.(per DCP 870276B) and were found not to involve an unreviewed safety question, j i b) .The' remainder of'the changes are editorial in nature and involve no functional or physical design change. These changes represent a clarification of the emergency diesel generator design for Divisions 1, 2 and 3 as described in FSAR Section 8.3 and as previously reviewed and approved by the NRC. Since'the changes described in Section I above involve only previously reviewed and approved design, the consequences of.any accident or malfunction of equipment have also been reviewed
.previously.vith respect to these changes and were found to not create any unreviewed safety questions. j II. No. No possibility for an accident is created by these changes. Those 4 changes herein which affect the original plant. design were evaluated 1 previously and.found to not create an unreviewed safety question.
1 The remaining changes are editorial.' III. No. The margin of safety as defined in the basis for any Technical , Specification remains unchanged. l i l 1 l 1
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-SE No.: 88-172
' Source Document: FSAR CR 88-120 Description of Change 3 Evaluation-of_an FSAR change request to completely rewrite Section 7.6.1.5 - Rod Pattern Control' System'(RPCS) to provideLa more complete and coherent description of the~ system,.it's functions,
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operations and design. Various changes were made.as follows: I
- 1. Described'the functions of the Rod Pattern Control System consistent with words used in the Technical Specifications.
- 2. Identified aspects of the'RPCS which deal with reducing the J- potential for a fast period scram or a Rod Withdrawal Error.
- 3. Rearranged the hardware descriptions into a narrative and provided'a more complete description of the inputs to RPCS.
- 4. Clarified how the thermal power measuring instruments in the two '
. channels are treated'in the determination of which mode the RPCS '
enforces. i
- 5. Provide reference to where rod group assignments can be found. , j
- 6. Made a distinction between drive bypassing (which is used for stuck rods) and position bypassing (which is used for~ failed position-sensors).
.1
- 7. Revised the description of the rules used in the RPCS logic for greater clarity.
- 8. Added a description of the fast period scram induced one notch withdrawal limitation.
- 9. Added a description of the change in increment permitted by the RWL' l as the thermal power crosses the HPSP. '
- 10. Added references to the appropriate documents from which the RPCS information is derived.
Summary i I. No. This FSAR change corrects minor errors in the description of system performance and adds more detail on system capabilities without affecting the control Rod Drop Accident (CRDA) or Rod Withdrawal - Error (RVE) analyses as described elsewhere in the FSAR. II. No. This change does not create any new system capabilities or alter j system performance from that which was used to perform the CRDA and RWE analyses. - _ = _ _ _ - - _ . _ _ _ - - .i
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l' f Attechs:nt 3 PY-CEI/NRR-0979 L Page 123 of 278 SE No. 88-172 (Continued) h [ < Summary -(Continued) LIII. No. This change'does not alter the operation of the RPCS as defined in the bases of any Technical Specification. i SE No.: 88-173 Source Document: FSAR CR 88-121
' Description of Change-l Evaluation of an-FSAR change request to Section 7.2.2.3 to remove the . reference to the Traversing Incore Probe (TIP) in connection with-the Average Power Range Monitor (APRM)_ calibrations. Requirement to adjust !
APRM gains due to local flux considerations was removed by issuance of I the full power Technical Specifications and was evaluated by the NRC in
'the Perry Supplement to the Safety Evaluation Report (SSER), Number 10.
Summary I. No. This change was previously evaluated in SSER 10 in Sections.6.3 and 16.2.1 as follows: Elimination of APRM Setdown In the current Technical Specifications, the flow-biased APRM trips l are reduced (set down) when the core maximum total peaking factor ' exceeds the design total peaking factor. The GE analysis . (NEDH-30963) performed for Perry includes results from analyses made to determine the new initial conditions of fuel thermal' limits that would be needed to satisfy the pertinent licensing criteria if APRM setdown vere eliminated. The new limits should (1) prevent violation of the MCPR safety limit, (2) keep the fuel thermal-mechanical performance within the design and licensing basis, and (3) keep peak cladding temperature and maximum cladding oxidation within allovable limits. It was concluded that current MAPLHGR limits protect against a LOCA even without APRM setdown. The flow-dependent MCPR limit is also not affected by elimination of APRM setdown because the design-basis flow runout event is a slov flov/pover increase not terminated by scram. The results of the analysis with approved methods are:
- a. New power-dependent relations for MCPR and MAPLHGR limits are provided, which include both high- and low-flow relations at powers belov 40% where reactor scram on turbine control valve fast closure is bypassed. The MAPLHGR relation is a factor, MAPFAC , which is multiplied by the normal full-power MAPLHGR limit Eo obtain the power-dependent MAPLHGR limit.
A
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Attachment 3 PY-CEI/NRR-0979 L Page 124 of 278 l SE No.: ,88-173 (Continued) l Summary (Continued)
- b. A new flow-dependent MAPLHGR factor, MAPFAC g , is provided.
This factor was determined from analysis of slow flow runout transients with the requirement that peak transient MAPLHGR values not exceed the fuel design-basis values. The staff finds the elimination of APRM setdown acceptable for Perry. Specific Technical Changes for Full-Power Operation Specification 3/4.2.1: The proposed change to this specification
~ dealing with maximum average planar linear heat-generation rate (MAPLHGR) limits results from the proposed elimination of APRM setdown in Specification 3/4.2.2. The current specifications provide for a reduction in the flow-biased APRM trips when the core maximum total peaking factor exceeds the design total peaking factor. ,With the proposed elimination of APRM set-down, this peaking effect is covered by a revision of the MAPLHGR limits. The revised limits are presented as graphs for both a flow-dependent and power-dependent MAPLHGR factor in Figures 3.2.1-4 and 3.2.1-5. The revised limits provide equal or increased margins to fuel integrity limits relative to those obtained with APRM setdown. The staff finds the proposed change acceptable.
Specification 3/4.2.2: The proposed change is to eliminate this specification, which involves the APRM setdown. As discussed under Specification 3/4.2.1, this proposed change is acceptable to the staff. II. No. See Item I above. III. No. See Item I above.
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-Attschmznt 3' l- PY-CEI/NRR-0979 L
"- Page 125 of 278 SE No.: 88-174 Source Document: FSAR CR 88-085.
I Description of Change
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The scope'of.this FSAR change request can be categorized'into the following items: The description of the HPCS Diesel-Generator Air. Starting System,is being revised and clarified'to more accurately describe system and. , component function and operating parameters as follows: l Diesel-Generator operates at rated speed, voltage and frequency _. within 13 seconds after receipt of the start signal rather than ten l seconds. : The air compressor normal operating range is between 210 psig and 250 psig. Air in the starting air receiver tanks is stored above the minimum i standby pressure; i.e., above 210 psig, instead of rated pressure. The vye strainers in the system function to minimize particulate . carryover during system operation but not collect all loose particulate. Inspection and cleaning of system components is performed periodically in accordance with manufacturer's recommendations rather than once during initial trial runs. The description of the starting air compressors is being revised to ! reflect implementation of DCP-870162A as follows: ! The Division 3 air compressors are driven'by 10 hp, 460 vac, 3 phase, 60 Hz motors. All reference to the diesel engine driven compressor is being deleted. ' The quantity of motor driven air compressors is increased from one to two units for this system. The description of the Starting Air System instrumentation and controls is being revised and/or clarified as follows: There are four locally-mounted pressure switches for monitoring the air pressure in the air receiver tanks. Two air pressure switches, one per air receiver, automatically start and stop their associated air compressor per the description above. The other two air preesure switches, one per air receiver, provide lov air pressure alarms and trouble alarms. There is a high devpoint alarm for each air dryer. l l 4
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, Page: 126.of 278 gi 7 f . SE No'.'s '; ;88-174'(Continued)1
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Summary l(Continued) ' . The' description of'the~ cranking capacit'y of the Starting-Air System e
~is;being changed.to. describe a cranking cycle's duration as
- sufficient to successfully start the.dieseligenerator, instead.of three 's_econds . - The design-of the capacity:of the Air Start. System-tis based on engine. start attempts and not on.three second cranking:
g Icycles. iSummary I . ; No. - The' revision made to the engine-start time.following receipt;of the start signal from 10.second to within 13 seconds-for stabilized operation-is'a change that still permits HPCS initiation'within s This revision also provides consistency withzthe. 27 seconds
- Technical Specifications which reflect'a time frame of 13 seconds.
This change provides an. engine start to full load time frame that is-similar-to.that for other GE/EMD HPCS Diesel-Generator installations.' This revision does not represent any physical or control, change to the HPCS Diesel-Generator.
$' The change made to the description covering the storage of air.in Lthe air receiver: tanks at a pressure.above;210.psig is a revision that provides consistency with the air pressure switch setpoints
'that monitor / control the operation of the system thus~ assuring ]
sufficient' volume for a minimum of'five consecutive engine starts. Other changes made to those sections of the FSAR concerning." normal operating range"'for the system (i.e., between 210 psig and 250 psig) provide similar consistency with'the air pressure switch setpoints. This change does not represent any physical or' control change to the HPCS Diesel-Generator. ! The' revision to the description of the vyeistrainers to reflect.
~
filtering of particulate carryover is an editorial change that correctly defines. actual.~ strainer performance. While the vye h strainer will remove most particulate from the Starting Air System, it is not designed to filter / remove all particulate. The design of the vye strainer limits particulate size so that the starting air L valves, motors, etc. downstream vill not incur any damage or , p: experience malfunction due to the presence of any of this carryover. l particulate. This revision does not represent any physical change j to the HPCS Diesel-Generator, i i The revision to the description of the Air Starting System component -l inspection and cleaning period updates the original text from the ; !- Preoperational Maintenance Program to requirements of the Operating ! i s lf L
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Attechm:nt 3 PY-CEI/NRR-0979. L .] o Page 127 of 278' I
-1 SE No.: 88-174 (Continued) .
I l
', Summary (Continued)-
Plant Maintenance ~ Program. This change is simply a clarification of- l existing Maintenance Program requirements and is not the result of-any change in physical design, or component or system reliability.- The revision to the description.of the locally mounted air pressure switches provides consistency with Figure 9.5-24 for both switch
' function as well as switch configuration for each air compressor and receiver tank train. Additionally, this change provides consistency-with the air pressure switch setpoints for automatic air compressor stop-start operation as well as system alarms for. low air pressure.
None of the above revisions. represent any physical change to the - diesel-generator other than those associated with and addressed in the Safety Evaluation for DCP-870162A for' removing the diesel engine 4 drive for air compressor-1E22-C004A. The revision to the description of the high devpoint alarm to clarify that the alarm exists for each air dryer in the Starting Air System is a change that provides consistency with installed panel configuration. Since each air dryer already has its own control i panel, local alarm for high humidity, and individual humidity sensor ! for monitoring outlet air quality, this clarification does not I represent a design change to the air dryers or system. The change to the description of the cranking capacity of the HPCS ! Die'sel-Generator Starting Air System is not the result of a change i f ,' .to any design specification for the Starting Air System, or the t- result of a physical design change. The three second cranking cycle duration originally ~ described in the FSAR is an approximate duration referenced in the Standard Review Plan Section 9.5.6, and was not a requirement of'the qualified design. The change to " cranking cycles ; of a sufficient' duration to start the diesel-generator" is the l parameter which was specified in the original design and verified l during qualification and preoperational testing. Hence,.this change ! is a clarification to state the original design parameter. -This change maintains the original HPCS diesel-generator design requirements and has no effect on the starting reliability of the HPCS diesel-generator. , With the exception of the modifications addressed by DCP-870162A and its associated Safety Evaluation, none of the changes involve physical changes to the originally qualified design. Therefore, the a probability of occurrence or the consequences of an accident have L not been increased by these changes.
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AttschmIntL3 4 SPY-CEI/NRR-0979 L
> > Page 128..of 278 SE No.: '88-174 (Continued) .
Summary (Continued)* _
'II. No..'These changes maintain.the equipment and' system reliability, qualification,' redundancy,.and function of the original design.
Since,no new type of design'is introduced.by these changes and all .
.of the original design requirements are maintained, no potential for l a-. malfunction of a different type-than any evaluated previously is j
" introduced.
{ III. No. The margin-of safety as defined in the: bases of Technical Specification Section 3/4-8 refers to-the reliability of the'onsite power supply. This reliability,is not compromised by.the changes a herein and hence the margin of safety is not' reduced. i SE No.: '88-175 Source Document: FSAR CR 88-086 Description of Change
.i The scope of this FSAR' change request can be categorized into the' l following items: l The description of,the flow loop of the HPCS Diesel-Generator Lube Oil System is being revised and clarified to more accurately describe.the system's components and their function as-follows:-
.i The description of the keepvarm cycle of the lube oil is augmented.
to include a reference to a more detailed description.of this process found in FSAR Section 9.5.9.2.2 "HPCS Diesel-Generator Jacket Water System Description". l A description of the AC motor driven soakback pump with respect to design, function,-and control is being added. The details describing the DC* motor driven soakback pump are being
- changed to reflect the current design function and control, and the description is being augmented to describe original motor design l characteristics.
The details describing the AC motor driven circulating pump are also . being changed to reflect current design function and control, and the description of the original motor design characteristics are ! being added. Information relative to the performance characteristics of the AC motor driven soakback pump is being added to Table 9.5-6.
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J M' PY-CEI/NRR-0979'L"- g Page 129 of 278 7p .> 7~- w
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{' lSE'NE.F. !88-175 (Continued)
, (Description'of Change (Continued)
K
' -A description'of thelflow loop ofLthe'Soakback System is added7 th
- further-ensure the changes made,by implementation of General Motors Li
- g. '
Corporation, Electromotive. Division Maintenance Instruction #9644 L ,
'(MI.9644) are completely described.
1 4-The description of-the. location of the point in the Lube Oil system at which'~ pressure is monitored'by the cranking lockout pressure
~
switch-is being changed-to reflect the location as originally.. qualified by the equipment' manufacturer.
.A'. description of each~of.the engine driven: lube oil pumps and their ,
l functions'is being added to reflect the current. design. The design codes'of the Lube 011 System piping are being added..by way of a reference to Table 3.2-1. Q&R Items =430.45 and.430.46 are being deleted. Summary I. No. 'The changes.and additions to the descriptions of the. components in the HPCS Diesel-Generator Lubrication System flow loop, including changes-to component' functions and. system flow path, represent a clarification of the. Lubrication System design as qualified prior to ' HPCS Diesel preoperational and operability' testing. These changes also reflect the implementation of General Motors Corporation, 1 Electromotive Division Maintenance Instruction #9644 titled " Lube j' Oil Circulating Pump System for Emergency. Fast Start Installations" (MI 9644). Perry committed to the NRC to implement.MI #9644 in FSAR: i O&R 430.46.- The design change which modified the HPCS Diesel Lubrication System to incorporate the features of MI #9644 was implemented in'. accordance'vith design, manufacturing, installation and quality standards which are equal to those'of the originally qualified > design. This. modification enhances the effectiveness of the Lube 011 Circulating System during standby conditions and the reliability ~ of the HPCS Diesel-Generator overall. This design change adds an AC-driven soakback' pump to continuously l supply oil to the turbocharger. bearings. As a result, the AC motor ] driven circulating pump is relieved of turbocharger prelubrication H flow demands such that the circulating oil pump is now dedicated to ] crankshaft bearing prelubrication and maintaining oil levels in the oil galleries. The original Lube 011 Circulating System design did not provide for forced prelubrication of crankshaft bearings or maintaining oil levels in the oil galleries during standby conditions.
Attachm:nt 3 PY-CEI/NRR-0979 L Page 130 of 278 SE No.: 88-175 (Continued) Summary (Continued) A primary benefit of implementing MI #9644 is that engine wear-is now minimized during engine starts. This is a direct result of the ' main bearings and their supply lines being supplied with oil, and oil lines to the upper engine being maintained full of oil during I standby conditions. Upper engine bearings are not continuously I prelubricated by this design. However, their supply lines are l maintained full of oil such that they receive lubrication within the l first few engine revolutions. By maintaining oil galleries full of l oil, upper engine lubrication upon startup is achieved without the j potential for oil leakage into a cylinder and the resulting l potential for engine damage upon startup. Since'the components utilized to implement HI #9644 to modify the HPCS Diesel-Generator Lube Oil Circulating and Soakback Systems l exhibit equivalent design, manufacturing, and quality standards as t the original equipment, their reliability is considered equivt. lent to the original equipment also. The change to the Q&R Section 9.5, which deletes the items numbered 430.45 and 430.46 is the result of implementation of HI #9644. Item 430 45 addresses engine prelubrication practices for manually initiated HPCS Diesel engine starts. The response to this item is no longer applicable as the result of HI #9644 since the j engine is. continuously prelubricated in accordance with c manufacturers' recommendations by the Circulating and Soakback Oil l Subsystems during standby conditions. Item 430.46 addresses the installation of an electric pre-lube pump which is accomplished as ; the result of implementation of MI #9644. As the result of this Change Request, the information discussed in these two Q&R items is now described in FSAR Section 9.5.9.4. Reflecting the current HPCS Diesel Lubrication System design, the deletion of these'two Q&R items is only an editorial change which has no effect on component or system reliability. The change to the description of the keepvarm cycle to further detail the process of varming the lube oil by the Jacket Water System does not involve a physical change. It is simply a clarification of the original design. This change in description has no physical effect on the equipment or its reliability. The change to the description of the location of the point in the Lube Oil System at which pressure is monitored by the cranking lockout pressure switch is a clarification and not a physical change to the original qualified design as supplied by the manufacturer. . Hence, this change has no effect on original equipment qualification ) or reliability. The function of the cranking lockout switch is not affected by this change either, as it still monitors main lube oil pump pressure. ; l
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<PY-CEI/NRR-0979 L Wl , ,
Page 131'of 278' M,' SE No.:: ..88-175 (Continued)' Summary . -(Continued) . Thel addition of)theidescriptions of'the engine driven lube' oil pumps is'a, clarification and'notfa' physical change to the original? qualified design as supplied by'.the, engine manufacturer. :These . I descriptions reflect the design shown'in FSAR Figure 9.2-25 which! , i was previously reviewed;and.. approved by the NRC. This change is-onlyr editorial in nature'and has no:effect.on the equipment r'eliability-or qualifications.of the HPCS Diesel Lubrication System.
. i LThe' change to the design codes'ofEthe Lubrication System piping is'. 1 entirely an editorial: change. Section 9.6.6'of Supplement #1 to NUREG-0887 " Safety Evaluation Report", details the. design codes:of.
lthe HPCS Diesel Lubrication System piping. -Table 3.2-1 of:the'FSAR
'is'being revised'as;part of-this'FSAR. update to reflect lthe details of the Safety Evaluation Report. .This change only clarifies the-design as; reviewed and approved by the'NRC and has no effect on the-reliability or qualifications of the HPCS Diesel Lubrication System.
.NoneLof these changes re' duce, equipment or. system reliability. . .
Hence,'the probability of occurrence of a malfunction of equipment as evaluated previously is unaffected. These changes' maintain the equipment and system reliability,'
~
'II. No. -s qualifications, redundancy, and function of.the originaltdesign. i 1Since no new type of design is! introduced:by these. changes and.all' of the original, design requirements are maintained,.no potential.for'
- l. a malfunction of a'different. type than any evaluated previously is 4 ' introduced.
III. No. The" margin of safety as. defined in the bases of Technical
' Specification Section 3/4-8' refers to.the reliability of the onsite power supply. .This' reliability is not compromised.by the' changes herein and hence the margin of safety is not' reduced.
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Attachm nt 3 PY-CEI/NRR-0979 L Page 132 of 278-SE No.: 88-176 Source Documents' DCF 87-0814, Rev. 0 Description of Change Remove the dry leg sensing line from the dryvell purge surge header level instruments in the Containment Vessel and Drywell Purge (M14) system and vent the level instruments directly to the containment atmosphere. This vill prevent water from being forced into the dry leg tubing during filling of the purge line causing incorrect level indication. Summary I. No. There is no probability of an increase in occurrence or consequence of an accident or malfunction of equipment important to safety previously evaluated since removing the tubing on the " dry leg" of instruments 1M14-N220A,B and 1M14-N221A,B will enhance the capability to monitor the water level in the surge headers in containment. Removing the tubing vill allow the dry leg to be taken directly from containment atmosphere rather than from the vent line of the surge header. The current configuration has allowed water to be forced into the dry leg causing inaccurate level indication in the surge header. II. No. The possibility for an accident or malfunction different from those previously evaluated is not increased because the design parameters which applied to the existing installation were taken into account in the evaluation of the removal of the tubing for the dry leg. This modification does not change the operation of the system or the l level instrumentation. III. No. This installation vill not affect the margin of safety defined in the bases of the Technical Specifications since the system's function has not been changed or reduced but has been enhanced. Removal of the. tubing for the dry leg on instruments IM14-N220A,B j- and 1M14-N221A,B vill allow the dry leg reference to be taken t .directly from containment atmosphere rather than from the vent line l of the surge header. This will allow more accurate level indication in the surge headers in containment. l 1
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" PY-CEI/NRR-0979{L l Page 133 of 278 d SE No.: 88-177
- Source Document: FSAR CR 88-205 la 4 DCN 2154 Description of ChangeL Change Master Parts List (MPL) numbers on drawing D-806-025 from i 1D17-N611A&B to iD17-N011A&B to correct a typographical error. .!
y . Summary, i I . No . . This.is.an MPL change on a.nonsafety instrument drawing. This'does ! not change / increase the probability of an accident as previously ! evaluated. 'i i The carbon bed vault radiation monitors are not used in the II. No. Chapter 15 FSAR Safety Analyses. The drawing MPL changes'do not
, create the possibility for an accident. j, III. No. The carbon bed vault radiation monitors are not required by Technical Specifications and are not defined in the bases. <
1 SE No.:~ .88-178' Source Documents: FSAR CR 88-126 Description of Change Evaluation of an FSAR change request to Chapter 15 which incorporates-various editorial comments as a result of the FSAR update review per 10 CFR-50.71. Summary i See Safety Evaluation 88-131. SE No.: 88-179 Source Document: FSAR CR 88-127
- Description of Change l Evaluation of an FSAR change request to Chapter 8 vhich incorporates !
various editorial comments as a result of the FSAR update review per ' 10 CFR 50.71 Summary- ; 1 See Safety Evaluation 88-131.
Attachmtnt 3 PY-CEI/NRR-0979 L :
; Page 134 of'278 SE No.: 88-180-Source Document: FSAR CR 88-043 Description of Change ;
Evaluation of an FSAR change request to Table 8.3-1 to revise the diesel loading description to accurately reflect all loads povered by the divisional diesels and the associated operating times. Summary I. No. This revision to Table 8.3-1 clarifies and summarizes all diesel generator supplied loads and their operating times. Extensive effort was done to consider the relationships of each piece of equipment with other system / equipment to determine the operating-time. All loads are on the bases of nameplate equipment ratings and equipment generally runs at less than nameplate. These table changes do not create or increase the consequences of an accident but merely define the diesel loading for a Loss of Offsite Power (LOOP) or Loss of Offsite Power LOCA combination. In addition, no new types of malfunctions can be created. The changes of starting time do not effect the plants capability to respond during any accidents within required. time limits. Automatically connected loads do not exceed Technical Specification requirements. ' If all connectable loads for the Division 2 bus (forced shutdown , column) are summarized, the results would indicate a total maximum ! continuous load greater than the continuous rating (7000 kW) of the standby diesel generator. However, not all of these loads are required to be operated at any one time or for any one scenario. ! Hany of the loads are manually actuated, redundant to other Division 2 loads or are only required for a particular scenario. The diesel generator system operating instruction (SOI) provides sufficient guidance to operators to prevent overloading the diesel generators. Visual indication (load limit line on kV meter) is also available on the control room panel to warn operators of the maximum diesel rating. No operating procedures require the energization of specific loads which would overload the diesel generator. The total connectable automatic Division 2 bus loading is significantly less ) than the die w U s maximum continuous rating. Table 8.3-1 also indicates a continuous Division 3 load of 2689 (forced shutdown) and 2660 (LOCA) which are greater than the continuous rating of the Division 3 diesel generator. Reoperation test data has shown that during rated flow conditions, (refer Figure 6.3-1) the actual High Pressure Core Spray (HPCS) pump load is approximately 2200 kV or less (as shown in Table 8.3-1, calculated nameplate load is 2397 kV). The preoperational test data l also indicated a narrow range of flow conditions which could j v - _ _ _ -
O - J , t I,, 'AttechmInt'3' .. l L . PY-CEI/NRR- 0979 L - [ Page 135 of 278! , SE No.: _88-180 (Continued) ; i L Summary (Continued) j p j cause HPCS pump load to exceed 2200 kV. However, these conditions ! are considered transitionary because they would normally be experienced only.while approaching or receding from rated flow.' .. Pump; flow and associated load during the accident modes described in Figure 6.3-1 would.'be bounded by approximately 2200 kW.. l Consequently,lthe maximum continuous load experienced for the HPCS diesel generator.would:be within.it's maximum continuous rating. This is documented in Note 19 of Table 8.3-1. Furthermore, the - shore-time' rating of.the Division 3 diesel generator (2860 kW) would accommodate this transitionary load. JAn additional issue ~ associated with the HPCS and RHR pump nameplate!
. loading figures (2397 and 729 kV respectively) should also be-addressed. Technical. Specification 4.8.1.1.2.e.2 requires in part,
'that the diesel generators be capable of rejecting a load greater than or equal to the~1argest single load (Division 2, RHR,.725 kW and Division 3,-HPCS, 2200 kW)-while maintaining speed less'than nominal speed plus 75% of the difference between nominal speed and' the overspeed trip setpoint of.15% above normal, whichever is less.
.(current surveillance requirements.use.725 kW and 2200 kW as the.
rejected load). The bases for this requirement refers to Regulatory Guide 1.9. " Selection,' Design and Qualification of Diesel Generator: Units.used as-Standby (onsite) Electrical Power Systems at Nuclear Plants". , The Reg. Guide' discussion originally intended for standby diesel generator states that this test is intended to prove that a standby diesel: generator can reject the largest single load supplied by the i generator and still maintain frequency within the specified band. This ensures that the diesel generator will continue to supply the: other' loads on the bus which may still be required to operate. i i As stated above, preoperational test data at-rated flow conditions indicated HPCS pump load at approximately 2200 kW. Preoperational test data has also shown that the RHR pump load at rated cond)tions j does not exceed 725 kW. The current test methodology using 2200 and ;
-725 kV is therefore satisfactory.
Additionally, in the case of the HPCS diesel generator, it's sole function is to support the HPCS pump. If the HPCS pump should trip, the HPCS diesel generator vould have no other design bases function. Consequently, whether or not the HPCS diesel generator maintains speed within a required band following the rejection of the HPCS pump is not significant to the safe operation of the plant. Consequently, the current design is in accordance with the applicable positions of Regulatory Guide 1.9, the existing accident analysis'and the margin of safety as described in the bases for the Technical Specification.
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Attcchmtnt 3 PY-CEI/NRR-0979 L L Page 136 of 278 i SE No.: 88-180 (Continued)
-l Summary.(Continued)
II. No. See Item I above. ] III. No. The margin of safety as defined in the Technical 1 Specification bases is.not reduced by these changes because sufficient ensite power vill still be available to supply the safety-related equipment required for (1) the safe shutdown of the facility and (2) the mitigation and control of accident conditions within the facility. SE No.: 88-181-Source Document: FSAR CR 88-104 l Description of-Change Evaluation of an editorial FSAR change request for Chapter 8 deleting those NRC Questions and Responses (0&Rs) which were not entirely ! t incorporated into the FSAR text. These Q&Rs are either already adequately discussed, contain information which is considered too detailed or,.no longer applicable. . I Summary I. No. The removal of these O&Rs does not affect the safe operation of the. l plant because the information contained in them, fell into one of-the categories discussed above. Consequently the change is considered editorial. !
.II. No. No new accidents or malfunctions vill be created since this change is editorial and information contained in these O&Rs is already adequately described in the FSAR text. ,
1
'III. No. These deletions have no effect on the bases of the Technical Specifications since no design changes or plant specific analyses ;
are being altered. j
Attachment'3 I FY-CEI/NRR-0979 L Page 137 of 278 SE No.: 88-182 Source Document: FSAR CR 88-125 { Description of Chr.nge Evaluation of an FSAR change request to Sections 6.4, 6.5, 6.7 and 6.8 which incorporates various editorial comments as a result of the FSAR update review per 10 CFR 50.71. Summary See Safety Evaluation 88-131. SE No.: 88-183 Source Document: PSAR CR 88-128 Description of Change Evaluation of an FSAR change request to Chapter 17 which incorporates various editorial comments as a result of the FSAR update review per 10 CFR 50.71. These changes include editorial clarification, deletion of redundant material, changes in titles of managerial positions (but no changes in responsibilities) and deletion of Q&Rs that have been previously incorporated. Summary See Safety Evaluation 88-131.
Attechm:nt-.3
- PY-CEI/NRR-0979 L Page 138'of 278 SE No. . '88-184 l Source Document: FSAR CR 88-129 l Description of Change Evaluation of an.FSAR change request to Section 6.2.7.1.1 and 6.2.7.3.3 to incorporate.the actual plant layout description of consequences of an ;
inadvertent Upper Pool dump. ) Summary I. No. The accident probability _ remains unchanged. _Veir vall overflow with.dryvell negative pressure, maximum suppression pool level, and an inadvertent upper pool dump would result in an approximate water , level of one foot-inside dryvell.. An analysis of piping components 'l which could become vetted has' demonstrated that this event could not-initiate a LOCA and therefore accident probability is not affected. J i The probability of m'1 function of equipment important to safety is not increased.- An analysis of components which would be vetted in i the event of-an inadvertent upper pool dump has demonstrated that. .j this event does not involve equipment important.to safety. ! l The. consequences of an accident.are not increased. The inadvertent upper pool dump which creates the possible weir vall overflow cannot -{' occur under accident conditions. The consequences of malfunction of equipment is not' increased. An analysis of piping components which would be vetted in the event of a dryvell. flooding transient from an inadvertent dump of the upper-pool (suppression pool makeup system) with the suppression pool at maximum operating level,- has demonstrated that this event could not , initiate a LOCA. Therefore, such a transient does not constitute a plant safety concern. II. No. .The inadvertent dump of the upper pool does not create an accident or malfunction of a different type since the analysis shows that potential vetted components do not constitute a safety concern.
'III. No. The Technical Specification margin of safety is not reduced.
Inadvertent dump of the upper pool is not related to Technical Specifications 3/4.6.3.4 or the Bases 3/4.6.3. l l-L
Attechmsnt 3' i PY-CEI/NRR-0979 L i Page 139 of 278 ' SE'No.: 88-185 i Source Document- FSAR CR 88-130 Description of Change Evaluation.of an PSAR change request to Section 6.2.7.1.c to incorporate Pre-Operational Testing data on minimum suppression pool vent coverage. Summary I. No. Accident probability remains unchanged. The suppression pool makeup l
. system is automatically placed in service following a LOCA.. Actual j vent coverage does not~ increase the probability of an accident.
The suppression pool makeup system is redundant and capable of supplying the required volume of water to'the suppression pool. Pressure suppression test facility test series 5701-5703 has demonstrated that the calculated l' - 8 15/16" minimum vent coverage ! is adequate for complete steam condensation and thus has no effect on Suppression Pool Makeup System performances. l The consequences of an accident are not increased. The actual calculated minimum-vent coverage has been shown to be adequate for complete steam condensation. ! The consequences of failure of equipment important to safety does not increase.. The suppression pool makeup system remains capable of supplying the required volume of water to the suppression pool. II. No. Notation of actual calculated minimum vent coverage does not deal with any new accident or malfunction. III. No. Margins of safety remain unchanged. The Suppression Pool Makeup System is capable of supplying the required volume of water to the i suppression pool. Testing has shown that complete steam condensation vill occur with vent coverage of l' - 8 15/16". j
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.:q Attachment 3 PY-CEI/NRR-0979 L- 1 Page 140 of 278 '
SE No.: 88-186' -l
. Source Document: FSAR CR 88-131 k
' Description of' Change i
Evaluation of an FEAR change request to FSAR Table 3.2-1, Equipment Classification to correct equipment locations, and to correct safety / quality /ASKE code classifications to those used to' design and build the plant. Summary I I. No. Changes to safety classification (2 to 3), quality group i' classifice. tion (B to C), and principal construction code subsection (2 to 3) of the air accumulator tanks'in the Nuclear Boiler (B21) system does not increase the probability of occurrence or the l consequences of an accident or malfunction of equipment important to safety. .The piping system and the accumulator tanks are Safety Class 3 built in accordance with ASME'Section III subsection ND.- l All sustained and occasional loads are accounted for in the system l design. The Safety Class 3 classification is consistent with ANSI /ANS 52.1 " Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants." 1 II. No. There is no possibility of an accident or malfunction of a different type as a result of changing the air accumulator tank safety classification. The system is designed in accordance with i
. ANSI /ANS 52.1 guidelines and ASME III subsection ND.
-III. No. The margins of safety as given in the Technical Specifications ,
remain unchanged by this change. The bases for the SRV's and the MSIV's (the two components which are supplied by the air accumulator tanks) are not affected as a result of the safety classification change. (Other changes are safety class / quality group /ASME code upgrades which improve integrity and reliability, thus improving margins of safety. ASME reclassifications are required by code definition and do not affect this safety evaluation.) l l l l
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.Page 141.of 278
'SE'No.: '88-187. . A.
-Source Documents- FSAR CR 88-132 ' .
]
Description of Change. h , Evaluation of an FSAR change request .to Chapter.13 which incorporates ] - various editorial' comments as a result of the FSAR' update reviev ;
.per.10 CFR 50.71.
1-Summary I See' Safety Evaluation 88-131. SE No.: 88-188 Source Document - .FSAR CR 88-133 Description of Change Evaluation.of'an FSAR change request to Section 3.10 which incorporates l
- various' editorial comments as a result.of the FSAR update reviev 1 per 10 CFR 50.71. l I
, Summary' See Safety Evaluation _88-131.
.i SE No.: 88-189 Source Document: FSAR CR 88-134
. Description of Change Evaluation of an FSAR cha'nge request.to Section 3.8 which incorporates various editorial comments as a result of the FSAR update review per 10 CFR 50.71.
Summary See Safety Evaluation 88-131. i { 1 I l
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;ci Att: chm:nt 3- I PY-CEI/NRR-0979 L I Page 142 of 278 SE No.: 88-190 Source Documents- FSAR CR 88-135 ;
)
Description of Change Evaluation of an FSAR change. request to Chapters 1 and 16.which incorporates various editorial comments as a result o01the FSAR update . review per-10 CFR 50.71. ! s i Summary, See Safety Evaluation 88-131. I SE No.: 88-191 Source Document: DCP 87-0504, Rev. 0 I Description of Change Replace.the existing: charge converters in the Loose Parts' l Monitoring (R63) system with new radiation hardened charge converters. , Rockwell, the vendor, suggested the changeout and supplied the converters. The existing charge converters were performing satisfactorily. Summary ; i I. No. Replacing the charge-convert'ers with the new radiation hardened -l charge converters will actually reduce the probability ef equipment malfunction. 1 II. No - The new charge converters vill not create any possible malfunction of a different type. The R63 system is designed for mor.itoring < functions only. 4 III. No. The margin of safety vill not be reduced and might be increased by using the.new charge converters. s I
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-l Attachmsnt 3 PY-CEI/NRR-0979 L Page 143 of 278 !
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SE No.: 88-192 Source Document: 'FSAR CR 88-119 i Description of Change Evaluation of an FSAR change request to Section 6.2.5, 6.5.3.1, 7.3.1.1.12'and Table 6.2-37 to reflect proper operation of the Combustible Gas (H51) and Hydrogen (M56) Control Systems. These changes were made to correct design parameters, eliminate excess detail, and clarify the systems' description and operation. i
-Summary N I..No. The purge system is designed as an alternative means of hydrogen control whose operation is administratively controlled (Chapter 7.3.1.1.11). The M51/M56 Plant Emergency Instruction (PEI) addresses proper operator action for all events. !
II. No. Correlations made reflect proper plant operation per.PEIs, thus no potential for a different type.of malfunction or accident has been ; created. 1 III. tio. Changes do not impact the required operability of the system thus no ! impact on the margin of safety within the Technical Specifications has been created. , I SE No.: 88-193 j Sou'W r Document: FSAR CR 88-136 i i Description of Change 3 i Evaluation' of: an FSAR change request to Sections 9.5.8.3, 9.5.9.5.3 and 9A.4.4.5.1.2.2 to delete'the portion of the text that pertains to the Chart Storage Room carbon dioxide extinguishing system. The Chart Storage Room use has changed and the system has been disabled. Summary I. No. The combustible loading of the chart storage room has changed so. that the CO extinguishing system is not necessary. The fire load has dropped2 from 7 hours to 35 minutes. II. No. There are no potential initiating causes of threats to the fuel or the reactor coolant boundary. j III. No. Only administrative aspects of fire protection are contained in the l Technical Specifications. l .in-__-____-__~-____ ., ._ = _ _ _ - _ _ _ _ _ _ __ _ _ _ _ _ _ _ _
I Attachmsnt 3 PY-CEI/NRR-0979 L-
, Page 144 of 278'
' SE No.: 88-194 Source Document g DCP 85-0295P, Rev. O I Description of Change
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Add a new J-header (J813) to-the Instrument Air System (PS2)-and add:new-branch lines from.the Two-Rod Demineralized (P21) System and ,
.P52 J-header (J806) to the new Spadone Unit'in the Tool Decontamination Room.
Summary , I. No. The only accident or malfunction discussed in the FSAR for.the Instrument Air System is the " Loss of Instrument Air" discussed in' i Section 15.2.10 and Section 15A.6'.3.3. The probability of 1 occurrence of this accident is not increased, since this addition to the system is comprised of welded stainless-steel piping of high
. reliability. The consequences of this accident remain the same, i.e., all safery-related equipment' fails'to a safe positiori (e.g.,
MSIV's close; turbine trips). There are no accidents or' malfunction discussed in the FSAR for the P21 Deminineralized Vater System (Reference Section 9.2.3 and Chapter 15). II. No. No new accidents or malfunctions are potentially created by these additions to the PS2 and P21 systems. The additions are basically i
- s. the same as the old system design, except for the use of'more q reliable materials and better on-line maintenance provisions (more system valving).
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III. No. Technical Specification bases do not address the P52 and P21 systems. i SE No.: 88-195
-Source Document: FSAR CR 88-137 Description of Change ;
Evaluation of an FSAR change request to Sections 6.1-6.3 which
-incorporates various editorial comments as a result of the FSAR update review per 10 CFR 50.71.
Summary See Safety Evaluation 88-131. s
Attachmsnt 3 I PY-CEI/NRR-0979 L Page 145 of 278' l SE'No.: 28-196 ! Source Document -DCN 2033 Description of Change-
-Remove (the alarm indication for the Reactor Core Isolation Cooling'(RCIC-E51) System valve 1E51-F076 as shown on the P&ID per this !
DCN. 4. Sunanary I ;I. No. Hardware modification was.previously performed per DCP 870123. This ! DCN only updates the piping and instrument diagram. Safety Evaluations 87-173 and 87-116 vere previously performed and approved for~this field modification. Equipment is not modified / changed by this drawing change. l Therefore, the consequences of failure of equipment important to i safety is not increased. II. No. The proposed clarification to the FSAR (Figure 5.4-9) would not create a new type of accident or malfunction. This change does not relate to events or disturbances that are considered potential initiating causes of threats to the fuel and/or the reactor coolant pressure boundary. ) p III. No. This change'does not reduce the margin of safety as defined in j Technical Specification 3/4.7.3. Technical evaluation of the ! hardware change where 1E51-F063 was modified'vith an "AC". operator and 1E51-F076 was changed to a normally closed valve were performed under Design Change Pcckages (DCP) 870123 and all of the supplement i DCP's,.A thru D. i i l i i l l 1 l t i (
Attachmsnt 3 l PY-CEI/NRR-0979 L Page 146 of.278 ) SE No.: 88-197 Source Document: -LL&JED 1-88-053 Description of Change l Removal of the high water level isolations for the'1A, 1B, 10, 2A, 2B and ' 2C feedvater heaters. These isolations were removed while troubleshooting / repairing heater 1 and 2 level controls to preclude loss of condensate flow. Summary I. No. The probability of occurrence and the. consequences of an accident are not increased since jumpers do not affect the cause or initiation.of a feedvater tube rupture. Proper control room indication and operator alarm procedures.are available to perform necessary actions to isolate feedvater heaters. (This FSAR reviev
. included Sections 10.2, 10.4, 15.1 and 15.2.)
II.-No. No accidents or malfunctions of a d!fferent type are created since adequate control room indications and procedures will result in proper actions to isolate feedvater heaters. III. No. No Technical Specification bases address feedvater heater condensate isolations. I f i 1 l l - _ _ _ _ - - _ _ ~ _
; l Attachmtnt 3 PY-CEI/NRR-0979 L Page 147 of 278
,, SE No.: 88-198 ,
Source Documents Condition Report 88-063 j 1 Description of Change l I Evaluation of Condition Report 88-063 which analyzed the effects of operation vith the Mixed Bed Distribution (P22) System contaminated. In accordance vith the guidance provided in I.E. Bulletin 80-10, the operation of P22 as contaminated must be evaluated relative to the limits in 10 CFR 20 and 40 CFR 190. Based on the current sample analyses of the system, no release of contaminated P22 vater to the environment via the Auxiliary Boiler was believed to have occurred. Summary I. No. The contamination of the Mixed Bed Distribution System vill have no ! impact on equipment important to safety.. This system provides no safety function and does not impact equipment important to safety. j Therefore, the item being evaluated has no impact. i II. No. Based on the isotopes detected, the malfunction that caused the contamination of P22 has already been evaluated under " Reactor Pressure Vessel Coolant Inventory Decrease". III. No. The mixed bed distribution system is not a Technical Specification-system, and therefore no safety limits or margins of safety are impacted. i l i 1 i
- - - _ - _ _ . - _ - _ . - _ _ _ _ - _ _ _ - _ _ _ - _ - - _ . _ _ - - _ _ ._ __ - _ = = __
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-Attachmint 3 PY-CEI/NRR-0979 L Page 148 of 278
.SE No.: 88-199
- Source Document: DCP 87-0338, Rev. O Description of Change Reroute the Service Vater System (P41) pumps (OP41-C001A-D) bearing water and pump motor cooler lines. Also increase the size of the supply !
header (P20) and bearing lines and change the bearing line material to stainless steel. This vill reduce maintenance by preventing clogging of the rubber bearings with silt. , Summary I. No. The P41 Service Water System, FSAR Section 9.2.7.3 (Safety Evaluation) does not address the pump bearing water or the motor cooler line, therefore there.is no increase in..the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety. The P20 Makeup Vater Retreatment System (Clearvell): FSAR Section 9.2.3 does not address any accident or malfunction of the clearvell portion of the P20 system, therefore there is no increase , in the probability of occurrence or the consequences of an accident ' or malfunction of equipment important to safety. 1 II. No. The.re-route and increased size of the nonsafety-related piping is designed'to ANSI B31.1 piping code and is not anticipated to fail. ! If failure were to occur, the piping is located in the Service Water Pump House and would not impact any safety-related components. III. No. The P20 (clearvell) portion of the system is not addressed in the Technical Specifications. The P41 system vill not affect the Technical Specifications (bearing water). i
Attachment 3 PY-CEI/NRR-0979 L Page 149 of 278 SE No.: 88-200-Source Document: FSAR CR 88-140 Description of Change Evaluation of an FSAR change request for deletion of various NRC Questions and Responses (0&Rs) to Section 3.6, 3.11, 5.2, 5.4, 6.5, 9.4, 10.2 and 10.4 that were not incorporated as a result of the FSAR update review per 10 CFR 50.71. ' Summary I. No. No accidents or malfunctions involved. Non-incorporation of Q&Rs due to the level of detail, information already in the text, etc. II. No. No new accident or malfunction involved. III. No. No Technical Specification margin of safety involved. _____ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - -- --' - - - - ~
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- e. Page 150 of 278 SE'No.:- 88-201 Source' Documents- DCP 87-0204,.Rev. 1 Description of Change Revire'the torque switches on Reactor Core Isolation Cooling (RCIC) <
zsystem motor. operated valve (MOV) lE51-F0078. Whenever field cables are i. terminated or determinate to remove or reinstall the torque switches.for balancing, the calibration on the torque switches _is disturbed. This . modification terminates the field cables on a spare. limit switch terminal and installs j' mpers u to the torque switch. j Summary' I. No. Field cables are normally.directly connected to the Torque Switches on MOV Operators. Whenever these cables are terminated or determinate to remove or reinstall the Torque Switches for balancing, theLcalibration on the Torque Switches is disturbed. To resolve.this concern EDCR/DCP 870204 was generated to install a Torque'Svitch Bypass' circuit using Limit Switch contact LS-1/2. This modification requires field cable to terminate on a spare limit j switch terrainal and installs jumpers.to the Torque Svitch. Thus I whenever the Torque Switch is removed for balancing, the wire termination at the Torque.Svitch terminal is not disturbed. Addition of this Limit Switch contact in parallel with the Torque Switch does not constitute any functional change to the valve open/close circuits. The probability of occurrence or the~ consequences of an accident or .i malfunction of safety equipment previously evaluated in the FSAR is not affected. This modification vill also not affect the possibility for an accident or malfunction of a different type than any evaluated in the FSAR. II. No. See Item I above. III. No. This change does not affect the margins of safety in the Technical l Specifications. l l i
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Attachmsnt 3 'j PY-CEI/NRR-0979 L ' Page 151 of 278 SE No.a. 88-202 Source Document: DCP 87-0204A, Rev. 1 ! Description of Change Revire the torque switches on the Main Steam (B21) system motor operated valve (MOV) 1821-F0016. Whenever field cables are terminated or determinate to remove or reinstall the torque switches for balancing, the calibration on the torque switches are disturbed.. This modification l terminates the field cables on a spare limit switch ~ terminal and installs jumpers to the torque switch. Summary See Safety Evaluation 88-201. f SE No.: .88-203 Source Document: DCP 87-0204B, Rev. 1 Description of Change ! Revire the torque switches on Residual Heat Removal (RHR-E12) system 1 motor operated valves (MOV) operators 1E12-F0073B, F0074A and F0074B. Whenever field cables are terminated or determinate to remove or reinstall the torque switches for balancing, the calibration on the torque switches is disturbed. This modification terminates on a spare
'., limit switch terminal and-installs jumpers to the torque switch.
Summary See Safety Lvaluation 88-201. I I I l
l 1 Attachmtnt 3 .I PY-CEI/NRR-0979 L i Page 152 of.278 j SE No.: 88-204- l 1 Source Document: DCP 87-0204C, Rev. 1 j Description of Change Rewire the torque switches on HSIV Leakage Control (E32) system motor operated-valves (MOV) operators 1E32-F0001A, F0001E and F0001N. Whenever ) field cables are terminated'or. determinate to remove or reinstall the '
'f torque switches for balancing, the calibration on the torque switches is I disturbed. This modification terminates on a spare limit switch terminal.
and installs jumpers to the torque switch. Summary 1 See Safety Evaluation 88-201. I SE No.: 88-205 ! Source Document: FSAR CR 88-141-Description of Change Evaluation of an FSAR change request to THI Action Plan, Table 1A-1. This change eliminates the implementation schedule and notes from this table within the USAR (as the implementation is complete and notes have been incorporated into the table where appropriate). i Summary I. No. This change is editorial and does not add or remove any information which could affect the accident analyses described in the FSAR. II. No. This change neither adds nor removes information pertinent to the design or operation of the plant. III. No. This change neither adds nor removes information used in the bases of.the Technical Specifications. 4 t
1 3 Attachmsnt 3 PY-CEI/NRR-0979 L Page 153 of 278- 3
-l SE No,'s. .88-206 ' '
- Source ~ Document: DCP 86-0346, Rev. 0 '!
FSAR CR 88-143 Description of Change
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Evaluate an FSAR change request to update FSAR Figures 7.4-1,(Sheets 1 , and 5 of 5) to reflect-DCP 86-0346. This DCP replaced keylocked Reactor. 1 Core' Isolation Cooling (RCIC) Isolation Logic reset switches with pushbuttons (due to key breakage encountered at Grand Gulf) and deleted annunciator vindows for "RCIC Logic A&B Isolation: Reset" on panel 1H13-P601-21A. Summary. I. No. The RCIC Isolation Logic reset switches have been changed from keylock to pashbutton due to the possibility.of key breakage. Key-breakage had been encountered at Grand Gulf. The overall-function of the switch is not changed.- This. change is consistent with the GE- . design intent that keylocked switches will be used only when the I control:svitch performs.the infrequent bypass of a safety function or test. function. Because the switch is momentary instead of-maintained the annunciator vindows indicating.that the switch is in reset position are no' longer required and-have been. deleted. There is no effect on safety. II. No.- See Item I above. III. No. Technical Specification bases Section 3/4.3.5, does not describe switches or annunciators in the Control Room. 4 SE No.: 88-207 Source Document: DCP 86-0539, Rev. 0
.FSAR CR 88-142 Description of Change
-Revise the torque switches on Reactor Core Isolation Cooling (RCIC-E51) system motor operated valves (MOV) operators'1E51-F0019, 1E51-F0077 and MSIV Leakage Control (M32) system MOV 1E31-F0001J. Whenever field cables i are terminated or determinate to remove or reinstall the torque switches l for balancing, the calibration on the torque switches is disturbed. This l'
modification terminates on a spare limit switch terminal and installs jumpers to the torque switch . Summary- i i See Safety Evaluation 88-201. L
Attachment 3-PY-CEI/NRR-0979 L ' Page 154 of 278 SE No.: 88-208 } Source Document: FSAR CR 88-145 Description of Change Evaluation of an FSAR change request to update Figure 6.2 Containment and Dryvell Isolation and Table 6.2-35 to agree with the plant as-built configuration. Summary I. No. Revision to Figure 6.2-60 of the FSAR to more clearly indicate the plant as-built configuration. No plant equipment is changed via this figure update. . Arrangements comply with General Design Criteria for Containment Isolation. Figure arrangements are in agreement with the ISI classification Boundary Diagrams (SS-305 series). Therefore, the probability of occurrence or consequences of an, accident or malfunction of equipment important to safety remains unenanged. II. No. Figure 6.2-60 of the FSAR is being updated to reflect present P&ID s configuration. Safety class boundaries for Containment Isolation
.are in compliance with General Design Criteria. Therefore, the l possibility for an accident or malfunction of a different type than previously evaluated is not created.
III. No. Technical Specification bases for Containment Isolation remain' unchanged. Reference 3/4.6.4. SE No.: 88-209 l Source Document: FSAR CR 88-144 Description of Change Evaluation of an FSAR change request to make various editorial changes to l Section 6.2.4 of the FSAR as a result of the update review per ' 10 CFR 50.71. Summary See Safety Evaluation 88-131.
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Attschmsnt 3 PY-CEI/NRR-0979 L Page 155 of 278' ! SE No.: 88-210 _
, Source Document's FSAR'CR'88-146-
' Description of Change
~H
' Evaluation of an FSAR. change request.to. update Table 6.2-32, containment Isolation Valve Summary to agree with the plant as-built configuration.
Summary' '
- I.'.No. No plant equipment is changed via this Table update..'The table
'still complies with General Design' Criteria for_ Containment! '
Isolation and ISI Classification Boundary Diagrams _(SS-305 series). h; Therefore, the' probability of occurrence or the consequences of an-accident or malfunction of equipment important to safety remains. unchanged. II. No. Table 6.2-32lof the FSAR is being updated.to reflect.the present_ P&ID configuration . The updated Table remains in compliance with General Design Criteria for Containment Isolation. Therefore,.the ; possibility for an accident or malfunction of a different type'than i
.previously evaluated is not created.
III. No. The Technical. Specification bases.for Containment. Isolation remain unchanged. Reference 3/4.6.4 SE No.: 88-211 1 Source-Document: DCP 86-0629, Rev. ,. Description of Change Conversion of Unit 2 Inservice Inspectiori Equipm' nt e Room on Elevation 654' into the measuring and-test equipment (M&TE) Hot Shop. However, this creates an editorial change in the FSAR since room titles appear on FSAR figures, but these room uses are not addressed within. Summary-I. No. A room description (use) change (editorial change) has no effect on the safety of the plant. No equipment malfunctions or accidents can 1 be caused by editorial changes. II. No. A room description change is an editorial change. Editorial changes do not create accidents or malfunctions different than any evaluated. III. No. Specific room descriptions are not addressed in the Technical l Specifications. I
Attachment 3 I
~.PY-CEI/NRR-0979 L.
Fage'156 of 278 SE No.:; 88-212
' Source Documents :SCR l-88-001-T.
Description of Change 'l i
;. l L
Temporary'setpoint change to increase the 1B21-R614 Recorder Safety l Relief. Valve'(SRV) Leakage High Temperature Alarm Setpoint. j
. Summary I.1No. Incorporation of this Temporary Setpoint Change to raise the-nonsafety high temperature alarm:setpoint does not affect any safety analysis reflected in FSAR Chapters 5, 6 or 15.. ,
2 The recorder used to monitor SRV Leakage Temperature (1B21R0614) is 1 unaffected and' vill continue to track SRV discharge pipe temperature L for all 19 channels. Increasing.the leakage high temperature alarm i setpoint could be considered an improvement to plant operation', as it eliminates _the distraction,of a continuous alarm due to SRV veepage.; It'is'also noted that safety-related SRV tailpipe pressure vindication is unaffected by the. temporary SCR.
'It is.concludedEt hat the probability of occurrence and/or the
~
consequences of an accident or malfunction of safety-related equipment previously evaluated in the FSAR.is not increased.. II. No. The scope of this Temporary SCR is; limited to the SRV Leakage High
?
Temperature Alarm described above. No other systems or components-are affected. A different type of accident or malfunction than previously evaluated in the FSAR is not created. ! III. No. The: Technical Specifications and associated' bases do not address the
-SRV Leakage'High Temperature Alarm setpoint nor alarm function. The margin of. safety is-thus not reduced.
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- PY-CEI/NRR-0979 LL i y .Page 157;of 278: <
SE NO.: 88-213-p ; Source Document: DCN 2166 . ;
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, . Description of. Change -
ql 1 1 DCP'85-315 did not~ remove valve 1P33-F722 yet it was inadvertly rbmoved
~
n[ from thefP&ID corresponding to FSAR< Figure 9.3-23. ~This DCN corrects I this error. Summary I.'No. ..DCN has no impact on'present configuration of the pla'nt and therefore does not impact the probabilities of~an accident or- q equipment' malfunction,
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o lII. No. .DCN updates' design documents and has no impact on the present configuration of the plant and therefore does not impact the. possibility of:an. accident or malfunction. III. No.' Technical Specifications are not affected by this change. q SE No.: 88-214 Source Document: DCN 2174-Description of' Change a Correction of'theLerroneous system. designator on P&ID D-302-606
-(corresponding to FSAR Figure.5.1-3) per FCR 8562.
Summary; I . No . - This DCN removes incorrect C33 system designator from1 this P&ID and replaces with-the correct C34 system designator.. It does not increase the probability'of an accident' or malfunction of equipment important to safety. II. No. This DCN simply updates a drawing. No possibility of a different-type of an accident / malfunction is created by this change. LIII. No. .The margin of' safety as defined in the bases'for any Technical
. Specification is not reduced by this DCN, as this is a minor editorial correction to the drawing. .. ; ; ;r , -c
E i Atttchm:nt 3 ' PY-CEI/NRR-0979 L ! Page 158 of 278 SE No.: 88-215 Source Document: DCP 87-0803, Rev. O i Description of Change Installation of a door in the vall between the Operations Support
-Center (OSC) Conference Room and the Health Physics Office on i Elevation 599' in the Control Complex. '
Summary I. No. The installation of a door in an architectural nonsafety, nonseismic vall between 2 offices will not affect the safety of the plant., II. No. The installation of this door vill not create a different type of accident or malfunction. III. No. The installation of this door vill not reduce the Technical ' Specification margins of safety. \ \ l i l SE No.: 88-216 Source Document: LL&JED 1-88-058 Description of Change Jumper the limit switch from the High Pressure Core Spray (HPCS) to Condensate Storage Tank (CST) Second Test Return Valve, 1E22-F0011 which prevents the HPCS Suppression Pool Suction Valve, 1E22-F0015 from opening when 1E22-F0011 is not fully closed. q Summary i I. No. The HPCS Suppression Pool suction valve, IE22-F015 is prevented from 1 opening by use of its associated valve control switch if either test return valve to the CST, IE22-F010 or F011 is not fully closed. The l reason for this is to assure that water taken from the Suppression ! Pool vil'1 not be discharged from the HPCS pump into the CST., j Transfer of Suppression Pool water to the CST will still be ' prevented by the 1E22-F010 valve even if the limit switch from the 1E22-F011 valve is jumpered. Discharging Suppression Pool water to the CST is not discussed as an accident in the FSAR and does not ' increase the probability of a design basis accident. 1 I II. No. Discharge of Suppression Pool water to the CST vill still be ! prevented by the remaining interlock on 1E22-F0010.
)
III. No. Lovering Suppression Pool level by using the HPCS pump vill still be i prevented by 1E22-F0010. i
I l Attachm:nt 3 PY-CEI/NRR-0979 L i Page 159 of 278 SE No.: 88-217 l Source Document: DCP 87-0569, Rev. 1 l Description of Change This design change installs radiophones at the Rad Vaste Control Room (RVCR) and at the Technical Support Center (TSC) CEI-dose assessment area. It also replaces the 39.58 MHz Lake County Sheriff's radio with an 800 MHz radio for a direct link with their E0C. Summary I. No. The radio system is a nonsafety system and a malfunction of this equipment will not cause an accident. Upgrading the radio link to - the Lake County Sheriff's Dept. from a 39.58 MHz to an 800 MHz radio link improves the reliability of the link due to better equipment technology. A malfunction of the two additional radio phones or the 800 MHz link vill not affect the operation of the existing radio phones or the plant radio system. The radio phones are stand alone units with separate power supplies which interface with the plant radio system for receipt and transmission of radio signals only. The 800 MHz link equipment is separate from the plant radio system. Therefore, i the reliability of the radio system or any other equipment important to safety is not affected. II. No. A malfunction of the 800 MHz radio link and two additional radio phones will have the same consequences as failure of the 39.58 MHz ! radio link and other radio phones. The malfunction vill affect only those components of the entire communication system. Therefore, the possibility for an accident or malfunction of a different type than ' previously evaluated in the FSAR is not created. III. No. There is no change to the Technical Specifications by review of Section 3/4.9.5. i l Q i
Attachment 3 PY-CEI/NRR-0979 L Page 160 of 278 SE No.: 88-218 } Source Document: NR PPDS 3135, Rev. O DCN 2149 Description of Change 1 The scope of this design change is as follows: j The "use-as-is" portion of this design change consists of exchanging the ; sensing lines between the Standby Diesel-Generator Lubrication System l lube oil filter differential pressure switch (1R47-N040A and 1R47-N040B) ; and the lube oil strainer differential pressure switch (1R47-N045A and 1 1R47-N045B). This design change is accomplished by DCN #2149 to document the as-built system configuration. The "use-as-is". portion also includes leaving the strainer differential pressure alarm setpoint at 20 psid. The pressure switch which annunciated this alarm measures differential pressure across both the lube oil filters and strainers; and is subject to spurious alarms as a result. The " repair" disposition of NR PPDS-3135 Revision 0 consists of an interim setpoint change tn the lube oil strainer differential pressure switch (1R47-N045A and 1R47-N045B). This interim setpoint change is made to accommodate the temporary "use-as-is" design which actually measures lube oil strainer differential pressure across the lube oil filter and the lube oil strainer, and is implemented to eliminate the resulting spurious alarms. The above setpoint change is described as interim since the setpoint vill be returned to its original value when the design is restored to its original design intent. This design change is accomplished via EDCR 88-0069 and will be evaluated for 10 CFR 50.59 Applicability separately, not in this Safety Evaluation. Summary I. No. The design change which exchanges the instrument sensing lines between the lube oil filter differential pressure switch (1R47-N040A and 1R47-N0408) and the lube oil strainer differential pressure switch (1R47-N045A and 1R47-N045B) has no effect on equipment reliability for the following reasons: A. The design and qualification of both pressure switches is identical as they both have the same manufacturer's part number, B. The design and qualifications of the tubing and supports for each sensing line is in accordance with the requirements of the original design as described in the FSAR,
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PY-CEI/NRR-0979:L ' Page.161.of 278- ! g^ SE No.: 88-218 (Continued) Summary (Continued):: '; 1
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C. ;The system design parameters such as temperatureand pressure 1 for both sets of sensing.. lines are' identical. '. Leaving'the setpoint of the lube oil strainer differential pressure 1; switch at-20'psid has no. impact on;the reliability'of the. switch 1 itself as'the original design parameters of the switch are l maintained. : The reliability of the Standby Diesel- Lubrication System is not'affected since this alarm performs no active safetyK 1 function to support Diesel-Generator or lubrication system operability. Hence with respect to tubing and equipment designs, not including function, the "use-as-is" configuration and the " designed" configuration'are identical. Therefore, reliability and qualification oftthe "use-as-is" design.is equivalent to that of-the original design. '
.The setpoint change to the lube oil strainer differential pressure.
.svitch is-'to:be performed in accordance with manufacturer's requirements;and is vithin the documented operating pressure rating of the switch. .Hence, this-change has no effect on the reliability or qualification of this pressure switch.
None of:these changes affect the reliability or-qualifications of the original design. Hence the probability of a malfunction of equipment' evaluated previously'is unaffected. i The pressure switches / gages affected by the' subject changes; perform no active. safety function.to support the mitigation of the consequences of an accident evaluated previously. The safety function of the affected portions of-the Standby Diesel Lubrication System design is passive, that1is only'to maintain pressure boundary. This function is ensured as demonstrated above by the maintenance of original design-construction standards and ! maintenance of. equipment reliability and: qualification. i Additionally,-these changes do not compromise' established redundancy !
' within each Standby Diesel-Generator Lubrication System or between redundant divisional Diesel-Generators, as no cross-ties are added between redundant' components, circuits, or divisional 3 j
-diesel-generators. Hence in the event of an accident, the response '
of the plant te W '. gate its consequences vould be unchanged with respect to thes, & ign changes, and the consequences of an accident would be unchanged also.
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-PY-CEI/NRR-0979 L.
Page~162 of 278-
- SE No.:: L88-218 (Continued)
Summary'(Continued)' The setpoint.of-'the' strainer-high differential pressure alarm.is: currently conservative.with respect to the intended original design.
~This is due to the fact that this pressure switch monitors-differential pressure-across both the filters-and strainers and.th'e setpoint only reflects allovable differential' pressure.:acrossithe:
-strainer.'
.The~ repair' disposition implements a setpoint change which accounts for normal operating differential pressure across-the strainers.
This change eliminates the built-in conservatism which is the1 result'.
.of the original setpoint- and the as-built sensing line configuration. Hence, the strainer differential pressure alarm will 4 accurately monitor-filter differential pressure.in accordance with I original design parameters.
- II. No. . These changes maintain the' equipment and system reliability, qualifications, and redundancy of the original design. -Other than lubrication system alarms, the function of the original design has.
been maintained also. .'Since no new-type of. component or e " construction standard is introduced by these changes and all'offthe q original design requirements have been maintained, except.for filter ! and strainer alarm functions, no potential for~a malfunction of a l
'different type-than any evaluated previously is introduced.by the subject changes.
III. No. The margin of safety as defined in the bases of Technical ! Specification Section 3/4-8 refers to the reliability of.the onsite power supply. As demonstrated above, this reliability-is not compromised by the changes herein and hence the margin of safety is^ not reduced. 'l l l I
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'I Attachment 3 PY-CEI/NRR-0979 L Page 163 of 278
'SE No.: 88-219 Source Document: DCP.87-0299, Rev. O Description of Change 1 Expand'the-Public Address (PA) system into the Maintenance Building. Extend the Intra-Plant Communications (PA-R51) system trunk line from ]
.{
SVPH-OR51J015 to the Maintenance Building.0R51J016 (new) and add j handset / amplifiers / speakers to the following areas:- shop area, i lunchroom, plant helper supervisors' office, M0 VATS office. -i. Summary I. No. The purpose of this RS1 system change is solely for expansion of the PA system into the Maintenance Building (MB or MB100). The expansion of this system vill not increase probability of-the items stated within this question, since this system is not and will not become (due to this change) a functional part of any safety shutdown equipment, nor does it deteriorate from safety evaluated in FSAR 9.5.2. l II. No. Any expansion of this system increases coverage of PA ! communications. This includes fire, evacuation, and R53 exclusion area alarms / announcements. Therefore, the possibility of accidents of different types are further prevented. This expansion does not interconnect to any additional systems; therefore, malfunctions of different types vill not be created. III. No. This R51 system change does not affect the Technical Specifications as described in 3/4.9.5, therefore the margin of safety is not reduced. i i
^* Attachmsnt PY-CEI/NRR-0979 L Page 164 of 278 SE No.: 88-220 Source Document: DCP 86-0921, Rev. O Description of Change Additional switches will be added to' Leak' Detection (E31)' system recorders 1E31-R608 (1 switch) and.1E31-R611 (2 switches: one to be used- , and one spare) to separate:svitch inputs with different setpoints. :The '
' inputs will go to the same annunciator as before. Reactor Vater
_ Cleanup (RWCU) demineralized will not be'svitched, but will continue to be recorded. This is a revision.of recorder;setpoints to have them agree-with calculation E31-C14/4.- Summary-1 I. No. The switch additions to the recorders will separate two alarm ! setpoints, thus alleviating two nuisance alarms in the Control Room. ! The recorders are used to record and alarm on high equipment room l temperatures. The RVCU Demineralized inputs have no isolation setpoints, therefore, they should not have an alarm output from recorders 1E31-R608 and R611.. However, the recorders will still record temperatures for these areas when in the scan mode. Deletion of'the RVCU Demineralized inputs from switch 5'(R608) and switch 2 1 (R611) vill have no impact on the recorder's performance. j l Operation of the new switches vill be similar to others that are already an integral part of the~ recorders. .Since these switches ] L only alarm, they have no safety function, so their failure vill not 1 increase the probability of an accident. The failure of these j
. switches-vill not degrade the recorder performance; therefore, the '
probability of malfunction of equipment important to safety is not l increased. { II. No. .These new cvitches are similar to others already, installed.in these q recorders, and were previously evaluated. No'new accidents or malfunctions vill be created. III. No. These switch alarm points and recorders are not part of the Technical Specifications. ; 1 i
Attachment 3 PY-CEI/NRR-0979 L Page 165 of 278 SE No.: 88-221 Source Document: PAP-0507, Rev. 7, " Review and Approval of Instructions" Description of Change A programmatic change that allows delaying the performance of periodic reviews of instructions by placing instructions "on hold", thus precluding them from use until the required periodic review is completed. FSAR Chapter 1 endorses Reg. Guide 1.38 which endorses ANSI N18.7 which states that plant procedures shall be reviewed no less frequently than every two years. Summary I. No. Use of documents which have not been reviewed within two years vill be prevented until the review is complete. Therefore, the probabilities as evaluated in the FSAR do not increase. II. No. Same as Item I above. III. No. This change does not affect the margin of safety as defined in the bases for any Technical Specification. SE No.: 88-222 Source Document: DCP 87-0529 Description of Change Remove all M0V space heater spare circuits (Penetrations - Electrical, R72) at their supply source for safety purposes. Summary I. No. This change does not create or involve any type of accident or malfunction because these spare circuits serve no function. II. No. See Item I above. III. No. Removal of all spare circuits from Technical Specification Table 3.8.4.1-1 does not reduce the margin of safety, since these circuits were spare and served no function. 1
4 Attech~ ment 3 : PY-CEI/NRR-0979 L 1 Page 166;of 278 j SE No.: 88-223 Source Document:. DCP 87-0773A, Rev. 1 Description-of Change '
. Revise DCN to eliminate an additional fire hydrant incorporated in Rev' O for the underground Fire. Protection System (P54) for the Maintenance Support Facility. i f
Summary I. No. The operating condition of.the underground fire protection water supply is not changed. The requirement for approximately 50 ft spacing.between hydrants as stated in the FSAR is maintained. II. No. See Item I above. This change does not impact margins of safety as defined in the
~
.III. No.
Technical Specifications. -'
.SE No.:~ 88-224 Source Document: LL&JED 1-88-062 Description of Change Remove the Channel 8' vibration and loose parts monitoring (V& LPM) input alarms to prevent continuing erroneous loose parts alarms, in order to 4 maintain Loose Parts Honitoring System operability.
Summary I. No. The loose parts alarm is nonsafety. A sufficient number of channels' remain to provide indication of an accident or malfunction of ' equipment important to safety. II. No. The 9 remaining channels are still operable and meet all R.G. - 1.133 requirements for loose parts detection. i I III. No. Technical Specification B 3/4.3.7.8 references R.G. - 1.133 which references V&LPH setpoints. Nine channels still operate. This meets R.G. - 1.133 requirements. Therefore, the margin of safety in the Technical Specifications is not reduced. ; I I i
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Attechment 3 PY-CEI/NRR-0979 Li Page 167 of 278 SE No.: 88-225' Source Document - DCN 2202
-Description of Change Incorporate HPL number for valve IP22-F0637'(Mixed Bed Demineralized System) on drawing D-302-713, .which was not there previously. l Summary I. No.
This is an editorial. change.to a drawing and does not impact any I equipment important to safety. II.-No. -See Item I above. III. No. The Technical Specifications are not affected by this change. SE No.: 88-226 Source Document: DCN 2188 FSAR CR 88-209 Description of Change Correct a. typographical' error for an HPL number on drawing D-302-871 (FSAR Figure 4.6-5, Sheet 1) where 1011-F0112B is identified as 1C11-F0112P. Summary l I. No. Correcting a typographic error for an MPL number has no physical impact ion the plant, nor does it impact the probability of1 occurrence or consequences of an accident or malfunction. j II. No. Correcting a typographic error.for an MPL number so it matches the ! actual configuration does not create the possibility for.an accident I or malfunction not previously analyzed. III. No. A nonsafety valve MPL number (and its correction on an FSAR figure) has no impact on Technical Specifications, nor is it part of the Technical Specification bases. {
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'Attachmant 3 PY-CEI/NRR-0979 L-Page 168 of 278 d
SE No.: .88-227-Source Document: 'DCP 87-0515,'Rev. 0
. Description of' Change Add an annunciator'for' Condensate Storage Tank (CST) "high level" to i panel 1H13P0870 and revise the CST supply valve closure setpoint.
Summary JI.'No. .FS/2 Section 9.2.6 states that at least 150,000 gallons of CST i holdings must be available-to support operation of RCIC and HPCS. Addition of a CST high. level annunciator in PGCC does'not affect this minimum requirement. Additionally,~ changing the normal CST fill cycle cutoff to the 300,000 gallon level vill not affect the CST minimum level condition. The modifications of existing
' instrument loops have no impact on the malfunction of equipment required for safety as postulated in the FSAR.
II. No. The design intent and operation of the condensate transfer and - storage system remain unchanged with the modifications of existing. instrument' loops. The possibility for an accident or malfunction not previously accounted for in the FSAR has not been increased. III. No. Technical Specifications 3.5.2.e.2 and 3.5.3.b.3 address minimum CST
' levels required to support operation of RCIC'and HPCS. This change does not affect low level instrumentation, interlocks or alarms.
SE No.: 88-228 Source Document: DCP 87-0357, Rev. O Description of Change Stabilize / secure miscellaneous items on elevation 689'6" platform inside containment to preclude undesired movement during a seismic-event. ; i Summary i I. No. The added loads on the containment vessel are within the allowable ' design limits and therefore the probability or consequences of an '
. accident are not increased. !
II. No. Since the additional loads are within the allowables, the possibility of an accident or malfur.ction not previously evaluated ! is not created. III. No. This is not a functional change, and the Technical Specification f margins of safety are not affected. 1
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^PY-CEI/NRR-0979 L Page 169 of 278-SE No.: 88-230'
. Source Document: DCN 2183 di Description of Change Change! description of FSAR Table 8.3-8 (HPCS Diesel,' Diesel Breakers, Alternate Preferred Supply Breakers Logic Diagram, Division'3) for unused, breakers.from " spare" to " future".
Summary-I. No. These breakers are not used. The status change does not affect plant safety, ru) operating equipment is, involved. < II. No. This DCN'does'not increase the possibility of.an accident or malfunction.because no operating equipment is involved.
.III. No.
Since there are no loads on these breakers, no margins of safety are i reduced.
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Attachment 3 PY-C3I/NRn-0979 L Page 170 of 278 SE No.: 88-231 Source Document: NR NEDS 3223, Rev. O Description of Change Evaluate the use-as-is disposition for the HPCS diesel fuel oil priming pump / motor assembly, since the nameplate data (1/4 hp pump) does not agree with the design documents or FSAR Section 9.5.9.1 (3/4 hp pump). Summary I. No. The function of the HPCS diesel is not affected by this nonconforming condition. The existing design with the 1/4 hp fuel oil priming pump has been demonstrated by preoperational and surveillance testing to meet all design requirements necessary for the HPCS diesel to perform as described in the FSAR. Since the function of the original design and the qualification of equipment has been maintained with respect to the original design as described in the FSAR, reliability of the original design has not been impacted adversely. Therefore, the probability of occurrence of a malfunction of equipment evaluated previously remains unchanged. There is redundancy between the engine driven fuel oil booster pump and the subject motor driven fuel oil priming pump, and this redundancy has not been compromised as the result of this nonconforming condition. In the event of a malfunction of equipment, the response of the HPCS diesel generator would be unaffected, and thus the consequences of that malfunction would be unchanged. II. No. No possibility for a malfunction of a different type is created by this nonconforming condition as the existing design still conforms to the original design codes / standards. Hence no new type of design is introduced by this nonconforming condition to introduce a possibility of a malfunction of a different type than evaluated previously. III. No. The margin of safety as defined in Technical Specification Section 3/4.8 refers only to the reliability of the onsite power supply. The reliability of the onsite power supply is not affected adversely by this nonconforming condition. Hence, the margin of l safety is unchanged.
Attachment 3 PY-CEI/NRR-0979 L Page 171 of 278 SE No.: 88-232 Source Document: DCN 2201 1 Description of Change Delete drain valves N21-F701A,B, N21-F221, and N21-F222 from the Condensate System (N21) P&ID and isometries to show as-built conditions to allow removal of HFI's. Summary I. No. The probability and consequences of accidents and malfunctions evaluated in the FSAR (Ref. Table 10.4-2) remain unchanged. The probability on a pipe break is not increased by this change. II. No. No new accidents or malfunctions are created by this change, since the system is functionally the same for normal plant operations. The only difference is that draining the system for maintenance during an outage is slightly more difficult. III. No. The Technical Specification bases do not address the Condensate System. Also, there are no indirect effects on any bases caused by this change. SE No.: ~~ 88-233 Source Document: LL&JED 14-063 DCN 2198 Description of Change Finalize routing of circuits to the Maintenance and Calibration System (R52) 12 channel handset / amplifier, located in the Control Room at the Supervising Operator Station. Summary I. No. Since the addition of a 12 channel handset / amplifier vill enhance the Maintenance and Calibration System (R52) by allowing the Control Room greater flexibility in monitoring communications, it therefore cannot increase the probability of an accident or malfunction of equipment as outlined in Chapter 15 of the FSAR. II. No. The malfunction of the 12 channel handset / amplifier would not disrupt the utilization of the communications system. A different type of malfunction than previously evaluated in the FSAR is not created. III. Nn. Since the addition of a 12 channel handset / amplifier enhances the design features of the RS2 system, it therefore would not reduce the margin of safety as defined in the bases of the Technical Specification (Ref. 3/4.9.5).
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.Page 172.of 278 1
~:SE No.: 88-234 L i.
Source Documents, IDCP 88-0012, Rev. 0 4 Description'of' Change i 'p ' -Add a check valve to.the Division 3 Diesel Generator starting air dryer s humidity sensor discharge. Y.j
. l y
% ; Summary q y \ R 5
\>
I . No . - Theinstallationofthecheckvalveatlthehumidity:shnsoroutlet will improve the monitoring / alarming capability of the air dryer by
~
preventing backflow of vet ambient' air when air dryer depressurization occurs. p
~
1 II.'No.-'The original design requirements are-maintained, therefore no 4 l potential'for a malfunction of a different type than any evaluated ; previously is introduced, i III. No.' . The margin of' safety as def ac0 in the bases of Technical -4 Specification 3/4.8.1 refers to the reliability of the onsite power supply This reliability is not compromised by this change, hence i the margin of safety is not reduced.
.q Y SE-No.: 88-235 1 Source Document: DCP 88-0012A, Rev.'O 1
?
% Description of Change l
. Add check valves to the Division 1 and 2 Diesel Generator starting air i
dryer devpoint indicator outlets. ' Summary i I. No. The installation of check valves at the devpoint indicator outlets vill improve.the monitoring / alarming ~ capability of the air dryertby preventing backflow of n t ambient air when air dryer j depressurization occurs. - i II. No. 'No potential for a different type'of accident is created by this ! change because the design remains essentially the same. All of the~ i original design requirements are maintained, and no potential for a j malfunction of a different type than any evaluated previously is introduced. A i III. No. The margin of safety as defined in the bases of Technical Specification Section 3/4.0.1 refers to the reliability of the ) l onsite power supply. The reliability is not compromised by this I change, hence the margin of safety is not reduced. l 1 l l
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1' Y \ ! .Attachmant 3: I PY-CEI/NRR-0979 L ' Page 173 of 278 i SE No.: 88-236- ' Source Docu nent: PAP-05G2 "Prept. ration, Review and Approval of Administrative Procedures", Rev. 6, Temporary Change #1 S. Y . ' Description of Change 1 .This proc.edure change shifts responsibilities for coordination of 4 interface. reviews from.the' Perry Services Department to the Perry Plant
-Technical Department, due to staff reorganization.
Summay
- 1. No. Interface reviev'of Operations Manual documents vil? continue under i
th~e new organization. Therefore, there is no effect on safety previously evaluated in the FSAR. II. No. This administrative change does not create a new or different .- ! possibility for accident or malfunction than previously evaluated. III. No. This change is administrative only, and vill not reduce the margins of safety as defined in the bases for any Technical Specification. SE No.: 88-237 Source Document: DCN 2161 i Description'of Change 1 Revise Service Water System (P41) P&ID D-302-212, Rev. T to add a failure i j position for the Turbine Building closed Cooling heat exchanger flov j control valve IP41-F003, and also correctly denote solenoid valve ! P41-F013 in the deenergized position. ' Summary l I. No. Adding a failure position for valve IP41-F003 does not change the ! design intent as described in FSAR Section 9.2.7.3. The position ' change to the solenoid valve is required for clarification and is an j editorial change only. Hence, the margins of safety previously - evaluated in the FSAR are not increased. II. No. Same as Item I above. III. No. These drawing changes have no impact on the margins of safety as ! defined in the bases for any Technical Specification, j l 1
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ef , a c j a, V Attachm1nt 3' PY-CEI/NRR-0979 L Pagei174 of 278 SE No':-
. 88-238:
Source Document -FSAR CR 88-167. { I Description of ChangeL a; a
. Delete from FSAR Figure'l.2-6laitoilet room on the 647-elevation'of the 1 i
UnitL1 Turbine ~ Building.-
]
g -Summary I.-No. The; toilet room has no effe/> on safety-related' equipment, 1
.therefore,-its deletion vily aot affect equipment'important to j
d saf e.ty. ! II..No. The deletion of the toilot s ee is. to prevent' an unmonitored release of.radioactivityff am the'R A ation Controlled Area. Thisideletion'-
< reduces the: possibilities o't an accident.
- III; No.
The Technical. Specifications do'not; address potable water and-sanitary! systems. Therefore, the margins of safety. remain unaffected by'this change.- SE No.: 88-239 Source Document: SXI-0022, Rev. O l
. Description of Change Measure instrument ~ air (PS2). flow to the dryvell through:a temporary rotometer installed across test connections.
Summary-I. No. Having the~3/4" safety-related test connection IP52-F642 open and connected to nonsafety temporary; test equipment does not significantly increase the probability'of-exceeding the allowable-
-FSAR dryvell bypass leakage. . Based on' prior dryvell bypass. leak'
- , test results, Perry's drywell bypass leakage is 123.8 scfm. 1 1
Allowable. leakage is 5751.6'sefm. _Therefore, the currently available~ excess bypass leakage is approximately 5600 scfm. II. No. The loss of instrument air has been evaluated in the FSAR. Per ; paragraph 9.3.1.3, failure of instrument air does not' compromise any ; safety-related system or component and does not prevent a safe ' reactor shutdown. Instrument air vill not be lost to the dryvell j during this test;.but if it.were, the instrument air loads in the dryvell: SRV's, MSIV's, and the dryvell personnel lock, all have accumulators with check valves on them. ' III. No. The margins of safety as defined in the bases for Technical Specifications are not reduced. The Control Room vill invoke the requirements of Technical Specification 3/4.6.2 and'take the ' required action if applicable, during the dryvell instrument air j flow measurement test. ' i b d
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'PY-CEI/NRR-0979 L- . .'
6 " i Page 175 of 278- -i
?SE'No.: '88-240'
' Source Document:: )DCP 88-0042,-Rev. 0 y
. . Description o'f Change
.i
- Hodify Division ~ 3 (HPCS) Diesel' Generator _ starting air compressor y discharge' tubing. '
' Summary ,
. I . No . - The compressor _ discharge tubing in'the HPCS' air starting system is located in a'nonsafety-related portion of.the system upstream of the?
safety-relat'ed. starting air: receiver tanks. This tubing supplies-
-compressed air:from the air compressor to the air dryer inlet manifold connection. Replacement 1of'the existing, unsupported i
" soft" copper compressor discharge tubing.with supported stainless steel discharge tubing significantly improves _the overal1~
operability and reliability'of the nonsafety-related portion of the system. -Since'the replacement stainless steel' tubing has_the same. - configuration, including identical tube ID and wall thickness, there is no change in' system' operating characteristics. ' l
-This? change does not' adversely affect' equipment. It improves system reliability. . Hence, the probability of occurrence of a malfunction of equipment as evaluated previously is unaffected. I In'thel event of any malfunction of equipment, the HPCS j
- diesel-generator's response,.and the response of its air starting system would be unaffected. 'The tubing modification does not affect component or system" reliability, qualification, redundancy, or function. :Hence the consequences of a' malfunction of equipment evaluated previously is unchanged.=
;II. No.
No potential ~for a different type of accident is created by this- a change as it does not compromise the original design. This change maintains-the equipment and system reliability, qualifications, redundancy, and. function of the original design. All of the original design' requirements are maintained, therefore no potential for a malfunction of a different type than any evaluated previously is introduced. III. No. The margin of safety as. described in the bases of Technical Specification Section 3/4.8.1 refers to the reliability of the onsite power supply. The reliability is actually enhanced by the design change, and hence the margin of safety is not reduced.
t- i t 1
-Attachmant'3 -
PY-CEI/NRR-0979 L { Page 176 of 278 l .:- 'SE No.: 88-241' l: Source Document: DCP 86-0843, Rev. 1 Description of Change l
- l. !
Replace trip units with signal resistor units in the control' circuit for L the Dryvell Atmosphere Temperature Monitoring System (D23) to reduce. component surveillance without compromising control loop reliability. .l Summary o I. No. The system function ~is unchanged as a result of this revision, a therefore, the probability of an accident or malfunction of safety-related equipment evaluated in the FSAR is not increased.
'II. No. The control system circuit function has not been changed. The same design basis is used. This change therefore does not create the ]
possibility:for an accident or malfunction other than those ; previously analyzed in the FSAR. k III. lio. The LCO for Technical Specification 3.6.2.6 remains unchanged. The margin of safet/ as defined in the Technical Specification is not ! increased nor decreased, since the same operating conditionLin the specification.is used as the basis for this. change. 4 1 SE No.: 88-242-i Source Document:- SCR 1-88-006-T
' Description of Change
{ Increase the Offgas System (N64) hi-flow alarm set' point (1N64R0036)'.from f
-34 scfm to 70 scfm.
Summary 4 I. No'. This setpoint change is associated with a nonsafety alarm which is not utilized in any FSAR analysis of Chapters 11, 12, or 15. Therefore, the probability of' occurrence or'the consequences of an y accident or malfunction of safety-related equipment previously ' evaluated is not increased. II. No. Since no other system or component is affected, a different type of accident or malfunction is not created. III. No. The nonsafety alarm and associated instrument are not described in the Technical Specifications, therefore, the margins of safety as defined in the Technical Specification bases are not affected. ___ - __- - _ 2
Attachment 3 PY-CEI/NRR-0979 L Page 177 of 278 SE No.: 88-243 Source Document: DCP 87-0595A Description of Change Install stop bars instead of dovels on Fuel Handling Building exhaust fan (0M40-C002C) to ensure bearing housing does not shift. Summary I. No. The installation of stop bars is an acceptable alternative to doveling the bearing housing to the baseplate per the vendor's manual. Since the component and system function is not affected, the accident analysis in the FSAR is not affected. II. No. Since the vendor recommends either method, the function of the fan and system has not been affected and therefore malfunctions of a different nature are not created. III. No. This modification conforms to the vendor's original recommendation. It does not affect the function of the exhaust fan as described in the Technical Specifications and consequently does not affect the margins of safety as defined in the Technical Specifications. SE No.: 88-244 Source Document: Rev. 8 to OM15A: " Emergency Plan for the Perry Nuclear Power Plant" Description of Change Evaluate Revision 8 to the PNPP Emergency Plan to ensure that the effectiveness has not been reduced per 10CFR50.54(q), and to ensure that it continues to meet the standards of 10CFR50.47(b) and the requirements of Appendix E. Summary I. No. OM15A outlines the administrative response to an accident or equipment malfunction and, therefore, does not affect the probability of their occurrence. II. No. OM15A does not direct the operation of plant systems or equipment and, therefore, does not croate the possibility for an accident or malfunction. III. No. OM15A utilizes existing Technical Specifications and does not control or affect their revision. Therefore, the margins of safety as defined in the Technical Specification are not reduced.
-e y "- f 'bi , ,f + " - At t'echment. 3 '
PY-CEI/NRRLO979 L Page 178;of 278 -{ SE No.s. 88-245 Source' Documents: FSAR CR 88-178 i >
-Description of Change
' Change.FSAR Sections 13.1.2.2.2, 17.2.1.3.3.1.2, 17.2.6.3.1 and L17.2.6.3.2 to update'the procedure controlling activities, since two -i procedure controlling groups were~ consolidated.into one group.. d Summary
.q P
.I.
No. .This administrative change only shifts _ responsibility'for procedure i control. It does not impact items'previously evaluated:in the FSAR. II. No. No possibility for an accident or malfunction is created by this- l administrative change. j III..No. _This change does not affect the margins of safety defined in the f bases of the Technical Specifications. j SE No.:' '88-246
-Source Document: SCR,0-87-1150 and 0-87-1151
. Description-of Change Add the allowable' limit, safety limit, leave-as-is-zone and-reset to the _i Fuel Pool Cooling and Cleanup (G41) level switch setpoint-data !
(0G41-N0369A,B).
]
Summary I. No. The G41 surge tanks low level pump trip function for level switches
-(0G41-N0369A,B) is not affected by the leave-as-is-zone change'or the setpoint change. This setpoint is more conservative than the previously calculated setpoint. 1 l
II. No. The OG41-N0369A,B setpoint data is consistent with the currently approved Setpoint Calculation Methodology. The G41-C01 setpoint change is in the, conservative direction, because the difference ! between the setpoint and the allowable limit is increased. III. No. The Technical Specifications and its bases do not describe the ( OG41-N0369A,B setpoint information and are not affected by these ' setpoint changes. I l l
o , r q q Attachmsnt 3 PY-CEI/NRR-09791L Page 179 off278' j SE No.: 88-247 Source Documents- PAP-1911 " Fire Emergency", Rev. 2 . Description of: Change f Revise PAP-1911 such that instead of.the Fire Brigade being called out'on receipt of all fire alarms, the Fire Brigade members will be notified by radio for every alarm that is received in the Secondary: Alarm Station and members' vill' acknowledge the notification..'A "First Responder" trained t in. incipient fire fighting techniques vill respond to all alarms. 'This eliminates unnecessary alarm notifications for spurious alarm signals and allows for faster response time for probable fires by placing the Brigade in a standby condation. Summary I. No. This procedure change complies with the intent of NFPA Chapter 4-7.2 as describtsd in FSAR Section 9A.S Position E. II.~No. There are no potential initiating causes of threats to the fuel or the reactor coolant boundary. III. No. This change does not impact the margins of safety as defined in.the Technical Specifications. I SE No.: 88-248 1. Source Document: DCN 2228 Description of Change i Add MPL numbers on one outlet of the Two Bed Demineralizers (P21) on drawing D-302-171. Also delete incorrect reference to the makeup waste regenerant transfer pumps on drawings D-302-171 and D-302-711. l Summary I. No. This change has no impact on the physical configuration of the plant. It is only an editorial' change to the process and instrument diagrams. II. No. See Item I above. III. No. Since this is an editorial change to the process and instrumentation diagrams, it has no impact on the Technical Specification bases.. l l l 1
q
.e '
s '
' AttachmtntL31 < L[ ' ,
PY-CEI/NRR-0979!L-
' 4 Page.180.of 278 i
- SE'No.: 88-2491
.; Source Document:L : DCP 85-0295TT ,
Description'of'ChangeL t
. Route discharge'from the Tool' Decontamination Room liquid abrasive b
' E
-cleaning' unit ~to the existing floor drain system on the
- 574'-10" elevation of theLIntermediate Building.--
Summary.
- I. No.' ThisL . drain linegtie-in for'the Intermediate Building Tool 1
l n
. Decontamination Room liquid ^ abrasive cleaning unit has no impact on any equipment important to safety. l" II. No.. This discharge line'is hard piped ~and partially embedded in' concrete-floor to-avoid'any potential-safety hazard. There are no-nev
. accident.or' malfunction possibilities created by.this design.
m III.-No. This. minor drain line modification to properly route cleaning ~ unit 1
~
discharge does not affect the Technical Specifications, nor does it 1 reduce the~ margin of safety _as defined in any bases for any
, TechnicalLSpecification.-
SE No.'s= 88-250 I Source Document: NR PPDS 3251, Rev. O 1 j Li Description ~of Change. ' Evaluation of.a nonconformance report which-indicates that the lube oil' pump motors for the Control Complex Chillers (OP47-B001A & B) are experiencing higher then nameplate amperage (that is 2.6 A versus a q nameplate.value of 2.2 A),"as described.within USAR Table 8.3-1.
-l Summary:
1 I. No. The higher than nameplate amperage is within the acceptable
~
operating limits of a 1.5 horsepower' motor with 2.6 A full load 1 amperage (FLA) having a 1.0 service factor as defined by I sections 430-22 and 34 of National Electrical Code. II. No. The motors are operating within the acceptable limits of the National Electric Code', which permit up;to 130% of full load amperage for a 1.0 service factor motor. III. No. The lubrication motors are not defined within the Technical Specifications.
~
i ____m____m_ _ _ _ - - _. _ _ _
7 ll , n
/
Attachment 35 PY-CEI/NRR-0979 L Page 181 of 278
.: SE No.' 88-252-
- Source Document: S0I-H51/H56, Rev.-3 Description of Change
' Change system operating instruction on Combustible Gas Control and Hydrogen Control to use.a 2 inch backup hydrogen purge line to continuously relieve >the dryvell pressure.-
L Summary I. No. The subject'line is provided with two H0Vs designed.to close on a LOCA signal. They will also close on~a high radiation inside-
'dryvell signal. The line is connected to the AEGTS which is a ,
safety related filtered exhaust system required to operate under ' i both normal and' post-LOCA conditions. .These isolation valves close -' in 30 seconds. The Chapter.15 FSAR offsite dose analysis conservatively assumes the AEGTS system is totally by-passed for
~
40 seconds. 'Thus, there is no impact to the previous evaluations in the.FSAR. II. No. Both isolation valves are-designed to close upon a LOCA or high radiation signal. Thus, possibility of a~ malfunction of.an accident of a different kind.is not created. III. No. The line is provided with redundant isolation valves which are qualified to close after a LOCA. Therefore,-- the margin of safety is not reduced. , l- i l 1
-4 i-
Attachment 3 PY-CEI/NRR-0979 L Page 182 of 278 SE No.: 88-253 Source Document: DCP 87-0509, Rev. O Description of Change Install a remote pressure indicator (1M14-R0710) from the Containment Vessel and Dryvell Purge in-line filter (1M14-D003). Summary I. No. There is no increase in the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated since the addition of the remote indicator, 1H14-R0710, will enhance the capability to monitor differential pressure across HEPA filter (vent line from RVCU Backvash Receiving Tank Room) 1H14-D003 without entry into the RVCU valve room. The new remote indicator, impulse lines, and supports will be installed to the same design criteria as the existing local pressure indica:or 1M14-R0225, which has been previously analyzed. II. No. The possibility for an accident or malfunction different from those previously evaluated is not increased because the same design and installation parameters which applied to the existing local differential pressure indicator 1H14-R0225, were taken into account in the evaluation of this installation. This modification does not change the operation of the system. III. No. This installation does not affect the margin of safety as defined in the bases of the Technical Specifications since the system function is not changed or reduced, but is enhanced. This new pressure indicator serves no safety function, and does not reduce any Technical Specification requirements. 1 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~
W M.
). <
Attechmznt 3 PY-CEI/NRR-0979 L Page 183 of 278
'SE No.:- 88-255 Source Document:- SXI-0010 Description of' Change Test the AUTO program for the Radvaste Programmable Logic. Controller ~for the radwaste-collector tanks.-
Summary-
'I. No: 'The performance of this Special Test does not increase.the probability of a radioactive liquid release, because no discharge
. valves are manipulated.
II. No. This, test does not change any design configuration, therefore, there is no change In evaluated accidents or malfunctions. J j
'III..No.. The performance of-this test does not affect any liquid radvaste -1 discharges ~and consequently, does not reduce the margins of safety for,any Technical: Specification. 1 SE No.:- 88-256 j
' Source Documents- SXI-0019 l
Description of-Change f i Test the AUTO prog'am r for the Radvaste Programmable Logic Controller for l the'radvaste floor drain collector tanks. i Summary , l i See' Safety Evalution 88-255. l 1 i
O t LAttechmsnt 3- - PY-CEI/NRR-0979 L Page 184 of 278 L JSE No.: 88-257 Source Documents. DCP 87-0545, Rev. 0-
. Description of Change-Add'a'"feedvater flow-steam flow. mismatch" annunciator alarm to~the-Feedvater Control System:in the Control Room.
Summary-3 1 I. No.,LThis design change adds a nev non-safety alarm on the Control Room Console (1H13-P680-Section 3A) to annunciate a feedvater flow-steam flow mismatch, when the difference in total feedvater mass' flow rate 1
-and steam mass flow rate exceed an operational setpoint. The nev l' . alarm which replaces lov steam flow alarm, 1C34K0608, should.be added to.FSAR, Figure 7.7-6 to reflect applicable alarms in:the Feedvater Control System.' However, addition of the non-safety alarm is considered to'have no. impact on Safety Analysis currently described in FSAR,. Chapters 7, 10 and 15.~ The probability of occurrence or the consequences of an accident or malfunction of safety-related equipment _previously evaluated in the'FSAR is not increased.
II. No.' No other sys'tems or. components are impacted by this' change. A
'different type.of accident or malfunction.than previously. described
, in the FSAR is thus not created.
III. No. . 7eedvater' Control _ System nonsafety annunciator alarms are not
. described in the Technical' Specifications nor associated: bases.
There is:thus no reduction in the margin of safety. i l 1 l l l
I Attachmrnt 3 PY-CEI/NRR-0979 L Page 185 of 278 I SE' No.': 88-258 Source Document: '.DCP 88-0130, Rev. 0
. Description of Change
~
Addiinsulationtovalves"lB33-F060A/Binth'edryvellarea. Summary I . ' No. : The addition of insulation does not increase the~ probability of ; occurrence of an accident or transients'previously evaluated in Chapter _ 15 of the FSAR. Consequences of the accidents / transients described in Chapter 15 of the.FSAR vould only be influenced tolthe '! extent that the ECCS-pump performance were influenced.- The ECCS , ,. . pump performance is not impacted,.therefore accident. consequences are not changed.; II . - No. The design change does not relate to events or disturbances-that are considered as potential-initiating causes of threats to.the fuel and/or the reactor coolant pressure boundary.
- III. No. .The margin of safety as defined in the bases.for ECCS/RCIC in
~
Section 3/4.5.of the Technical Specifications.is not reduced by this change.
- SE No.
- 88-259
. Source Document: DCN 2245 Description of Change Add MPL numbers (1N71-D004A-D) for Circulating Vater joints to P&ID drawing D-302-201, Rev. V. l Summary f
I. No. This is an editorial change and does not change the-system design. II. No.- See Item I above. III. No. The Circulating Vater System is not addressed in the Technical Specifications. I
m.. - , . .
- 2 :;
Attechmant 3 PY-CEI/NRR-0979 L Page'186 of 278 SE No.: 88-260'
' Source Document: DCN 2249 H' Description of Change Correct MPL designations and a drafting error on drawings D-302-107, 302-108, 302-109 and D-302-110.
l Summary I. No.; These changes are editorial only. There is no change to any plant
~
equipment. .All analyses previously performed remain unchanged by~
.this DCN. .
II. No. See Item I above.
'III. No.. These. changes do not affect any Technical Specification components. j i
a SE No.: 88-261 Source Document: TXI-55 " Condensate Filtration System Bypass Operation", Rev. 0.. Description of Change I j
' Evaluation of a change to bypass the condensate filters when insoluble J iron is reduced to 10 ppb or less. '
Summary I. No. The values in Table 5.2-6 were established as guidelines for the ! effluent water quality of the condensate demineralizers. Removal of the condensate filters-following plant startups vill have no adverse d effect on the water quality ranges described in USAR Table 5.2-6.
]
Chemistry will analyze the Hotvell' Pump Discharge for insoluble iron l after the plant has reached 70% power. When insoluble iron is l reduced to 10 ppb or less, the recommendation vill be made.to remove I the condensate filters from service. The probability of an accident is not increased. 1 l
- II. No. Since the quality of water is not being compromised by the removal i of the condensate filters, there vill be no increase in the possibility for an accident or malfunction of a different type than previously evaluated in the USAR.
l III. No. The bypass of the Condensate Filters for removal of suspended matter l does not affect Technical Specifications. Vater quality vill remain I within the guidelines of USAR Table 5.2-6 for Condensate Treatment l Effluent. i l
's -}
i - 4
' -Attachmsnt 3 1 PY-CEI/NP.R-0979 L Page 187 of 278
- SE No.: '88-262!
Source Document: SVI-E12-T1194, Rev. 2, TCN #6 (LPCI Pump A Discharge (Bypass) Flow-Low Channel Functional for 1E12-N652A)
- Descript' ion of' Change.
.TCN #6 contains instructions to use LL&J's to keep the RHR A minimum flow
. valve open:while.the channel functional test for lE12-N652A is performed.. j i
Summary I."No. This TCN ensures that the RHR A minimum flov~ valve vill remain open oto prevent a malfunction of RHR pump-A. The pump will remain operable to perform its' safety function. The basis for this is an
-i evaluation of Technical Specifications,'which allow the minimum flow valve to be placed in the tripped condition (open) for a period'of-seven days.
II. No. Operations vill continue to maintain 1 control of the minimum flow j valve with the control switch. The' possibility for a different type of accident is not created. III. No. This TCN complies with the Technical Specification action required ~ vhen the LPCI Pump A Discharge Flow-Lov channel'is inoperable. I
'l i
( 4 1 I l _ i_ - _ _ _i
Attachment 3 PY-CEI/NRR-0979 L Page 188 of 278 SE No.: 88-263 Source Document: DCP 87-0210, Rev. 0. Description of Change Add time delay relays to RVCU, HSL/RWCU and RHR/RCIC leak detection (temperature monitoring) isolation logic circuitry and also to the setpoint list. The purpose of the modification is to eliminate spurious trip signals caused by thermocouple monitors when their associated head / set switch is operated during plant surveillance. Summary I. No. This design change concerns the addition of I second time delay relays in the Leak Detection circuitry associated with RWCU, HSL/RVCU, and RHR/RCIC Systems and isolation logic. The purpose of I the modification is to eliminate spurious trip signals caused by Panalarm (Riley) Model 86 thermocouple monitors when their associated Read / Set switch is operated during plant surveillance. The scope of the proposed modification is consistent with the design action taken by Duane Arnold Energy Center as reported in IE Information Notice 86-69. Addition of the 1 second time delays in the Leak Detection (temperature monitoring) isolation logic is considered an effective method for eliminating spurious hardware induced isolations without impacting the actual design function of detecting process leakage and initiating valve isolations/ alarms. Review of Perry USAR Chapter 6, 7, and 15 Safety Analysis indicates that the subject changes have no impact on Perry Safety Analysis with respect to containment isolation valve closure times or the plant's ability to attain a safe condition / shutdown. The isolation trips of the subject logic circuitry can be associated with the Small Break Loca event described in USAR Section 15.6.2. This is a non-limiting event in comparison to Large Break Loca events described in USAR Sections 15.6.4, 5, and 6, and relies on operator action to isolate a broken instrument line after the first 10 minutes of the event. Addition of 1 second delay to validate a true process leak would thus have no effect on the operator to take corrective action or containment isolation valve closure times. The bounding large break Loca events result in plant isolations due to other process instrumentation measuring reactor vessel water level and high-dryvell pressure. Associated trip logic circuitry for this instrumentation is unaffected by the proposed design modification. The probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously evaluated in the USAR is therefore not increased. l
7
? ?, ,
Attachmant 3 3.< PY-CEI/NRR-0979 L L
' Page 189 of 278 s
)
- SE No.:' 88-263'(Continued)'
1 i
' Summary (Continued) m
;II. No-.
The scope.of this design modification is limited to the changes described for Leak Detection in-Item I above. No other systems'or components are affected byLthe modifications. f A different type.of accident or. malfunction than previously described in the USAR is thus not' created.
]
L -III. No. The. subject time delay design and" setting requirements are not proposed for Technical Specification addition-(3/4.3.2) based on the conclusion that no safety analysis'is impacted by.the modification. i This conclusion is also supported.by current "NA" response time .l requirements in the Technical. Specification 3.3.2-3 for Leak Detection Temperature instrumentation. The margin of' safety as defined-in the Technical Specifications or associated bases is not-reduced. SE No.: l80-264 Source Document: DCN 2254,.Rev. 0
- (Fire Protection Series Drygs. D-914 and D-964 P&ID's)
Description of Change-This DCN provides for.as-built information and accurate designations of where the augmented quality assurance program applies. Summary I . No . - The operating conditions of the fire protection systems are not ' affected by this DCN. 'This DCN provides as-built information and clarity. II. No. There are no potantial initiating causes of th~reats to the fuel or reactor coolant pressure boundary created by this DCN. III.'No. Only administrative aspects of fire protection are in Technical Specifications, and this DCN will not reduce any margins of safety. l
0: l Attachment 3 -l PY-CEI/NRR-0979 L Page 190 of 278
.'SE N6. 88-265 Source Document: NR 00SS 3295 Description-of Change The NR associated with this. Safety Evaluation describes a condition where 480 volt Class.1E switchgear breakers supplied with Solid State Trip ] '
(SST's) devices capable of having their. instantaneous pick-up setting set. at 24X vill not work properly. The affected breakers. serve as the source'- breaker and protective device for 480V, Class 1E Motor Control Centers
~
(MCC's) cable feed and bus. The individual loads connected to the McC's .t are protected by their own circuit power fuses and, therefore,.should a :l fault occur. downstream of any of these fuses, the fuse vill remove the faulted circuit from the MCC bus. None of these trip devices are used in " j Division III and,'therefore, Division III is not susceptible to this problem. Summary
, i I. No.
The ultimate result of the Nonconformance could be the loss of-either Division 1 or.2 (480V power) should the worst case fault 1 L occur. The USAR analyses assume the loss of-a single division of
. safety power (SKV, 480V & 120V). . 2 II. No. Same as Item I above.
III. No. The Technical Specification bases.for 3/4.8.1, .2'& .3 state "The l OPERABILITY of the power sources are consistent with the initial ' condition assumptions of the safety analyses and are based upon maintaining at least Division 1 or 2 of the onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and' single failure of the other onsite A.C. or D.C.. source." The failure of the instantaneous trip and the subsequent overtripping vill not result in the loss of more than one division. i b i
s
-Attechmsnt 3 PY-CEI/NRR-0979 L-Page'191 of 278 SE No.:- ^88-266
-Source Document: .SXI-0020, Rev. 0 lj
. Description of Change ;
Install a test pressure gauge at vent connection 1E12-F582 in'the
.' Residual Heat Removal System (E12).
' Summary I. No.. The normal _ system pressure retaining boundary is the vent valve-itself. -The valve is maintained in the closed position and is only-opened briefly to allow use of the test pressure-gauge. The vent
-connection is outside the-RPV pressure: boundary. Operability of' RHR "B" is not affected.by the test gauge.
II. No. See I above.
- III. No.
The test gauge does not affect any safety limit in the Technical-Specifications. l SE No.: 88-267
- Source Document: DCP 86-0645A, Rev. O Description of Change
-Add supplemental ventilation to the Diesel Generator Rooms to provide cooling during the Diesel Generator stand-by mode to maintain .the rooms.
u in habitable condition. , i 4~ Summary I. No. Failure of this new system. vill not impact the operation of the Diesel Generator Bldg. Ventilation System (M43), which starts upon ; Diesel Generator start. Random failure of this system vill not have
~
1 any impact on the Diesel Generator, since the room temperatures remain at or less than 120'F during the. stand-by mode without this j 3 supplemental ventilation. Thus, the probability of occurrence or 1 the consequences of an accident or. malfunction of equipment q important to safety previously evaluated in the USAR is-not ' increased. II. No. The new system only operates during Diesel Generator stand-by mode, and its failure has no impact on the Diesel Generator and the safety-related M43 HVAC system. Should the new system fail to stop i i upon Diesel Generator start (even though it is povered off ! non-safety pover), the safety-related M43 system flop is much ! greater than that of the new system and thus, will not be adversely affected. Thus, no new accident or malfunction is created. { III. No. The Technical Specifications do not address the M43 System, however t reliability is not impeded, thus the operation of the Diesel l Generators is not affected. L___-_:_______ _ i
p . ~ Attechmant.3 PY-CEI/NRR-0979 L-
-Page 192 of 278
SE No. " ~88-268-Source Documents. DCP 88-0077, Rev. 0
~
Descript' ion of Change Add drain valves to the Building Heating System (P55). Summary j q
.I.'No.
~
This.is a system enhancement. Addition of drain valves provides y 7 draining capability for an; isolated coil bank.:.-This design change does~not' adversely affect equipment operation as evaluated in the 'l USAR Section 9.4.10. '
-l II. No. Addition of drain valves to provide draining. capability for an isolated coil bank is a' system enhancement design change. .It does not create any new accident or malfunction and will not' adversely affect'. equipment: operation.
III. No. This system is not addressed in the Technical' Specifications, 3
.g
.therefore', the margins of' safety are-not affected.
SE No.: 88-269 Source Documents. DCP 87-0788, Rev. 0- '
-Description of Change l
Add. drain lines from the pump packing leak collection system to-the floor drain in the Auxiliary Boiler Fuel Oil-System (N62). ! Summary-I . ^ No .' The mechanical vacuum pump is designed to have some leakage from t
. packing. This design change does not adversely affect equipment ~!
operation as evaluated in the USAR. ! II. No. The N62. vacuum pump is designed to have some leakage from packing. i Addition of drain lines from pump packing to the floor drain does not create any new accident or malfunction. This change does not f adversely affect equipment operation. III. No. This change has no effect on the margins of safety as defined in the Technical Specifications.
Attachmsnt 3 ' PY-CEI/NRR-0979 L l Page 193 of 278 1 SE No.: 88-270 y Source Document: FSAR CR 88-169
' Description of Change i
Update the High Pressure Core Spray Functional Control Diagram, USAR Figure 7.3-1, Sheets 1, 2, 3 to provide additional design clarification of the system logic and consistency with other USAR descriptions. Summary
. I. No. The design changes made to the Functione!. Control Diagram reflect reconfiguration of ERIS points and modification of control / reset switch nomenclature. The ERIS points ~are associated with nonsafety circuitry / functions. Revision of the switch nomenclature does not affect the system design function described in USAR Sections 6.3 and' 7.3. Both areas of design are considered to not impact any Safety _
Analyses in USAR Chapters 6, 7 and 15. Therefore, the probability of occurrence or the consequences of an accident or malfunction of , safety-related equipment previously evaluated in the USAR is not increased. II. No. No other system design or component.is affected by this change. A j different type of accident than previously evaluated in the USAR is ' not created. i III. No. This design update of.the Functional Control Diagram is a software change only. Technical Specification Section 3/4.3.3 and associated 3 bases remain consistent with other USAR analyses / description and ' Perry as-built design drawings. The margins of safety as defined in the Technical Specifications are not reduced. l
.------------.---.------,-----------s
Attachment 3 PY-CEI/NRR-0979 L Page 194 of 278
.SE No.: 88-271 Source Document: FSAR CR 88-170 Description of Change Update the Low Pressure Core Spray (LPCS) Functional Control Diagram, USAR Figure 7.3-4, Sheets 1, 2 to provide additional design clarification of the system logic and consistency with other USAR descriptions.
Summary I. No. These design changes to the LPCS Functional Control Diagrams are consistent with the USAR description (Sections 6.3 and 7.3), and the Chapter 15 analyses; and they provide additional design clarification of the system logic. Therefore, the probability of occurrence or the consequences of an accident or malfunction of safety related equipment previously evaluated in the USAR is not increased. II. No. No other system design or component is affected by this change. A different type of accident than previously evaluated in the USAR is not created. III. No. This design update of the Functional Control Diagram is a software change only. Technical Specification Section 3/4.3.3 and associated bases remain consistent with other USAR analyses / description and Perry as-built design drawings. The margins of safety as defined in the Technical Specifications are not reduced. 1
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - ---- ~
Attachment 3 PY-CEI/NRR-0979 L' l Page 195 of 278 SE No.: 88-272 Source Document: FSAR CR 88-171 Description of Change 4 - Update the Reactor Vater Clean-up System (RVCU) Functional Control' Diagram, USAR Figure 7.3-6, Sheets 1 and 2 to provide additional design clarification of the system logic and consistency with other USAR descriptions. ; Summary I. No. These design changes to the RVCU Functional Control Diagrams are consistent with the USAR description, (Chapters 5 and 7, j Figure 5.4-16), and the Chapter 15 analyses; and they provide additional design clarification of the system logic.
\
There are several design changes to the Functional Control Diagram ' which reflect reconfiguration of ERIS points and additional annunciator alarms. Both areas of design are associated with nonsafety circuitry / functions which do not affect any safety analyses in USAR Chapters 5, 7, and 15. Therefore, the probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously evaluated in the USAR is not increased. II. No. No other system design or component is affected by this change. A-different type of accident than previously evaluated-in the USAR is not created. III. No. This design update of the Functional Control Diagram is a software change only. Technical Specification Section 3/4.3.2 and associated bases remain consistent with other USAR analyses / description and Perry as-built design drawings. The margins of safety as defined in the Technical Specifications are not reduced. l l 1 l l l e_ -_ _ _ _ - _ -_
J 1 Attachmtnt 3 i PY-CEI/NRR-0979 L. ( Page.196 of 278' SE No.:' 88-273
. Source Document: FSAR CR 88-172 !
-Description of Change i
Update the MSIV Leakage Control System Functional Control Diagram, USAR. Figure 7.3-7, Sheets 1-4, to provide additional design clarification of
'the system logic and. consistency with other USAR' descriptions, j Summary ;
l I. No. The design changes to the HSIV Leakage Control System Functional Control Diagrams are consistent'vith the USAR description . (Sections 6.7 and 7.3), and the Chapter 15 analyses; and they ~l provide additional design clarification of the system logic. 1 There are several design changes to the Functional Control Diagram which reflect reconfiguration of ERIS points and additional 1 annunciator alarms. Both areas of-design are associated with nonsafety circuitry / functions which do not affect any safety l analyses in USAR Chapters 6,:7, and 15. Therefore, the probability , of-occurrence or the consequences'of an accident or malfunction of safety-related equipment previously evaluated in the USAR is not increased. . II. No. No other system design or component is affected by this change. .A !
~different type of accident than previously evaluated in the USAR is not created. ;
J III. No. This design update of the Functional Control Diagram is a softvare l change only. Technical Specification Section 3.6.1.4 and associated bases ~ remain consistent with other USAR analyses / description and Perry as-built. design drawings. The margins of safety as defined in .i i
'the Technical Specifications are not reduced.
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-Attechment'3 PY-CEI/NRR-0979 L-
- i. Page 197 of 278 SE No.: 88-274 l Source Document: FSAR CR 88-173 Description of Change.
Update the Standby Liquid Control System (SLCS) Functional Control Diagram, USAR Figure-7.4-2, Sheets 1 and 2, to provide additional design clarification of the system logic and consistency with other USAR descriptions.- ; Summary I . No. . The design changes to the SLCS Functional Control Diagrams are I consistent with the USAR description (Chapters 7 and 9, i Figure 9.3-19), and.the Chapter 15 analyses; and they provide 1 additional. design clarification of the system logic. Therefore, the ! probability of occurrence or the consequences of an accident or
. malfunction of safety-related equipment previously evaluated in the ;
USAR is not increased. I II. No. . No other system design or component is affected by this change. A different type of accident than previously evaluated in the USAR is not. created. i III. No. This-design update of the Functional Control Diagram is a softvare ! change only. Technical Specification Section 3/4.1.5 and associated bases remain consistent with other USAR analyses / description and' Perry as-built design drawings. The margins of safety as defined in the Technical Specifications are not reduced. ' i h l i
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Attachmsnt 3-PY-CEI/NRR-0979 L Page 198 of 278 c.. . SE No.: 275- ,
. Source Document: FSAR'CR 88-176 Descriptiori of Change Update the Neutron Monitoring System Functional Control Diagram, USAR Figure 7.6-2, Sheets 1-7, to provide additional design clarification of i the system logic and consistency with.other USAR' descriptions. '
Summary ,
- 1. No. The design changes to the Neutron Monitoring System Functional
' Control Diagrams are consistent with the USAR description-
.(Sections 7.2, 7.6 and 7.7), and the Chapter 15 analyses; and they' provide additional design clarification of'the system logic.
'There are recommended design changes to'the Functional Control Diagrams which correct trip inputs to SRH/IRM/APRM indicating lights' '
and reconfigure ERIS.and Process Computer alarm points. Additional design detail logic is'also added'to the SRM and TIP Drive System logic. In all cases, however, these changes are associated with. nonsafety circuitry / functions which do not affect. safety analyses in .s. USAR Chapters 7 and'15. Therefore, the probability of occurrence or. the consequences of an accident or malfunction of safety-related > equipment previously evaluated'in the USAR.is not increased. II.:No. No other system design or component is affected by this change. A different type of accident.than previously evaluated.in the USAR is not cre'ated. III. No.- The design update of the subject Functional Control Diagram is a software change only. Technical Specification Sections 2.2, 3/4.3.1, 3/4.3.6 and associated bases remain consistent with other USA.R analyses / description and Perry as-built design drawings. The- ! margins of safety as defined in Technical Specifications and its i bases are not reduced. i l l i
'Attachmsnt 3~ 1 PY-CEI/NRR-0979 L $
Fage 199 of 278 i SE No.:' '88-276 Source Document: FSAR CR 88-.179- ' Description of Changd s Update-the Residual IIeat Removal System Functional Control Diagram, USAR Figure 7.3-5, Sheets 1-5, to provide additional design clarification of the system logic and consistency with other USAR descriptions. Summary l
.i I. No. The design changes to the Residual Heat Removal System Functional ;
Control Diagrams are consistent with the USAR description (Sections 5.4 and 7.3), and the Chapter 15 analyses; and they 1 provide additional design clarification of the system logic. Therefore, the probability of occurrence or the-consequences of an accident or malfunction of safety-related equipment previously evaluated in the USAR is not increased. II. No. No other system d'e sign or component is affected by this change. A different type of accident than previously evaluated in the USAR is not created, i III.'No. The design update of the subject Functional Control Diagram is a software change only.- Technical Specification Sections 3.3.3, 3.4.9, 3.5, 3.9.11 and associated bases remain consistent with other USAR analyses / description and Perry as-built design drawings. The margins of safety as defined in Technical Specifications and its " bases'are not reduced. t 1 I
4 4 Attachment 3-PY-CEI/NRR-0979 L Page 200 of 278 SE No.: 88-277 Source Document: FSAR CR 88-180 Description of Change Update the Reactor Core Isolation Cooling System Functional Control Diagram, USAR Figure 7.4-1, Sheets 1-5, to provide additional design clarification of the system logic and consistency with other USAR descriptions. Summary I. No. The design changes to the Reactor Core Isolation Cooling System Functional Control Diagrams, are consistent with the USAR description (Sections 5.4 and 7.4.1.1), and the Chapter 15' Analyses; and they provide additional design clarification of the system logic. Therefore, the probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously evaluated in the USAR is not increased. II. No'. No other system design or component is affected by this change. A different type of accident than previously evaluated in the USAR is not created. III. No. The design update of the subject Functional Control Diagram is a software change only. Technical Specification Sections 3.3.5 and 3.7.3 and associated bases remain consistent with other USAR analyses / description and Perry as-built design drawings. The aargins of safety as defined in Technical Specifications and its bases are not reduced.
v; J i Attachment-3 .i 7 < PY-CEI/NRR-0979 L- I ! 3
'Page'201 of 278 a !
i cSE No.: 88-278 ~l r Source Document: .FSAR'CR 88-184 Vg: ' Description of Change'
..5- ~
Update the Reactor Protection Syctem Functional Control Diagram, USAR
+
Figure 7.2-1 Sheets 1-4 to provide additional design clarification of the system logic and: consistency with other USAR' descriptions.
*y Summary- \ I I . No .~ The design changes to'the Residual Heat Removal' System Functional g ;
y. Control Diagrams are consistent withithe USAR' description, and the i Chapter 15 analyses; and they provide additional design l clarification of the system logic.i , 1 Onexchange'to the Functional Control Diagram is.the. deletion of the I
'"Recire Pump Trip System-A(B) tripped" annunciators. These alarms'
.j'
' exist on the. process computer'as-points C71-NCO25,26. ,The elimination of these nonsafety alarms does not affect any safety '
analyses'in USAR, Chapters 7 and 15. Therefore, the probability ofi 4 occurrence or'the consequences of an accident or malfunction of i y safety-related. equipment previously evaluated in the USAR is not increased.
- II. No. No other system design.or component is affected by this change.' A different type of accident.than previously evaluated in the USAR is y not created. '
i
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III. No. TNe design update of the subject. Functional Control Diagram 1.s a i sontvare change only. Technical Specifications and associated bases i remain consistent with other USAR analyses / description and Perry as-built design drawings. The margins of safety as defined in Technical' Specifications and their bases are not reduced.' a i
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Attachmsnt 3 2 3; PY-CEI/NRR-0979 L q Page-202 of.278 SE No. - 188-279 . Source Documents .FSAR CR 88-181 ' Description of Change- 'i
' Removal of Regulator'yLGuide 8.15 (Acceptable Programs for Respiratory' ?
Protection)-from USAR Table 1.8-1_and the replacement of reference to this regulatory guide on pages 12.5-7 and 12.5-8 with 10 CFR 20.103. Summary, l I i , . I I. No.Thip change. updates the references in the'USAR without: changing the level of commitment. The NRC incorporated the requirements-for an' ' acceptable respiratory protection: program into 10 CFR 20.103 that- ' wereipreviously incorporated by reference. This change was 47FR 16162 Published 4/15/82. II. No. Same as Item I above. III. No. ;This change'does not impact'the Technical Specifications. . 1
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7 .i L ., p.- Attachment 3 h [~ PY-CEI/NRR-0979 L M Page 203 of 278. R SE No.: 282 l Source Document: FSAR CR 88-186 I
.)
- - Description of Change Update the. Nuclear Boiler System Functional Control Diagram, USAR. .
Figure 7.3-3, Sheets 1-7, to provide additional _ design detail of.the 3 system logic and to ensure consistency with other USAR descriptions.. ! Summary I . No .' The' design changes to the Nuclear Boiler System Function'l a Control Diagrams are consistent with the USAR description (Chapters 5,16, 7. and }igure 5.1-3), and the Chapter 15 analyses Land they provide l additional design clarification of the system logic. ., There'are a considerable number of design changes.which reflect reconfiguration / addition of ERIS points,. lights and annunciator alarms, and also the relabeling of control svitch positions. These .f , areas of design are associated with nonsafety circuitry / functions. which do not affect any safety analysis,in USAR Chapters 5, 6, 7 and
- 15. Therefore, the probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously.
i evaluated in the USAR is not increased. II. No. No other system design or component is affected by this change. A different type of accident than previously evaluated in.the USAR is not created. . f
, i III. No. Technical. Specification Sections 3/4.'3, 3/4.4 and associated bases- i remain consistent with other USAR analyses and the Perry as-built design drawings. The margins of safety as defined in the Technical Specifications and their bases are not reduced.-
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.m PY-CEI/NRR-0979 L
}; Page 204 of 278 , l
.SB'No.: '88-283 '
1 ' Source Document: FSAR CR 88-187' Description of Change j Update the Suppression Pool Hakeup System Functional Control Diagram,
.USAR Figure 7.3-9'to provide additional: design clarification of the )
j system logic and to ensure consistency with other'USAR descriptions. .
. Summary I. No. The' design changes to the Suppression Fool Makeup System Functional Control Diagrams are consistent with-the USAR description' (Figure"7.3-9), and the Chapter 15 analyses; and they provide additional clarification of the system logic design. The probability of occurrence or the consequences of an accident or malfunction of. safety-related equipment previously evaluated in the- l USAR is not increased.
II. No. No other system design or component.is-affected by this change. A. different type of accident than previously evaluated in the USAR is not created. . j III. No. Technical Specification Section 3.6.3.4 and its associated bases' ' remain consistent with other USAR analyses and the Perry as-built design drawings. The margins of safety as defined in.the Technical- u Specifications and their bases are not reduced. l t 1 l l l
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3, [ Attechmant 3 PY-CEI/NRR-0979 L s Page 205 of 278 SE No.: 88-284- I
-Source Document: FSAR CR 88-189 Description of' Change i
' Update.the Reactor Recirculation System Functional Control Diagram, USAR 'l Figure 7.4-1, Sheets 1-7 and 7.7-5, Sheet 1, to provide additional design detall'of.the system logic and to ensure consistency with other USAR descriptions.
Summary I. No. The design changes to the Reactor Recirculation System Functional i Control Diagrams are consistent with the USAR description
' (Figures'7.4-1 Sheets 1-7 and 7.7-5 Sheet 1), and the Chapter 15 analyses; and they provide additional design clarification of the system logic.
The probability of occurrence or the consequences of an accident or malfunction of safety-related equipment previously evaluated in the USAR is not increased.
'II. No. No other system' design or component is affected by this change. A different type of accident than previously evaluated in the USAR is not created, i
III. No. Technical Specification Section 3.3.4 and its associated bases '
-remain consistent with.other USAR analyses and the Ferry as-built design drawings. The margins of. safety as defined in the Technical _
Specifications and their bases are not reduced. ! l i i l l I i i ! __ -__-_-_____-_-_D
i; Attachment 3 -< PY-CEI/NRR-0979 L i Page 206 of 278 SE No.: 88-285 l Source Document: FSAR CR 88-188 { Description of Change ! 1 i Update the Redundant Reactivity Control System Initiation Logic', USAR Figure 7.6-8, to provide additional design detail of the system logic and ) l to ensure consistency;vith other USAR descriptions. j Summary ?
'I. No. The-design changes to the Redundant Reactivity Control System Logic ;
figure are consistent with the USAR description (Chapters 6, 7 and i Appendix 15B), and the Chapter 15 analyses; and they provide additional design clarification of the' system logic. The i probability of occurrence or the consequences of an. accident or ; malfunction of safety-related equipment previously evaluated in'the ' I USAR is not increased. 1
'l II. No. No other system design or component is affected by this change. A !
different type of accident than previously evaluated in the USAR is ) not created. III. No. Technical Specification Sections 3/4.3.2, 3/4.3.4 and associated ' bases remain consistent with other USAR analyses and the Perry
as-built design drawings. The margins of safety as defined in.
Technical Specifications and their bases are not reduced. ' r. l 1 1 l l
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+ At ta<:hment 3. t l-PLCEI/NRR-0979 L ; Page 207 of 278 t
SE No': . 286' i Source Document FSAR CR 88-193
]
- Description of Change
" -Update 4the Control Rod Drive Hydraulic System Functional Control Diagram, USAR Figure 7.7-1 Sheets 1-7, to provide additional design detail of-the
- l. system-logic and.to ensure consistency with other USAR descriptions.
I-l' Summary
- I . No .- The design changes to the Control-Rod Drive Hydraulic System' L
' Functional Control Diagrams are. consistent with'the USAR description ,
l (Chapters 4 and 7), and the Chapter 15 analyses; and they provide l {, additional design clarification of the system logic. \ j There are a. considerable number.of design changes'which reflect i reconfiguration / addition of ERIS points,. lights and annunciator
! alarms.- These areas of design are associated with nonsafety circuitry / functions which do not affect any safety analyses in USAR '
- l. Chapters 4,.7 and 15. The. probability of occurrence or the L, consequences of an accident.'or malfunction of' safety-related j equipment previously evaluated in'the USAR is not increased.
II. No. No other system design or component is affected by.this change. A different. type of-accident than previously evaluated in the USAR is ; not created. I
.III. No. Technical Specification Sections.3/4.1, 3/4.6 and associated bases ]
remain consistent with other USAR analyses and the Perry.as-built design. drawings. The margins of safety as defined in Technical Specifications and their bases are not reduced. l l 1 l
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w -- o l: Attachment 3 PY-CEI/NRR-0979 L 1 Page 208 of 278- 1 SE No.t- 88-287. Source' Documents- DCP 87-0456, Rev. O' j Description of Change Enlarge the existing penetration (PAB 3106) in the vest vall of the Unit 2 Auxiliary Building, Elevation.632' .to allow HVAC usage due to i Service Building Hot Shop modifications. No' reinforcing bars will be cut during the removal of the concrete-to enlarge the opening. Summary I. No. Structural evaluation shows that the vall's capacity is sufficient to resist.the loading applied to it. Therefore, the consequences of 3 an accident or malfunction of equipment important to' safety ! previously evaluated in the FSAR, is not-increased..
.II. No. -Since the structural integrity of the vall is not impaired, the possibility'of-an accident or malfunction of a different type is not created. .
III. No. The enlargement of an existingsvall opening does not affect the margins of safety in the Technical Specifications.. SE No.: 88-288 Source Document: DCN.2291 Description of Change Revise drawing D-912-613, Rev. U to add a note stating that all Intermediate Building Ventilation System (M33) fire dampers are in accordance with the augmented QA program. Summary 5 I. No. This is a revision to a drawing that is editorial in nature and vill 1 not affect the systems' operability as described in the FSAR. l l II. No. See Item I above. )
]
III. No. This is an editorial drawing change and does not affect the bases of the Technical Specifications. l l l 1
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i < Attechmnnt 3 < PY-CEI/NRR-0979 L L < ~ , Page 209 of 278 SE No. 188-289 , Source' Documents' DCP 87-0667H, Rev. O
' Description of Change j i
Install a security barrier fence associated with the Service Building hot l L shop extension. '
,' j Summary )
J 1-j I. No. ' Installation of this fence does not affect equipment.important to " safe plant' operation. The occurrence of an accident ~1s not increased. There fu no change to Section 13.6.1 of the USAR. II. No. This fence does not, interface with any equipment. The fence does -t not perform a safety function. Fences are'not. addressed in accident- ! L scenarios.
'III..No. Fences are not addressed in the Technical Specifications.. This 1 outside fence vill not affect safety equipment. Plant operation is j not affected. '
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Attachmsnt' 3 PY-CEI/NRR-0979 L @ Ptige 210 of 278
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SE No 2 88-290 F' -
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Source Documenti LL&JED 1-88-086 Description ^of Change' 1 Remove the Loose Parts Monitoring System (R63)' solenoid pingers.for ' repair., Removal requires use of lifted lead tags and vill extend into l Mode 1 operation.- L 1 i Summary l I. No. USAR'Section 4.4.6.1.4 discusses the. availability of the solenoid pingers in the manual mode of operation-for system testing. The pingers are utilized in SVI-R63-T1470,-Loose Parts Monitor,(LPM) 4 Channel Functional, however, the ' pingers are not utilized in the l, portion of the SVI to satisfy Technical Specification operability requirements. Since the use or availability of the pingers in no _t way affects-system operability per Technical Specifications,'the l consequences of an accident or malfunction of equipment important to i
. safety is not increased. l j
II. No. l USAR Section 4.'4.6.1.3 states the LPH system is~ intended for operator information only, and reliance on this.information is not required _for any safety-related action. Therefore, the possibility of an accident of a different type than previously evaluated does )
-not, exist. l l
III. No. USAR Section 4.4'.6.1.4 states system testing is done per the Technical Specifications. Current SVIs to satisfy all_ Technical Specification operability requirements do not require the use of the pingers. Therefore, the margin of safety as' defined in the bases is. not reduced. l l 1 I l
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AttschmInt 3 PY-CEI/NRR-0979 L Page 211 of 278 SE No.:- 88-291 Source Documents. DCP 88-0154, Rev. 0 Description of Change l Install a new drainage system to collect Cooling Tower Basin. spillage and -j route it to the existing storm drain system. l
-Summary
.I. No. The cooling tower is a nonsafety structure, the storm drain system is.nonsafety. This change does not increase the probability or consequences of any evaluated accident or malfunction.
II. No. The enlargement of the nonsafety storm drain system near the nonsafety cooling tower vill not create a different accident or malfunction. III. No. The Technical Specifications do not address the yard storm drainage system. SE No.: 88-292 d Source Document: NR NEDS 3332, Rev. O Description of Change i Installed pipe support 1B21-H475 by mistake as Safety Class 3 rather than Safety. Class 1. The support installation drawing listed the support as Safety Class 3 rather than Safety. Class-1 per USAR Table 3.2-1. The only i difference is that Class 1 requires certified mill' test reports. After comparing the actual loading condition to the manufacturer's certified load capacity data sheets, there is a minimum of 30% margin of additional load carrying capacity. This provides reasonable assurance.that the ' support vill function as required. This is a temporary use-as-is disposition. The pipe supports vill be replaced as Class 1. Summary I. No. Since the pipe support in its present configuration meets the design size requirements for a Class 1 support, the probability of support-failure is not increased. II. No. Since the pipe support is designed in accordance with ASME i Section III, Subsection NF, the possibility of a different type of accident or malfunction is not created. ; III. No. Since the pipe support meets the design size requirements of ASHE s Section III, Subsection NF, Class 1, the margin of safety is not reduced for this pipe support.
Attachmsnt 3 PY-CEI/NhR-0979 L Page 212 of 278
+
SE No.: '88-293 l, , Source Documents -FSAR CR 88-198 Description of Changes
~
1 Section 12.5.2.3.2 of the USAR states that an additional 30% of the instruments listed in. Table 12.5-2 vill be available for replacement of instruments that are out-of-service. Table 12.5-2 no longer lists L ' quantities of instruments. Therefore, the last sentence of the second paragraph of Section 12.5.2.3.2 no-longer has relevance. , Summary
'I. No. The commitment remains that a sufficient number of portable ,
instruments vill be maintained to allow proper monitoring during " both normal and accident conditions. Therefore, this change vill not increase the probability or the consequences of an accident. II. No. No new accidents vill be created by this change. III. No. The Technical Specifications are not affected by this administrative ! change. SE No.: 88-295 Source Document: MFI 1-88-092
' Description of Change Install temporary piping to apply clearvell water to the Service Vater pump seals and motor cooler. Clearvell vater is the normal supply. This )'
temporary piping is needed to implement DCP 87-0338, which redesigns the , Service Water pump bearing / cooling flow rate. Y Summary 1 I. No. Service Vater pumps and the clearvell system are nonsafety. These i j systems are not needed to shutdown the reactor and the probability l of occurrence of an accident previously evaluated in the FSAR is not ! increased. II. No. Failure of the temporary seal vater piping vill not lead to a different type of accident than previously evaluated. III. No. The bases for Technical Specifications are not affected by Service Vater or clearvell availability.
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Attachment 3 PY-CEI/NRR-0979 L' Page 213 of:278 SE No.: 297 Source Documents .DCP 87-0418, Rev. 1' Description of' Change Revise Control Room' legends, local panel nameplates and improve the Inclined Fuel. Transfer System (IFTS) Maintenance Areas Access Control-Switch labels. - Summary I. No. No' change is being made to the. permanent radiation shielding around i the IFTS areas.L Operation of the Maintenance'Are.as' Access Controls
.is not affected. Revision of the position labeling for the two j keylock switches and.the. annunciator legend discussed in *
' USAR 12.3.2.2.1.d eliminates confusion :in switch operation. There-is'no increase in the possibility for an accident or malfunction of 'l equipment important to. safety previously evaluated-in the USAR.
l
- II. No. 'The design land operation of the Inclined Fuel Transfer. System Maintenance Areas Access Controls. remains unchanged by the labeling- )
and legend changes. -The possibility for an accident or malfunction not previously' accounted for in the USAR does not exist.
.III. No.- The Technical Specifications do not address IFTS Maintenance Areas Access Controls.
l l I I i I
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.Attachmsnt 3 PY-CEI/NRR-0979 L Page 214 of 278 SE'No.: 298
. Source Document: PAP-1922, Rev. 1,." Preparation, Review and Approval of Pre-Fire Plan Instructions" Description of Change i
Change procedure PAP-1922 to establish the criteria by which pre-fire plans for safety and nonsafety-related areas are createdLand revised. Summary I
\
I. No. The changes being made either meet or exceed.the requirements in d Appendix 9A of the USAR and in Appendix R of 10 CFR 50 for pre-planned strategies for fighting fires in specific plant areas. As a result, the probability of an occurrence or the consequences of y an accident or malfunction previously identified is not increased. ' II. No. .These changes do not create the possibility.for an accident or I malfunction of a different type than any previously identified in the USAR. The changes being made are improvements.and are
~
consistent vith the requirements in Appendix 9A of the USAR and also d 10 CFR 50 Appendix R. III. No. The changes being made vill result in an improved method of
-providing pre-planned fire fighting strategies over the current.
pre-fire plans that are.being used. Both the present and revised methods meet the requirements of Appendix 9A'of the USAR and l Appendix R of 10 CFR 50, and-there is no impact on the Technical ! Specifications. l 1 l l 1 I l l l 4
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' Attachment'3 PY-CEI/NRR-0979 L ,
Page 215'of'278 m , SE No'.: .'88-300 ' e
; Source Document DCP 86-0768-l MFI l-88-093',. '
j LL&JED 1-88-093-f
. Description of Change -4
}1 Modify thel Turbine Bldg / Heater Bay' Bldg isokinetic sample. panel lH51-P757: ')
'in the Plant: Radiation. Monitoring-System to. remove the-automati_c sample j
. flow control'and defeat nuisance lov stack / sample flow annunciator that- '
is caused by. damaged instrumentation. .It'is not prudent to rework and ! recalibrates the-instrumentation since DCP 86-768 is being processed to remove much of this instrumentation. Summary I. No. The'MFI and LL&J reduce the total number of instruments within the-sample flow control loops and eliminate a nuisance alarm until ; DCP.86-768 is implemented, therefore, the probability of equipment l malfunction is not increased; The design function'of the sample I panels'.is not changed, since.the equipment is still capable of. I providing a representative sample. 'Also, it aids the operators'by' eliminating a nuisance annunciator. ' i
'II.;No.
The isokinetic > sample panel's are not used in USAR Chapter 15 Accident Analysis. ,The modification-does not. change.the systems. ability'to collect;a representative sample, therefota this change l does:not create the' possibility for'an accident or malfunction. III. No. The representative sampling capability is not changed by this. MFI/LL&J, therefore, the Technical Specification margin of safety is , j not reduced. ' 1 1 j l
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V< .{ Attachmant 3 PY-CEI/NRR-0979 L Page 216 of 278 SE No.: 88-301 Source Document: DCN.2271 Description of Change Change drawing D-302-355 to revise the safety classification design flags, add drain valves on the Division 1 and 2 Diesel Generator air intake: filters,. add service indicator on the Division 3 Diesel Generator air intake filter and correct expansion joint MPL numbers. Summary i I. No. This drawing change reflects the same basic equipment configuration and safety classifications as defined in Sections 9.5.8 and 9.5.9.5 of the USAR for the Division-1 and 2 Diesel Generators and the Division 3 Diesel Generator, respectively. Since there is no change to the Diesel Generators as described in the USAR or as installed, the probability of an accident is not increased. l
.These changes are minor editorial and configuration changes for clarifying component safety classification as non-ASME, safety-related. They do not increase the probability of Diesel Generator engine malfunction, because vendor design documents and manuals already reflect these components and support classification as evaluated.
II. No. See Item I above. III. No. Since there is no change to the Diesel Generators as described in the USAR or as installed, the margins of safety as defined in the bases of the Technical Specifications remain unaffected by this drawing change. l
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, + t Attachment 3' R Te
- PY-CEI/NRR-0979 L 1
'Page 217 of 278 = .
SE No.: :88-302- , \ 1 g Source Documents- SXI-0023 L ] Description of Change 1
']
1 Test the AUTO program for the'Radwaste: Programmable Logic Controller for ' the condensate backwash settling tanks. Summary-i I. No. .The' performance of this Special: Test does not increase the
. probability of a radioactive liquid release, because no discharge valves are manipulated.
II. No. This test does:not change any design configuration; therefore, there ! is no change in evaluated accidents or malfunctions. III. No. The performance of.this test does not affect any liquid radwaste discharges, and consequently does not reduce the margins of safety. for any Technical Specification.- SE No.: 88-303 S6urce Document: Rev. 8 to OM15A: " Emergency Plan for the Perry Nuclear Power Plant" Description of Change i Delete the U.S. Coast Guard as a contact' point for the initial and follow-up notifications from the Perry Plant for an emergency event ; classified under Section 4.0 of OM15A. The State of Ohio Disaster i Services-Agency has assumed responsibility for the notification of the l U.S. Coast Guard regarding the implementation of protective actions for i marine, commercial and leisure traffic within the Perry Plant's 10 mile EPZ. Summary ! I. No. This is an administrative change only and does not affect the ; operation of plant systems / components. ! II. No. See Item I above. ! III. No. The Technical Specifications are not affected by this change. I
i Attachmtnt 3 ! PY-CEI/NRR-0979 L Page 218 of 278 SE No.: 88-304 through 88-317 Source Document: See below 'I Description of Change 1 l J These nonconformance' reports address 2 inch diameter and smaller connections on the Feedvater (N27) or Condensate (N21) heaters listed below (tube side), where the threaded plugs on the heater are of unknown material. SE No.- Source Document Description 88-304 NR HMON-1116, Rev. 0 IN27-B0003B 88-305 NR MMON-1115, Rev. 0 1N27-B0003A 88-306 NR MMON-1114, Rev. 0 l IN27-B0002B 88-307 NR MMON-1111, Rev. 0 IN27-B0001A 88-308 NR MMON-1112, Rev. 0 IN27-B0001B 88-309 NR MMON-1113, Rev. 0 1N27-B0002A 88-310 NR HMON-1110, Rev. 0 1N21-B0003B
'88-311 NR HMON-1109, Rev. 0 1N21-B0003A 88-312 NR MMON-1108, Rev. 0 IN21-B0001C j 88-313 NR MMON-1107, Rev. 0 1N21-B0001B -!
88-314 NR MMON-1106, Rev. 0 IN21-B0001A 88-315 NR MMON-1103, Rev. 0 1N21-B0002A 88-316 NK MMON-1104, Rev. 0 1N21-B0003B I 88-317 NR MMON-1105, Rev. 0 IN27-B0002C Summary I. No. The N21 and N27 system are nonsafety-related. The temporary "use-as-is"' disposition of this NR does not. increase the probability i of occurrence of an accident. These heaters were pressure tested at 1 1/2 times the system design pressure and were still found to be in ; accordance with ASME Section VIII, Division.1 code requirements for the heater. If leaks were to develop from the threaded plugs in the condensate side of a heater, it would'not be immediately felt by the reactor coolant system due to the storage capacity in the hot surge tank and the feedvater system. The storage capacity will allow either corrective actions to be taken or an orderly runback to a compatible load or shutdown of the reactor. The threaded plugs do ! not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the USAR. i II. No. The USAR Section 10.4.7.13 addresses leaks from feedvater or condensate heaters, therefore, the possibility for an accident or malfunction of a different type than any evaluated in the USAR is not created. < III. No. The N21 and N27 heaters are not addressed in the Technical Specifications, i . 1 L_. _ _ - _ _ - _ _ _ _ - _ - _ - _ _ _ - _ - _ _ _ _ _ _ _ _
4 i Attechment 3 ' PY-CEI/NRR-0979 L Page 219 of'278 'l
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1 i: SE No.'s '88-318
-Source' Document:
DCP 87-0793A, Rev. O g -Description of Change Install an annubar flow element assembly'(1M51-N100).in the Combustible.
. Gas Control System (M51).
> Summary
.I. No. .There'is no probability of an' increase:in occurrence or the-consequences of an accident or malfunction of equipment,important..to..
safety previously ersluated, since the installation'of the annubar flow element enhances the: capability to monitor the air flow thru. " the Combustible Gas Control System (M51) when. venting the dryvell. The current configuration does not allow measurement-of air flow. ,.
'thru the M51 System.
II. No...The possibility for an accident or malfunction different from those-previously evaluated is not increased because the design parameters which applied to the existing installation were'taken into account
-in the evaluation of the installation of the annubar flow element. .
This modification-does not change.the operation of the system.. I III. No.- The Technical Specification basis for isolation of the ba'ckup hydrogen. purge system, as discussed in Section 3/4.6.1.8, is not
'i
. reduced or.affected, since the design does not involve any changes
'to the containment isolation valves or controls. Therefore, the margin of safety is not reduced.- i l
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[.. _ Page 220 of 278. n l SE No.: 88-321 Source Documents. DCP 88-0095 Description of Change ! Remove the. Reactor Core Isolation Cooling System (RCIC) orifice' l
. plate 1E51-D0027 and-replace it vith a pipe spacer. This nev' spacer allows forffaster varmup of the RCIC steam.line, thus making RCIC. '!
available sooner to perform its intended safety function. Summary; [ I. No. The modification / alteration to the RCIC varmup line~in no way l l affects any. component or system which could cause the probability of-occurrence of an~ accident or transient (FSAR Chapter 15) to increase.- .
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Replacement of the .1875" orifice plate in the varmup line does not- ' increase:the probability of malfunction of equipment. The new spacer. Installation vill be built and installed per.FSAR commitments
.(Table 3.2-1).-
The orifice plate can be removed due.to the implementation of DCP-870123 which changed the position of. containment isolation valve ~1E51-F063 from'"normally closed" to "normally open". The. 3 analysis performed under DCP-870123 allows RCIC to De placed in . l
-standby via opened'F063. The original intent of the .1875" orifice j
'was to limit reactor steam through a pipe break in the Steam .
Tunnel / Auxiliary Building when the system was in-standby with.F063 - j normally closed. Since'F063 is now normally opened and the new I analysis has reviewed a pipe break with F063 opened, the orifice is
.no longer necessary to reduce environmental conditions in the Auxiliary Building during a RCIC line break.
The consequences of an accident as, stated in the FSAR (Chapter 15) are not increased by removing an existing orifice plate'and' replacing'it with a pipe spacer. The design change was reviewed .f against " Steam System Pipe Break Outside Containment" (FSAR 15.6)' , and is bounded by a main steam line break versus a RCIC steam line break. , II. No. The proposed clarification to the FSAR vould not create a new type of accident or malfunction. This change does not relate to events or disturbances'that are considered as potential initiating causes j of threats to the fuel and/or the reactor coolant pressure boundary. ; III. No. The margins of safety as defined in the Technical l Specification 3/4.7.3, are unchanged and unaffected by the proposed modification to the RCIC varmup piping. This change allows faster varmup of the downstream RCIC steam piping during startup of the RCIC system from secured status to standby status. J _ _ . _ _ _ _ - - - - . ~ -
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SE No.: 88-322. Source Document:' DCP 88-0155-
.a-Description of Change I
0-- l
' Install bypass alarm switches'on Leak Detection System (E31)- -
1 recorders-1E31-R0608 andi1E31-R0611. j Summary" l l I.-No. At present, the leak detection recorders input a' signal that vill
' " seal in" the annunciators, thus preventing or masking any.
- additional alarms.'that are significant to.each recorder.. This-modification provides the means:for the' operators to manually bypass all, one,'or a combination of alarm inputs, thus' releasing the-annunciator " seal in". Therefore, the probability of an accident.or.
an equipment malfunction.is decreased due to'the increase in additional monitored' input alarm signals. Automatic safety function is not affected. II. No. The' scope of the design change is limited to the E31 leak detection recorders and'does'not affect the probability of an accident or. equipment malfunction other than previously evaluated. # III. No. This' modification does not affect the Technical Specifications, and
-therefore, the. margin of safety is not reduced.
s
-SE N4 .: 88-323 Sourc5 Document: DCP 86-0568K, Rev. O ~1" Description of-Change t
' Md service air _ (P51) supply to the Control Rod Drive (CRD) Rebuild Room.
This DCP revises drawing D-302-242, which is USAR Figure 9.3-29 to show the service air modification. l Summary-I..No. The service air system has no safety-related functions as defined in i USAR Section 3.2. Failure of this system does not compromise any safety-related system or component and does not prevent safe reactor shutdown. , 1 II. No. Addition of this supply to the CRD rebuild room meets standard f design and construction practices for this system. Any possibility for an accident or malfunction of this system has already been 'l j evaluated in the USAR. ) l ( III. No. The service air system is not addressed in the Technical ! Specifications. L
Attachment 3 PY-CEI/NRR-0979 L Page 222 of 278 SE No.: 88-324 Source Documents- DCP 87-0819 Description of Change Add break flanges to the drain lines of the RHR heat exchangers to allov 1 the RHR heat exchanger cover plate to be removed without having to break and reveld the drain lines. This reduces radiation exposure time during the routine maintenance of the RHR heat exchangers. i Summary i I. No. The drain lines to the RHR heat exchanger drain lines are not addressed in the USAR. The break flange additions do not alter the original function of the drain lines. Therefore, the addition of break flanges to the RHR heat exchanger drain lines does not increase the probability of an accident or malfunction to the Emergency Service Water System, as described in Section 9.2.1 of the USAR. II. No. The break flange additions do not change the original function of the RHR heat exchanger drain lines of the emergency service water system, and do not create a possibility for an accident or malfunction of a different type than any evaluated previously in the USAR. III. No. The break flange additions do not reduce the margin of safety as descr2 bed in the Technical Specifications.
l Attachmsnt 3' PY-CEI/NRR-0979 L -( Page-223 of 278 SE No.: 88-.325 Source Document: DCP 85-0558, Rev. O f Description of Change ! i Remove an unnecessary 1 1/2 inch diameter vacuum'line'from RCIC to RHR
~
relief lines.-
. Summary I. No. The probability _of occurrence of accidents stated in Chapter 15 of the PSAR is not increased by removal of the 1 1/2" diameter vacuum line. This line was not adequate to prevent drawing slugs of water i (suppression pool) back through.the discharge piping. Deletion of I this piping interconnect removes any safety concern of check valve l failure. Consequence of failure.of equipment.important to safety is not increased. The addition of two-6" diameter vacuum breakers have i since been added to provide a more adequate capability to reduce reflood intensity and the loads associated with it. This DCP permanently locks the existing check valve (1E12F103/F104) with a threaded plug. The probability of malfunction of'these active valves is significantly reduced. i II. No. This change does not create a new type of accident or malfunction.
This change does not relate to events or disturbances that are considered as potential initiating causes of threats to the fuel and/or the reactor coolant pressure boundary. III. No. Removal of'the vacuum breaker from RCIC penetration #115 & #106' increases the ability to perform LLRT testing on RHR i penetrations #107 & #429. Removal of these active valves from the RHR/RCIC system by. f permanently plugging has no impact on the margin of safety as ! defined in the bases of the Technical Specification, for Containment Systems (3.4.6), RCIC (3/4.7), or RHR (3/4.5)- The six inch diameter vacuum breakers located on each relief header, provide adequate protection against drawing slugs of water from the i suppression pool back through the discharge piping. ! l l l l
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-Attachmtnt 3 PY-CEI/NRR-0979 L 1 Page 224 of 278 .!
SE No.: 88-326 _ Source Document: DCP 87-0592, Rev. O Description-of Change l i
- Hodify the ventilation ~ openings in the_Radvaste Building by- !
redistributing air flow to optimize ventilation of:possible airborne: contaminants above solid radvaste_ fill' pit area and also to close up vall-penetrations to achieve the same result. Summary I. No. The overall system function vill not change with the implementation of this' design _ change. Therefore, the parameters upon which the accident and transient analysis in the USAR vere based, are not affected. II. No. -This design change does not" affect the overall system function. Therefore, an accident or malfunction of a different nature as-previously evaluated in.the USAR will not be created. III.-No. The Technical. Specifications' address the non-safety charcoal filtered exhaust systems. This design change does not alter the exhaust flow and therefore, there is no change to the Technical Specifications and the margins of safety are not reduced. SE No.: 88-328 i Source Document: MFI 1-88-115 i Description of Change Provide Moisture Separator Reheater.(MSR) 1A and 2A 2nd Stage drain tank i normal level control via alternate control valves F240A and F245A. Summary
.I.'No.- By controlling the MSR 1A & 2A 2nd Stage drain tank with the alternate drain valves,-with the normal level controllers, level vill be maintained at the same or lower than normal. elevation, which does not increase the accident or malfunction probability previously evaluated in the USAR.
By rerouting MSR 1A & 2A 2nd Stage drains a small reduction in final feedvater temperature vill occur, but well within the 100'F reduction allowed per USAR Chapter 15 Appendix D. II. No. There is no new type of accident created as a result of this change other than what has previously been evaluated in USAR Section 15.1.1 and 15.2.3. III. No. This MFI does not affect the margin of safety for any Technical Specifications. Technical Specification 3.3.1 accounts for this with reduced setpoint penalties.
t. Attachm:nt'3 PY-CEI/NRR-0979 L Page 225 of 278 SE No.: 88-329-Source Document: DCP 87-0456,.Rev.'O Description of Change l Rercute.the existing 8-inch: Fire' Protection Systemi(P54) distribution ! main, located beneath the Service Building Hot Shop Annex, route existing CO2 vent lines utside the new Annex, and. add new automatic sprinklers.in j the Hot Shop Annex. Summary I' I. No. The new pipe route does not adversely affect water supply to i suppression systems. The building header has multiple feeds. The slight increase in the resistance to flow caused by this change vill result in a slight decrease in flow through thic feed. This causes a corresponding increase in the flow rate in the other feeds with a si minimal increase in the overall system pressure drop. II. No. si :ce the new routing does not significantly increase pressure or vate. .o systems, the system function is not affected. III. No. The margins of safety for any Technical Specification bases are not affected by this change. SE No.: 88-330-Source Document: DCP 88-0024, Rev. O Description of Change Remove the existing Service Water System makeup flapper valve, 1P41-F950, i located in the Cooling Tower Basin, and route the Service Water piping into the Basin below the water level to limit the cold vinter air from entering'the inside of the pipe and freezing valve 1P41-F405. This DCP also increases the heat tracing capacity and insulation for the Service Vater Circulating Vater pipes. Summary I. No. Removal of this flapper valve from the Cooling Tower makeup line does not effect the two Safety Class III, Seismic Category I motor-operated valves located in that portion of the pipe and described in l USAR Section 9.2.7.3. Therefore, the probability of occurrence or the consequences of an accident as previously evaluated in the USAR is'not increased. II. No. Failure of this Service Water piping into the Cooling Tower Basin has no effect on any safety-related components. III. No. The Service Vater and Circulating Vater Systems are not addressed in the Technical Specifications, therefore, the margin of safety is not reduced.
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Page 226;of 278z
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SE No.: 88-331-Source Documents. -DCP 87-0456V, Rev. 0
-Description of Ch.ange Add Instrument Air (P52) supply to the Service Building Hot Shop and:
revise' drawing'D-302-243 (USAR' Figure 9.3-31). 1 i
' 'l
- g. Summary i H i
' q I. No. The instrument ale system has no safety-related functions as. defined I in USAR Section 9.3. Failure of this system vill not. compromise any
' safety-related system or component and vill not prevent' safe reactor-shutdown.
II. No. Addition of.this supply to the Service Building Hot Shop room meets
- standard design and construction practices for this system.- Any possibility for-an accident or malfunction of this system has already been evaluated in the USAR.
III. No. The' Instrument Air' System is not addressed in the Technical' Specifications and the margin of safety is.not reduced. i-1 i (
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Attachment 3 -l PY-CEI/NRR-0979 L J Page 227 of 278 '
.1
. SE No.: 88-332 I
Source Document: DCP 87-0363, Rev. O j Description of Change- l' Replace the 1 inch carbon steel drain _ lines and valves with stainless 1 steel; add test connection and valves for helium leak testing / pneumatic d pressure testing in the Offgas System (N64) charcoal vessels. Summary I. No. This design change replaces carbon steel pipe and valves with i stainless steel in the same configuration. Changing the saterials of construction does not change the probability of occurrence of an accident. The configuration change in piping to simplify integrity- 3 1 testing by adding a test connection with isolation valves and threaded cap poses no' change in the probability of occurrence of an 1 accident. II. No. Pipe rupture and/or breach of pressure boundary are the only malfunctions or accidents possible due to piping configuration change.and pipe alteration. Replacing carbon steel pipe with stainless steel has no impact on process parameters, .and, in fac':, vill. decrease the likelihood of drain blockage due to corrosion. ; This change does not relate to events or. disturbances that are considered as potential initiating causes or threats to the fuel' and/or the reactor coolant pressure boundary. l III. No. Margin of safety as outlined in Technical Specification 3/4.11.2 4
" Gaseous Effluents" is not affected or reduced by. changing out ~
piping'and. improving system. testability. 4 f 4 m_.___________._______-__m_ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ . _ . _ _ _ _ . . _ . _ _ _ _ _ _ _
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3' ' Attachment 3 PY-CEI/NRR-0979 L
, Page 228 of 278 SE No.: 88-333 Source Document: HFI 1-88-117 Description of Change' l
1 1 Transfer level controller R141A from level transmitter N144A, which has failed, to N43A (the norma) level transmitter). This allows level control of the Hoisture Separator Reheater (HSR) 1A ist Stage Drain Tank via drain valve N25-F160A with the normal level transmitter. Summary I. No. By controlling the HSR 1A ist Stage Drain Tank with alternate drain valve, with the normal level controller, level vill be maintained at the same or lower than normal elevation which does not increase the accident or malfunction probability previously evaluated in the USAR. By rerouting MSR 1A ist Stage drains,. a small reduction in final feedvater temperature vill occur, but vell within the 100'F reduction allowed per USAR Chapter 15 Appendix D. II. No. The accident or malfunction is previously evaluated in USAR Sections 15.1.1 and 15.2.3. III. No. This MFI does not affect the margin of safety for any Technical Specification. Technical Specification Section 3.3.1 accounts for this with reduced setpoint penalties.
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,_ Page 229 of 278-
-SE No.: 88-334 V Source Document ' 'DCP 86-0768. RevX 0
1 1 Description of Change Mo'dify the isokinetic sample panels in the' Plant Radiation Monitoring System (D17) by removir.g.most of the exi' ting: s stack / sample' flow measuring and control instrumentation in~ order to simplify the' design.x The nev l design reduces the total' number of instrum4nts in the panel'to-improve l reliability. 'i y Summary.
-i I. No. The simplified design reduces the total number of instruments.within' the stack / sample flow control;1 oops. .The design function of the sample panels in not changed since the equipment is still capable of providing a representative sample. 'Also,'it. aids'the operators by.
clarifying the annunciator nomenclature and eliminates a nuisance alarm. II. No. 'The' isokinetic sample panels are not used in the USAR, Chapter'15 I s Accident Analyses. The modification Moes not change'the system's 'it Nability . to, nieasure stack flow or collect a representative sample;.
- therefore, the DCP does not. create the possibility.for an accident or malfunction.
{ III. No. The' stack'flov' rate monitor and representative sampling-capability. are the only Technical Specification requirements for this- i equipment. The DCP does not' change either function, therefore, the ! Technical Specification margin of safety'is not reduced. ' ;
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l Attachment 3 PY-CEI/NRR-0979 L Page.230 of 278-f
'SE No. ' 88-335 1
, . Source Document: DCP 87-0456C and P: 1 Description of Change Add HVAC to the new service Building. Hot Machine Shop'(H54) to provide conditioned air and exhaust air from the facility via a HEPA filtration i
. system through the monitored Unit 2. Plant Vent.
Summary I. No. This HVAC system is' designed to ontrol and. limit the-spread of airborne contamination in accordance vith the design bases'of the. Plant Ventilation Systems described in USAR Section 12.3.3. It ensures that the airflow patterns in the Hot Shop and its i surrounding areas vill be from lover to higher areas of probable- ; contamination, which is' consistent with the USAR.' The system i operates independently of the other Plant HVAC systems and vill not affect any equipment or system important to the safe operation or shutdown of the' Plant. As such there is no increase in the probability of occurrence or the consequences of an accident or-malfunction of safety-related equipment previously evaluated in the USAR. i II. No. The possibility for an accident or malfunction of a different(type than any evaluated previously in the USAR has'not been created. t III. No. The H54 System is nonsafety and nonseismic. Its operation ensures ; that radioactivity levels resulting from the new Service Building ! Hot Machine Shop vill remain within acceptable levels. The system is designed to safely transport and filter airborne contaminants prior to. discharge to the Unit 2 plant vent. The additional airflow in the Unit 2 plant vent vill not affect the operation of the ; existing plant HVAC systems which discharge to this vent. In .I addition, the increase in radiation levels at the Unit 2 Plant Vent i resulting from the H54 System operating vill be insignificant and ! still well within the bases'of the Technical Specifications for d radioactive effluents. ' 4 i l b. 33 i l
'I 1
Attachment-3 PY-CEI/NRR-0979;L-Page 231 of 278 : SE No.: 88-336' Source Document: FSAR CR 88-240. Description of Change Changes to the Perry Plant Organization.as follows: formation ~of the Nuclear Support Department-(NSD),. elimination-of Technica1' Superintendent' position, elimination of RDAS section, formation of Costs and Program
#. . . Section under NSD, formation of Operations Support Section'under Perry. i Plant Technical Department (PPTD), elimination of Materials Services. !
Section by. transferring functions into the Maintenance Department, transfer of various sections between departments. Summary I. No. The proposed organizational changes do not' delete any administrative j functions important to safety. The changes _ reassign the existing I functions into a stronger organizational structure. The Perry Plant Staff. continues to meet or exceed the qualification requirements of' 1 ANSI N.18.1-1971. The organization'provides the. depth and strength- j of both management and operating experience.to support Perry Opcrations, and offers considerable strength and flexibility to - effectively and safely operate.the-Perry Nuclear Power Plant. As j such the proposed changes do not increase the probability of 1 occurrence or the consequences of an accident-or malfunction of equipment irtportant to safety previously evaluated'in the'USAR.' II'. No. As discussed above, the organizational changes are merely realignments of existing administrative functions and , responsibilities. CEI has not deleted any safety-related functions nor has it created the possibility for any new or different types of-accident or malfunction. The proposed change is administrative in ! nature, and no physical alterations of' plant configuration or' 1 changes to setpoints, or operating parameters are proposed. III. No. The bases of the Technical Specifications do not discuss the Perry Organization. Since the proposed changes are to the organization, and do not alter plant configuration, setpoints, or operating-s parameters, nothing in the Technical Specification bases is being changed. Since the changes are administrative in nature, and do not reduce any administrative function important to safety, no margin of safety as defined in the bases for any Technical Specification has been reduced. l 1 [= r - .
Attachment 3' PY-CEI/NRR-0979 L s Page 232 of 278 j SE No.: 88-337 Source Document: DCP 87-0520, Rev. 0 ' Description of Change Install a maintenance breaker in position D1B04 to provide an alternate I DC supply path from-the D1B bus, to accomodate maintenance being performed on circuit breaker D1B06 and D1B07 (DC Systems, R42). Summary i l' I. No. Since the maintenance breaker utilizes the same source of power as I breakers D1B06 and D1B07, no degradation in DC system performance vill result from its.use. The maintenance breaker will not be a l i permanently installed component in the DC system and is not intended for use while the plant is in operation. , II. No. ! D1B06 and D1B07 are nonsafety-related circuit breakers which supply ! non-1E DC power to all nonsafety-related switchgear (13.8KV, 4.16KV, ! and .480KV) protection systems, annunciators, emergency lighting, ! etc. The breakers are listed in USAR Table 8.3-8. They do not involve or create different types of accident / equipment malfunctions than any previously evaluated in the USAR. III. No. The circuit breakers are not specified in the Technical l Specifications and the margin of safety is not affected. l i
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Page 233 of 278
,i
- SE ' No'. : 88-338L '
' Source Documents;; DCP 87-0800A, Rev._0-
. Description of Change 1
~ '
Replace _the Barton' turbine meters with Rosemount= mag-meters in the Leak' !
, Detection System (E31).for Dryvell cooler drain flow measurement.
Summary I. No. -The new Rosemount flow measurement system utilizes a'viring scheme similar to theLinstalled Barton system.- The power for;the trip-unit" -, is associated with Division 2 and is disconnected from the 1E, 24 VDC power supply during LOCA conditions. Since these same i
. conditions were=previously evaluated'for the Barton system, there is no increase in the probability of malfunctions of equipment important to safety. .The new trip unit's function (alarm only) I stays the same,.so there is no increase in the probability of an accident,occurting. .
II. No. The Rosemount trip unit power source connections and function are- ' similar to the Barton; trip unit with the addition of nonsafety. - j 120 VAC to the transmitter. .Since the instruments do not perform a j safety function, loss of the 120 VAC power vill not create a new a accident._ Failure of the-120 VAC power source vill not affect the ! 24 VDC power supply; 6" separation (or shielding) vill beJmaintained i between~the nonsafety_and associated viring. The 120 VAC'is used to- ' pover'the transmitter and flow element, and the 24 VAC is_used to power,the. trip unit. The 24 VDC source is further protected by j fuses in line with the' trip unit and the 1E power input. Therefore, Lthere vill not be any malfunction of-equipment different than that i already evaluated in the FSAR. 'b III. No. ' Changing the flow measurement = devices vill not affeet the alarm setpoint or operability requirements for unidentified leakage. :j There is no change to .the margin of : safety defined in the bases of 1 the Technical Specification for Dryvell cooler leakage. .i 1 q 4 l i I
i I { 'Attachmsnt 3-PY-CEI/NRR-0979 L Page 234 of 278 ' SE No.: 339 Source. Document: VO 88-4968 for required LL&JED and MFI's VO 88-4969 1
. Description of Change
' Remove' valve intervals (plugs) from lP43-F015'and'F020 to allow Nuclear I Closed Cooling System (P43) flow to each set of' redundant coil banks on !
the upper and middle dryvell coolers. Simultaneous flow through both sets of coils vill aid M13 cooling and thus reduce dryvell temperature, Summary i l I. No. P43 is not safety-related and has no safety classification, except for piping and valves. forming part of the containment and dryvell boundaries. The system is not required for safe shutdown of the reactor after a loss-of-coolant accident. Therefore, this relatively minor system change, that results in altered P43 flow, does not have any safety significance. II. No. No new accidents or malfunctions are created by this valve modification. Section 9.4.6.3.1 of the USAR is affected by this change. The operator would no longer have the capability to divert cooling vater flow to the standby coil,'since the valve internals -j vould be removed. ' III. No. The reason for attempting this valve modification is to ensure that average.dryvell air temperature does not exceed 135'F as defined in j Technical Specification Section 3.6.2.6. Allowing greater flov j l through the M13 upper and middle coolers (via both sets of redundant ! coil banks) vill enhance M13 c'ooling and thus lower average dryvell i temperature. SE No.: 88-340 ! Source Document: SXI-0025 1' Description of Change { i Test the AUTO program for the Radvaste Programmable Logic Controller for ! i the fuel pool backwash settling tanks. Summary:
'!T I. No. The performance of this Special Test does not increase the probability of a radioactive liquid release, because no discharge i valves are manipulated.
II. No. This test does not change any design configuration; therefore, there is no change in evaluated accidents or malfunctions, i III. No. The performance of this test does not affect any liquid radvaste discharges, and consequently does not reduce the margins of safety l for any Technical Specification.
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-Page 235 of 278 I L LSE No.:' 188-341-
. Source Document:~ SXI-0026 Description of Change l Test the' AUTO program for the Radvaste Programmable Logic Controllers for.
'the A & B spent resinLsystem. '
i Summary. I. No. .The performance of this Special Test.does not increase the probability of a radioactive liquid release, because no discharge valves are manipulated.. II. No. .This test does not change any design configuration; therefore, there t
'is no. change.in evaluated _ accidents or malfunctions.' '
i III. No. The performance of this test does not. affect any liquid radvaste
. discharges, and consequently does not, reduce the margins of safety for any Technical Specification. '
SE-No.: 88-342 Source Document: DCP 86-0843,-Rev. 4 SCR 1-88-1368-SCR 1-88-1369 Description of Change. Revise the dryvell high temperature alarm setpoints to 145'F-in accordance with recent Technical Specification 3/4.6.2.6 change. Summary I. No. .This change establishes non-safety circuit alarm setpoints in accordance with Technical Specification limits and Plant Emergency Instructions (PEI). II. No. Utilizing non-safety alarm setpoints at Technical Specification limits and PEI entry conditions does not create new/different accidents or malfunctions to be addressed in the USAR. III. No. Technical Specifications do not address non-safety alarm setpoints. The Technical Specification high temperature limit is the basis for this change.
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PY-CEI/NRR-0979 L Page 236 of 278 SE No.: 88-343,
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-Source' Document:- DCP 88-0033, Rev. 0 Description o.f, Change- !
)
' Install a blovout-panel between the-RCIC Room and the RVCU Room to provide pressure relief for a RCIC line break and to satisfy ~ air flow patterns committed:to in.the FSAR, Appendix 9A, Fire Protection.
Summary. I. No. The blevout panel performs the same function as'an open grating for . pressure relief and does not change the fire hazards analysis. ! a II. No. There are no potential initiating causes of threats to the fuel and { the reactor coolant pressure boundary.
'III. No.- The margin of safety for any Technical Specification basis is not affected by this change.
i SS No.: 88-344 Source Document: DCP 87-0629, Rev. 0
- Description of Change Replace the existing cage in condensate valve 1N21-F245 with a modified l cavitrol III, 2-stage cage, which vill eliminate vibration and cavitation within this valve during use.
Summary. I. No. The new cage vill eliminate vibration and cavitation within the valve and vill not increase the probability of occurrence of the analysis described in USAR Section 10.4.7.1.3. l II. No. Replacement of the valve cage in the Condensate System does not g change the design function of the short cycle cleanup line; ; therefore, the possibility for an accident or malfunction of a different type than any evaluated previously in the USAR is not ( created. III. No. The Condensate System is not addressed in the Technical Specifications. l 1 l-
i) ( Attachment'3 . .
)
PY-CEI/NRR-0979-L 1 c Page 237 of 278 a
- SE No.: 88-345-Source Document: MFI l-88-121
' Description-of Change Due to a leak in the underground piping, install a temporary line for i
hydrogen' supply to the generator located in the Unit 1 Turbine Building. Summary I. No. ~ The safety features. described in.USAR Appendix 9A, for the hydrogen
-storage system which limit the potential of a hydrogen explosion.or i fire from affecting safety related systems include an excess flow valve and.a remote shutoff valve. This temporary piping arrangement; is' attached to the permanent header, downstream of the excess flow valve'and the remotely activated shutoff valve.. These safety features are still functional as protection from a hydrogen leak.
l Therefore, the probability of occurrence of an accident previously ^ evaluated in the USAR is not increased. l II. No. The potential for a hydrogen explosion or fire has been evaluated. 1 This-temporary change does~not present any new hazards or potentials ' for hydrogen ignition. l III. No. Fire protection features of the hydrogen system are not addressed in the Technical Specifications. ' SE No.: 88-346 Source Document k DCN 02354 I Description of Change Label the applicable nitrogen gas supply valves for the Post Accident Sampling System (P87). Summary
)
l This is an editorial change to a P&ID drawing and has no impact on I. No. present equipment. l II. No, Since this is an editorial change only, the previous evaluations in j the USAR are not changed. III. No. The margins of safety for the Technical Specification bases are not affected by this change.
Attachm:nt 3- . ;
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o Page 238 of 278 -i SE No.: 88-347- ! Source Document: DCP 88-0241, Rev. 0 ' l'
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l Descriptionof Change Replace Dresser (one inch') valves 1E51-F529'and 1E51-F530 with Kerotest
'(three quarter inch). root valves in the Reactor Core Isolation Cooling-System-(E51) to improve operability.
Summary -:i 1 I . No . . The reduction in valve size vill not affect the primary function of the level switch (1E51-N037), since the switch is a Magnetrol float type.' The water level in the condencate collection pot is directly proportional'to the level-in the switch float chanber; therefore, i any change-in level is sensed immediately by the level-switch. The new configuration vill not inhibit the level'avitch froq performing its intended Lfunction of providing the drain pot high level alarm-and' controlling valve, 1E51-F005.. No credit for this level switch ! I t arrangement'is taken in the USAR.. Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated or of a different type than evaluated previously in the USAR is not increased or created.' -i
.II. No. .Same as' Item I above.
l III. No. Since the replacement root valves will perform their original ' intended function, the margins of safety defined in the Technical .i Specifications are not reduced. 1
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Attschmsnt 3 PY-CEI/NRR-0979 L Page 239 of 278 SE No.: ~88-348' Source Documents .TXI-0058, Rev. O " Bypassing;the Unit 1 Condensate Demineralized System at Power" Description of Change . This is a special instruction.for bypassing the condensate demineralizers during power operation and still maintaining proper water quality per USAR Table 5.2-6 and Section 10.4.6.2. Summary I. No. .The water quality of the hotvell pump discharge meets the values contained in USAR Section 10.4.6.2. These values are established as guidelines for effluent water quality from the condensate ; demineralizers and for feedvater (USAR TABLE 5.2-6). Based on these ! analytical results, the probability of an accident is not increased. II. No. Since the quality of water meets the values listed in USAR Table 5.2-6 and Section 10.4.6.2 prior to demineralization, the removal of the condensate demineralizers, vill not result in.an increase in the probability for an accident or malfunction of a different type than previously evaluated in the USAR. III. No. The bypass of the condensate demineralizers does not affect water 'i quality in Technical Specifications, therefore the margin of safety is not reduced. SE No.: 88-349 Source Document: SXI-31 i
. Description of Change Test the AUTO program for the Radvaste Programmable Logic Controllers for the A & B detergent drain tanks.
l Summary i See Saafety Evaluation 88-255. l l l l
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'Attachmsnt 3' PY-CEI/NRR-0979 L .1 Page 240 of 278 ,;
;SE No.s. 88-350 g Source Documents. t MFI 1-88-125
,j
-Description of Change-Install-three 2-inch pilot.t'ube taps in the main discharge circulating- l vater, pipe for flow measurement, j
Summary. , I. No. The worst case-is all three' taps breaking'off and h'ving a three~ j 2-inch holes in the circulating water. pipe- This leak-vould not'
~
affect safety-related buildings-and components, since'the leak'is
~
small compared to a' circulating water expansion joint -failure', which the plant;is designed to vithstand.(ref. USAR Section 10.4.5.3.1'and Table 2.4-9 and 2.4-10). Therefore,' the probability of occurrence -
' of an accident _ previously evaluated in the USAR is not . increased.
i8 II.'No. ' Loss of condenser vacuum and a leak in the circulating water system has been evaluated in the__USAR.and a malfunction of a different type is not created. III. No. This change' has no effect on any Technical Specification bases,'and -i
. consequently-the margin of safety is not reduced. 1
'l ,
..g. SE No t 88-351 . !-
. Source Document: SXI-0021 a
Description'of Change i 1
. Test.the AUTO program for the Radvaste Programmable Logic Controllers for the radvaste sample tanks A and B.
Summary
~See-Safety Evaluation 88-255.
I- k SE No.: 88-352 Source Document: SXI-0024 .i Description of Change i Test the AUTO program for the Radvaste Programmable Logic Controller for the floor drain sample tanks A and B. - Summary See Safety Evaluation 88-255. j i t - _ _ - - - - - - _ _ _d
1 - Attachment 3 s PY-CEI/NRR-0979 L Page 241 of 278 SE No.s. 88-353 Source Document: FSAR CR 88-248 Description of Change Change responsibilities for prept. ration of Operations Manual Volumes 1, 17 and 18 from those described in USAR Table 13.5-1. Also, removo-reference to the General Supervising Engineer of Reliability and Design Assurance (R&DAS) being the ISEG Chairman,.because the R&DAS is no longer a section in the current PNPP organization. l Summary l 1 [ I. No. ISEG requirements for membership and responsibilities have not i changed, therefore, the probability of occurrence of an accident l previously evaluated in the FSAR is not increased. I II. No. This administrative change in responsibilities due to reorganization of PNPP personnel does not create a new type of accident or malfunction. III. No. The changes described do not affect the margin of safety defined in the Technical Specifications. i l:
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'Page 242 of 278 3
-SE No.:' 88-354 e
Source Document 'DCP 87-0613, Rev. O' -
, Description of. Change-iReplace"the Steam Jet? Air Ejector (SJAE) expansion bellows, which have
.L ; experienced fatigue cracks', with a section of "hard" pipe. -
Summary H I.'No. The failure of~the air ejector discharge: lines to-the'offgas system? ' have-been~ considered in the initial design of the plant. .The failure is analyzed in Section 15.7.1.3:of the USAR. FailureEof.the'line could occur when there is a lov flow of motive high pressure steam, as' described in the USAR Equipment Malfunction-Analysis Table 11.3-4. Table.11.3-4 describes'how an insufficient steam-flow can'cause:the hydrogen and oxygen concentration to increase and cause the' process gas to beceme flammable.
- The failure of the air ~ ejector' discharge line1to the offgas system-
.vould result in the discharge of radioactive gas into the atmosphere. This failure would result in a " loss of flow'to the off.
gas system",: af ter which the operator should initiate shutdown of the reactor to reduce the amount of gaseous activity being discharged to the atmosphere as' described in USAR Section 15.7.1.3.5.1. This section also addresses the assumptions used in calculating the amount of' gaseous radioactive materials released when the air ejector discharge line breaks.- USAR Section 15.7.1.3.5.2 describes the fission product transport to-the environment, and the assumptions.used~in calculating the amount of activity; released to the environs.
'USAR Section 15.7.1.3.5.3 (Results) describes that the calculated exposures for the mentioned analysis are a very small fraction of 10 CFR'100 guidelines..
The replacement of the SJAE expansion bellows with "hard" pipe still-meets the USAR requirements. No decrease in safety vill be experienced. II. No. This piping modification does not change the original function of the Condenser Air Removal System. Therefore, the probability of an accident or malfunction of a different type than any evaluated previously in the USAR does not exist. j III. No. The condenser air removal system still retains its original function l vith the replacement of the SJAE expansion bellows. The piping modification vill not affect the operability or availability of the ! offgas system (Base 3/4.11.2.4) or the ventilation exhaust treatment j system (Base 3/4.11.2.5). . W-
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- Page'243 of 278!
- SE ' No. s . 88-354 (Continued)"
- p. ' Summary.' _ (Continued) '
Thehidrogenor.anyotherexplosivegasmixturesconcentrationvill' not.be increased-(Base 3/4.11.2.6)'as a, result lof'the' piping
. modification. -The piping _modificationLvill not affect the.
restrictions of the gross' radioactivity:: ate of noble gases from the i l' main condenser as. described in Base 3/4.11.2.7.
- SE No.: 88-355 Source Document: DCP 88-0078, Rev. O Description of' Change Switch the generator. Resistance Temperature Detector.(RTD) to tl.e ERIS System and wire the spare' exciter RTD.to the. trend recorder 1R41-K110 in the Control Room to enhance the generator / exciter L temperature monitoring system.
Summa'ry
^
- )
I.'No. 1This itemiuses'all available generator'RTD's for maximum monitoring. of generator and exciter temperatures.. This item is a system and Human Factors enhancement and does not affect ~ equipment important to safety. l.. II. No. This' item is.a. system and Human Factors enhancement to generator and exciter temperatures' monitoring and does not affect' safety
. equipment.-
a III. No. This item'_is not' described or defined in the Technical. Specifications. This item is a system and Human Factors enhancement.- , i I l q l' i l.
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't u Attachm:nt 3 PY-CEI/NRR-0979-L Page 244 of 278 yo ~ SE No.: 88-356:
Source Document: DCP 87-0456R 9
.s Description of Change L Add penetrations to the Service' Building.second and: third floors to allow new HVAC'ductwork.'to be installed.
Summary
;I. No.
BasedRon the structural analysis and evaluation, the consequences of an' accident or malfunction.of equipment important to safety,_ previously evaluated in'the USAR, is not increased. II. No. Since the structural integrity of the floor is not impaired, the possibility of an accident or malfunction.of a:different type is not created. III. No. The addition of the floor penetrations does not affect the margin of safety in the Technical Specifications.
- SE No.: 88-357 Source Document: SXI-30 Descrip' tion of Change Test the AUTO program for the Radvaste Programmable Logic Controllers for.
the A & B-chemical waste tanks.1 Summary See Safety Evaluation 88-255. L
.SE No.: 88-358 ;
[. Source Document: SXI-27 i Description of Change . Test the AUTO program for the Radwaste Programmable Logic Controllers'for the A & B reactor water cleanup backwash settling tanks. Summary-See Safety Evaluation 88-255. l l 1 l- i I- _ _ . - - _ _ _ - _____ - Q
Attachment.3-PY-CEI/NRR-0979 L Page 245 of 278 I SE No.: 88-359 Source Document: DCP 87-0284 ) Description of Change Install "Isolok" Samplers on the 4-inch recycle lines for the spent resin, reactor water cleanup, condensate backwash and fuel pool settling ;
, tanks for radvaste sampling. .
l Summary
]
I. No. All equipment impacted is non-safety and installation location is such that no safety-ralated equipment is in the same room; ! therefore, the probability of an accident important.to safety does not exist. .Since this change is in accordance with the original design the possibility of'an inadvertent release does not exist. II. No. Installation only impacts radvaste, a non-safety system. 'Any failure of this new component or any portion of its installation vill not impact any other component other than the process system . the sampler is Installed on. J III. No. Since only.the-technique of sampling has changed and not,th'e representativeness of the samples, the margin of safety in the Techni' cal Specification bases is not reduced.
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'Attachmant 3 PY-CEI/NRR-0979 L Page 246 of 278
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SE No.'s 88-360-Source Document: DCN-2355, Rev'. O c Description of Change Install' mechanical snubbers (pulsation dampeners) in the impulse lines. upstream of the instruments 1E31-N0084 A/B in the Leak Detection I System (E31).
~
.ni Summary i
'I. No.- Based on'a review of the following sections of the USAR, it has been i concluded that there is no probability of occurrenca or the
{ consequences of.an accident or malfunction.of equipment important to i safety previously evaluated.
~, l 5.2 Integrity of Reactor Coolant Pressure Boundary 5.3 Reactor Coolant Pressure Boundary Materials 5.2.5.2 Leak Detection-Instrumentation and Monitoring j
5.4.6 Reactor Core Isolation Cooling System l-7.4.1.1 . Reactor Core Isolation Cooling (RCIC) System l 7.6.1.3.2' RCIC System Leak Detection ; 15.6.2 Instrument Line Pipe' Break II. No. Since mechanical snubbers are fixed in-line components, data was compiled between 8/24/87 and 9/4/87 with reactor power levels-varying'between 4% and 100%. It was determined than no adverse effects were. identified with regard to the 1E31-N0084A/B transmitter output. Also, repetitive tasks 88-1485 and 88-1486 have been t generated to inspect the snubbers on six month intervals. This-inspection requirement vill eliminate concerns regarding clogging. Therefore, there is no~ possibility for an accident or malfunction of
, a different type then any evaluated previously in the USAR.
III. No. This change does not' involve a change to the Technical Specifications. , Installing mechanical snubbers (pulsation dampeners) in.the instrument impulse line had a significant dampening effect on the 9HZ inherent frequency and other pressure perturbations, thus improving the operability of the E31/RCIC j Systems without compromising the margin of safety as defined in the 1 basis for any Technical Specification. There are no response time requirements for these instruments. ' ? L l' a
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j i Attachment 3 l PY-CEI/NRR-0979 L 1
.Page 247 of 278 SE No.: '88-361 Source Document: FSAR CR 88-242' l' Description'of Change Add a sentence to USAR Section 9.4.3.5.1.c.8 to clarify automatic start of 1the standby exhaust fan 1M38-C002 A/B upon a lov flow signal.from the operating fan in the-Auxiliary Building Ventilation System (M38).
Summary- 1 l I. No. This is not a change but a clarification to the OSAR.' Thus, it is 'j editorial in nature and does not change system design operability. ' II. No. See-Item I above. III. No. This change does not impact the Technical Specifications. i !- l SE No.: 362 Source Document: OM4C: PEI-D23-3, Rev. 1, TCN 2
, Description of Change Change the entry condition to PEI-D23-3 for dryvell temperature control from 135'F to 145'F to reflect the new. Technical Specification LCO.
Summary i I. No.
.In Appendix 1A (NUREG-0737 item I.C.1) the USAR commits Perry to implementing the guidance in the generic Emergency Procedure Guideline (EPG). Revision 3 of the.EPG references 135'F as the entry condition for dryvell temperature. The Perry Specific Technical' Guideline (PSTG) incorporated this guidance by establishing the entry condition at 135'F,' Perry's Technical Specification LC0 at that time. This change meets the intent of.
both the EPG and the PSTG by incorporating the change to Technical Specifications. This change is also consistent with USAR Section 13.5.2.1.6 which describes the Plant Emergency Instructions as the procedures to be utilized during " emergency" conditions (i.e., when dryvell average temperature exceeds the LCO). Since the i EPG is based on evaluation of the transient and accident analysis to 1 provide symptomatic pro:edures, neither the probability nor the consequences of an accident previously evaluated is increased. Likewise, the possibility of an-accident not evaluated is not created by this change as both the change and the EPG have been
. evaluated and approved by the NRC.
II. No. See Item I above.
)
III. No. A' change was made to the Technical Specifications authorized by Amendment 14 to Operating License NPF-58, July 14, 1988. L i a l w___ _ _u_ _ __-- - - - -
l l Attachment 3 I PY-CEI/NRR-0979 L Page 248 of 278-SE No.: 88-363
' Source Document DCP 87-0733, Rev. O Description of Change Interconnect the normal.and alternate level transmitter signals to the
' alternate and normal' drain controller.on the 5A and 5B feedvater heators and the moisture separator reheater drain tanks. This vill assist ) Chemistry in keeping the conductivity of the reactor water down during { startup by providing-the ability to swap the level inputs from the l normal / alternate level transmitters to the alternate / normal drain I controllers respectively, without causing any heater isolations or level oscillations. Summary I. No. 'There is no increase in the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated, since the system analysis has shown that failure of the.high pressure heater drain and vents vill not compromise any safety related systems or prevent safe shutdown. II. No. The possibility for an accident or malfunction different from those previously evaluated has not been increased, because the same design and installation parameters were taken into account in the evaluation of this installation. III. No. This installation vill not affect the margin of safety defined in the bases of the Technical Specifications, since the system function ' is not changed or reduced. T L
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Attachutnt 3
;4, PY-CEI/NRR-0979'L Page:249'of 278' ,
, i SE No.: 88-364 Source Document: DCP 87-0718, Rev. O i
Description of' Change '
' Hove thermostat M21-R150 from the Health Physic. 0ffice to the Radiation. .
Protection Office. This places the thermostat in an area served by duct- l heater M21-B002C, so that it vill be able to properly' control temperature. Change to USAR Figure 9.4-2. Summary I. No. - This change enhances temperature control, but the operation of-the . system remains unchanged; therefore, the probability of occurrence of an accident is not increased. " II. No. The M21 system (Controlled Access HVAC) is nonsafety-related. No .. protective devices are changed, and therefore a different type of I accident is not created. III. No. No Technical Specification margin of safety is impacted by this change. SE No.: 88-365- i Source Document: DCP 88-0057, Rev. 0 Description of Change l This design change replaces relay contacts with switch contacts to, eliminate the impact of power bus failure on,the Main Steam Isolation Valves (MSIV's) closure logic. Indica don: lights will be powered-from I the opposite buses. Presently, the manual closure logic of the'MSIV's is such that losing pver from either Bus A or B will result in' either the outboard or inboard valves going open. Also, all indication ~ lights are powered from Bus A. Summary q I. No. Ability to isolate the main steam lines as required by the Safe Shutdown capabilities Report (SSCR) at the alternate shutdown panel during a Control Room fire is not affected. This change does not substantially alter the combustible loading in any plant area. The~ . fire protection program is not adversely affected; thereforu, this ! change does not increase the probability of occurrence or the I consequence of an accident as described in the USAR. II. No. The probability and consequences of a fire are not changed by this DCP; therefore, this change does not create the possibility of an accident or malfunction of a different type than described in the USAR. I III. No. Technical Specification Section 3/4-3.7.4 requires remote shutd an capability. This capability is not affected by this change. No
'other portion of the " Bases Section" is applicable to Fire Protection.
l i i Attachment 3 PY-CEI/NRR-0979 L Page 250 of 278 SE No.: 88-366 Source Document: HFI 1-88-132 Description of Change Provide a temporary means of controlling 2C Heater Level upon failure of normal and alternate drain level controllers by adding temporary level indication and re-routing N26-F070C alternate drain valve position demand signal to a temporary controller in the Low Pressure Heater Drains and Vents System (N26). , Summary I. No. By controlling the Heater 2C alternate drain valve, level vill be maintained at the same or lower than normal elevation which does not increase the accident or malfunction probability previously evaluated in the USAR. i By re-routing Heater 2C drains, a small reduction in final feedvater temperature vill occur, but well within the 100*F reduction allowed by USAR Chapter 15 Appendix D. f II. No. A different type of accident or malfunction than previously e evaluated in the USAR is not created. III. No. This MFI does not affect the margin of safety for any Technical Specification. Technical Specification Section 3.3.1 accounts for this with reduced setpoint penalties. SE No.: 88-367 Source Document: HFI 1-88-134 Description of Change I This MFI will cause the 6A Feedvater Heater alternate drain level controller to operate the normal drain valve, and the normal drain level controller to operate the emergency drain valve in accordance with TXI-060. This vill prevent an increase in reactor water conductivity after placing Feedvater Heater 6A in service. Summary I I. No. Feedvater Heater 6A drain control does not affect the probability or consequences of any accident or malfunction as described in USAR Chapter 15. II. No. Feedvater Heater 6A drain control vill not result in an accident or malfunction of a different type than previously described in the USAR. III. No. Feedvater Heater 6A drain control is not a factor impacting Technical Specification bases.
Attachment 3 PY-CEI/NRR-0979 L Page 251 of 278 SE No.: 88-368 } Source Document: DCP 88-0259 Rev. O Description of Change Replace reactor feedvater booster pump seal water piping on reactor feedvater booster pumps (IN27-C001A,B,C,D) with piping of all velded construction, instead of threaded connections. Also add 1/2 inch bypass line from the discharge pipe to the suction side of the pump. Summary I. No. This modification does not increase the probability of occurrence of an accident as this line is already discussed in the USAR. II. No. The use of velded connections helps prevent leakage caused by line vibration. The line remains the same, therefore, there is no different type of accident created than previously evaluated. III. No. The reactor feedvater booster pump seal water discharge lines are not addressed in the Technical Specifications. SE No.: 88-369 Source Document: FSAR CR 88-231 Description of Change Change Sections 3.11.2.1.3.5 and 3.11.6 of the USAR to reflect the original and current qualification requirements for NSSS mild environmental zone equipment as addressed in Section 1.8-1 of the USAR and editorial changes on sequencing of references for Section 3.11. Summary I. No. These changes do not increase the consequences of an accident or malfunctions of equipment. They reflect the actual and original qualifications for NSSS mild environmental zone equipment. II. No. These changes are corrections to reflect equipment qualification requirements. They do not create the possibility for an accident or malfunction not previously addressed in the USAR. III. No. These changes do not affect the margin of safety as defined in the Technical Specifications.
Attachment 3 PY-CEI/NRR-0979 L Page 252 of 278 SE No.: 88-370 Source Document: FSAR CR 88-231 Description of Change Change Section 3.11.3.2 of the USAR to reflect the auditable file package format for Class 1E equipment located in a harsh environmental zone. Summary I. No. These changes reflect the format of equipment qualification auditable file package and do not increase the probability of occurrence of an accident or malfunction of equipment. II. No. See Item I above. III. No. These changes do not reduce the margin of safety as definei in the Technical Specifications. SE No.: 88-371 Source Document: FSAR CR 88-232 Description of Change Change Sections 3.10.1.1.3.4 and 3.10.5 of the USAR to reflect the actual qualification of the plant. Summary See Safety Evaluation 88-369.
Attachment 3 PY-CEI/NRR-0979 L-
- Page 253 of 278 SE No.: 88-372 So,urce Document: FSAR CR 88-232 Description of Change Change Sections 3.10.1.4.1 and 3.10.2.1.3.1 of the USAR to reflect the actual minimum frequency to which hydrodynamic loads are considered per Perry's Equipment Qualification Program.
Summary I. No. These changes do not increase the probability or consequences of an accident or malfunction of equipment. They reflect actual qualification criteria for NSSS equipment. II. No. These changes are corrections to reflect equipment qualification requirements, they do not create the possibi?ity for an accident or malfunction not previously addressed in the USAR. III. No. These changes have no effect on the margin of safety as defined in the Technical Specifications. SE No.: 88-373 Source Document: FSAR CR 88-232 Description of Change Change Section 3.10.4.1 of the USAR to reflect the information as it appears on the Equipment Qualification List and data base. Sumfaary I. No. These changes are to the equipment qualification list and do not increase the probability of occurrence or consequences of an accident. II. No. See Item I above. III. No. The changes have no effect on the margin of safety as defined in the Technical Specifications.
E
# Attachmsnt 3
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'Page 254 of 278< l 1
'SE No.: 88-374 Source Document:- I FSAR CR 88-232
{ Description of Change 1 Change Section 3.10.4.2 of the USAR to reflect the requirements for { Class lE mild and seismic auditable file packages.
]
Summary See Safety Evaluation 88-370.
.SE No.: 88-375 Source Document: DCN 2377 Description of Change-Install three 3-inch pitot taps and isolation valves with 2-inch penetration into the circulating vater pipe (N71 System).
. Summary i
I. No. The installation'of.the pitot taps and valves meets the USAR 3 requirements and does not increase-the probability of occurrence of an accident. II. No. The installation of the pitot taps and valves will not change the original ~ function of the circulating water system. Therefore the probability of an accident or malfunction of a different type than any, evaluated previously in the USAR does not exist. III. No. The circulating water system still retains its original function with the' installation of the pitot taps and valves. This system is not addressed in the Technical Specifications. The modification vill not affect the operability or the availability of this or other systems.
+ ' l s Attachhant 3 ) PY-CEI/NRR-0979 L Page 255 of 278 SE No.: 88-376 ' i Source Document: DCP 87-0443, Rev. 0 l Description of Change. , g Install test cards in APRM channels to consolidate Neutron Monitoring System ~(C51) SVI test points, end to eliminate the lifting lead rathod of 1 performing SVI tests. This provides for a safer, more reliable end convenient means to comply with Reg. Guide 1.118 "Periedic Testing of Electrical Power and Protection System". ;
' Summary I. No. Since each component is qualified, the design change vill not reduce the overall reliability of the safety-related system relative to performing its safety function. It does not result.in a reduction in redundancy'of the system, nor does it reduce the margin for <
safety in the repetitive testing as required in Reg. Guide 1.118. ' II. No. The addition of viring changes and test cards will not create a condition or accident, which has not been pr3viously evaluated in the USAR. The use of test. cards is an improvement over lifting leads. (Ref. letter PY-CEI/NRR-0307L). No new or different ! accident / malfunction than what has previously been considered in the USAR is created. l III. No. This design change does not affect the scope of the Technical Specifications relative to a potential reduction in safety. Conversely, this design change enhances the practical aspects and parameters required for testability cf system and components resulting in increased margins of saiety.
- i. .
a. Attachment 3 ) PY-CEI/NRR-0979 L l s Page 256 of 278 1 SE No.: 88-377' Source Document: DCP 87-0544, Rev. O Description of Change Modify the Hydrogen Control System (M56) circuitry to ensure that the ignitors will not auto start after a loss of povor. Summary I. No. The Hydrogen Ignitor System is utilized for beyond design basis scenarios and is not analyzed with respect to the accidents analyzed in Chapter 15 of the USAR. Therefore, the probability of occurrence or the consequences of an accident analyzed in the USAR is not increased. This design change is consistent with the. Chapter 6 wasign basis, which says that the " Hydrogen Control system is , secured if power to the ignitor is lost and hydrogen concentrations inside the dryvell or containment.cannot be determined to be below predetermined limits". This function vill now occur automatically instead of manually. The new control circuit is designed so that the probability of malfunction is not increased over the old design. In addition, the circuit meets single failure criteria and has not introduced any comtron mode failures, which ensures that the consequences of a malfunction of this equipment is not increased. II..No. The new design does not create an accident or malfunction previously un-analyzed, since it performs the same function as before, except it does so automatically rather than manually.
< III. No. This logic change does not impact Technical Specification, Section 3.6.7.3.
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_,_. _7 _ _ ------ - ---- p y [ V, h( ;\ , b N' Attachmant.3 .. . 3 'y' PY-CEI/NRR-0979 L-4': i',
'Page 257 of;278, !
SE No. : ' ' '88-378:
' Source Document: PTILP45-P001, Rev, 5,;TCN-3 Y i PTI-P45-P002, Rev. 5, TCN-4 ,
i. AL Des'criptfon of Change. '
\ Incrdose Emergency Service Water (ESV-P45) flow fkom?7 ,300 gpm to l: 7,900Egpm through the RHR her.s v ' igers . This al.lovs.the 3HR heat: _
s exchangtrs to' maintain-their des :,,n sia heat' transfer;wita an ESV inlet ; temperature up to 84.4*F. ' ] a
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g" , '\ Summary..
- '1' >
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' . I . No . , By increasing the flow through the RHR heat exchangers.to 7,900 gpm,
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< . the ESV pumps will be operating-at their' design flow, and1therefore, -
<. the. probability of \a malfunction of the pump is not increased.
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3
. II. No. . -This chan'ge does. tiot create a different type of. accident than previously evaluated in USAR Chapter 15, Accideht' Analysis. > 3
\
31 ' III. No. xIncreasing'the. flow through the RHR heat exchangdes)to'7,900 gpm, 3 while maintaining diesel heat exchanger flow and ECC~ heat exchanger
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. flow at their_present values,'will increase the cooling capacity, and' consequently,Jthe margin of safety of ESV'to cool the i RHR heat- '
- exchanger.
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i Attachment 3 I PY~CEI/NRR-0979 L Page 258 of 278 i SE No.: 88-379 i 1 Source Document: DCP 86-0401, Rev. 4 Description of Change This design change originally entailed the addition of tvo pressure svitches to monitor the left and right bank starting air pressure on the Division 1 and 2 standby diesel generator. These pressure switches actuate a diesel generator inoperable. alarm when starting air pressure drops below the 150 psig setpoint. This evaluation analyses the removal of the Division 1 pressure switches (1R44-N256A and -N257A) from this DCPs workscope. 'these changes for the Division 1 diesel generator are \ incorporated into DCPs 87-0276A and 87-0276C. (Electrical Evaluation) Summary I. No. This change does not increase the probability of occurrence of an accident evaluated in the PSAh because its scope is limited to the standby diesel generators which alone can not cause a design basis accident. The pro, aed subject design change agrees with the FSAR commitment, i.e., "DG Out of Service" alarm activates when starting air supply is less than 150 psig. This change is consistent with~the existing design and maintains the original design parameters as evidenced by the acceptable equipment qualification evaluation and the design input record. The design equivalency between the original design and this design change, which is the basis for this design change demonstrates that the likelihood of an equ.i.pment malfunction' is the same as the original design. Hence the probability of a malfunction of equipment is unchanged. The consequences of an accident or malfunction of equipment are unchanged with respect to the design change based on the equivalency of the designs also; that is, the consequences of the failure of the subject change would be the same as any similar failure of the original design. Additionally, a malfunction of equipment might be diagnosed earlier or more precisely as the result aof the subject changa. (Refer also to summary for SS 88-0380 that follows.) II. No. See Item I above. ' III. No. The Technical Specification is not changed by this change; hence, the margin of safety as defined in the Technical Specification (Refer to 3/4-8) remains unchanged.
Attachment 3 PY-CEI/NRR-0979 L : Page 259 of 278 l SE No.: 88-380 Source Document: DCP 86 -0401, Rev. 4 Description of Change The detailed scope of this design change entails the addition of two ! pressure switches which monitor the lett and right bank starting air j pressure on the Division 2 standby diesel generator. These pressure j switches actuate a diesel generator inoperable alarm when starting air j } pressure drops below the 150 psig setpoint, which is also the start ' signal interlock setpoint. The workscope for the Division 1 diesel generator is incorporated into DCPs 87-0276A and 87-0276C. (Mechanical Evaluation) Summary I. No. This change does not increase the probability of occurrence of an accident as it is limited in scope to the standby diesel generators which alone cannot cause a design basis accident. This changa is installed in a similar manner as the original ; installation. The parts used are identical to those used in the ; originally qualified installation. Environmental and seismic qualification of this design change is in accordance with the original design requirements as evidenced by its acceptable Equipment Qualification evaluation. Hence, the installation and performance of this design change is equivalent to that of the original design, and therefore, the probability of occurrence of a malfunction of equipment is not increased. The consequences of an accident as evaluated previously in the USAR remain unchanged with respect to this design change. This change is implemented with similar installation standards, and equivalent i performance and qualifications of the original design. This change is limited in scope to diesel generator alarm functioni and has no effect on actual diesel generator control or automat; response to emergency signals, he. nee, the response of the plant to mitigate the consequences of an accident is not affected by this design change. Additionally, this design change does not compromise the redundancy p of the Division 2 standby diesel generator starting air system i because it adds no cross connections between redundant starting air trains. Also, this change does not compromise the redundancy between the Division 1 and 2 diesel generators since Division 1 is i not affected by this change and no interdivisional connections are } added by this change. Hence, in the event of a malfunction of equipment previously l evaluated in the llSAR, the plant's response is unchanged with l respect to this change. Therefore, the consequences of a malfunction of equipment is unchanged.
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a Attachment 3 i PY-CEI/NRR-0979 L Page 260 of 278 SE No.: 88-380 (Continued) ] Summary (Continued) II. No. No possibility for an accident of a different type than any evaluated previously is created by this change since it is limited in scope to the standby diesel generators which alone cannot cause a design basis accident. No possibility for a malfunction of a different type thaniany , evaluated previously is introduced by this change since the original i insta)1ation standards, component performance, system function, system redundancy, and overall reliability is maintained with respect to the original design. (As described in Item I above.) III. No. The margin of safety as defined in the bases of Section 3/4-8 of the Technical Specifications relates to the independence and redundancy of the onsite power supply. This is not affected or compromised as the result of this change and hence the margin of safety is r.ot reduced. SE No: 88-381 Source Document: DCP 87-0684, Rev. O Description of Change This modification affects the Division 1 and 2 Diesel-Generator lube oil supply configuration for the turbocharger and for the rocker arms as shown on USAR Figure 9.5-11 and as described in USAR Section 9.5.7. For this modification, a new cross-tie line with a manual ball valve is being installed between the " bypass" riser to each turbocharger lube oil drip assembly and the " normal" lube oil supply line to each turbocharger downstream of the 1 1/2" 0 rocker arm / turbocharger lube oil supply header. Each ball valve vill be throttled so as to provide rocker arm prelube oil flow without significantly reducing flow to the turbocharger lube oil drip system when the " bypass" line ball valve is opened three to five minutes prior to planned engine starts. This modification includes the provision for temporary sight glass installation in each " normal" supply line to aid in balancing lube oil flow. This modification also revises the touting of a RB " normal" lube oil supply to provide additional spacing away frota hot turbocharger / exhaust surfaces as well as modifying other associated tube routings to accommodate intercooler adapter access and support changes. Oil spray deflectors at tube fitting locations are also being added per DCP-870684A to re-direct any oil opray away from hot. turbocharger / exhaust surfaces.
l Attachm:nt 3 ' PY-CEI/NRR-0979 L Page 261 of 278 SE No.: 88-381 (continued) Summary I. No. This modification to the Lube 011 System has no significant affect on the existing " normal" supply line to each turbocharger other than the addition of temporary sight glass connections and minor configuration changes involving tubing and fittings.
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The probability of an accident or fire resulting from tube fitting l failure is diminished by the addition of oil spray deflectors at ' appropriate locations to prevent oil from coming in contact with hot surfaces such as exhaust manifolds and turbocharger casings. This modification also has no significant impact on the turbocharger lube oil drip system because cross-connection supply to the rocker arms will only be utilized during a three to five minute period prior to Diesel-Generator engine start when the j " bypass" valve is open. In the event of an accident, the plant's response to mitigate its consequences would be unchanged and thus the consequences of the accident would not be affected by the design change as described above. In the event of any malfunction of equipment, the Standby Diesel-Generators' response, and the response of the Lube Oil System would be unaffected. This design change does not affect component or system reliability, qualification, redundancy, or function, llence the consequences of a malfunction of equipment evaluated previously is unchanged, i II. No. No potential for a different type of accident is created by this design change as it is similar to the original design and does not compromise it. This design change maintains the equipment and system reliability, qualifications, redundancy, and function of the original design. Since all of the original design requirements are maintained, no potential for a malfunction of a different type than any evaluated previously is introduced by this design change. III. No. The margin of. safety as described in the Bases of Technical Specification Section 3/4.8.1 refers to on-site power supply reliability. Since reliability is not compromised by this change, the margin of safety is not reduced.
Attachment 3
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PY-CEI/NRR-0979 L Page 262 of 278 SE No: 88-382 } Source Document: DCP 87-0713, Rev. O Description of Change Provide an interlock between the sample pump (C5029) start /stop logic and the sample chamber high/ low flow alarm annunciation of the radiation monitor log ratemeter (D17K606). This vill create a permissive signal which vill allow annunciation only when radiation monitoring sampling is in operation. This vill eliminate a Control Room nuisance alarm. Summary I. No. This design change is the result of eliminating the unwanted annunciation of the high/ low sample flow alarm of the radiation monitor < log ratemeter (D17-K606) displayed on Control Room Panel lH13-P906. Currently, due to no flow conditions when the radiation monitor is not in use (the unit is only operated when discharging Emergency Service Vater to the lake), continuous alarms exist resulting in a nuisance during plant operations. The modification incorporates a relay that is interlocked between the sample pump start /stop logic and the sample chamber high/lov flow annunciation system. The result is a permissive signal to annunciate ONLY vhen radiation monitoring is in operation. The interlock has no effect on the design bases (USAR 11.5.2.7.9.1), nor does it affect the upscale trip logic that is used to initiate a closure of the radvaste system discharge valve. It does not change any of the existing design'and control logic that is necessary to control the amount of radioactive vaste discharge to the environment. Based on this premise the probability of occurrence of an accident or malfunction of safety related equipment previously evaluated in the USAR is not increased. II. No. The USAR design basis has not changed nor has the system function been affected. The design objective, which is to initiate appropriate protective action to limit the potential release of radioactive materials to the atmosphere, is not compromised. This change, therefore, does not create a possibility for accident or malfunction other than those previously analyzed in the USAR. III. No. The LC0 for Technical Specification 3/4.11.1 remains unchanged as a result of this DCP. The DCP which eliminates a nuisance alarm does not affect the technical requirements specified in Technical Specification 3.11 1.1. The margin of safety as defined in the Technical Specification is therefore not decreased.
Attachmant 3-
.PY-CEI/NRR-0979 L Page 263 of 278 SE No.: 88-383 Source Document: ' HFI 1-88-140 Description of Change l l l
l Provide manual control of-the following High-Pressure Heaters, Drains and I Vents (N25) system drain valves: IN25-F165A, F175A, F240A, F250A, and i F240B. Provide an alternate level input to the normal controller ! 1N25-R220A and R540A. 0 1 Summary I. No. This mechanical foreign item (MPI) does-not affect any accident or i malfunction of equipment previously evaluated in USAR, Chapter 15. II. No. This MFI does not override any alarms, isolation trips or control valve failure design features.
.III. No. This MFI does not affcet any margin of safety for any Technical Specification.
SE No.: 88-384 Source Document o DCP 88-0097, Rev. O Description of Change Install seal-in ci~rcuit for the Reactor Core Isolation Cooling (RCIC-E51) system manual initiation pushbutton. Summary i I. No. ! This modification installs a seal-in circuit for the RCIC Manual Initiation Pushbutton S-37 so that the operator does not have to hold the pushbutton for 2 seconds. The seal-in circuit ensures that the valve F045 is open when RCIC is initiated. The valve line-up sequence is not changed, nor is any other functional requirement, described in USAR Sections 5.4.6 and 7.4.4. Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the USAR is not increased and the possibility of an accident or malfunction of a different type than evaluated in the LISAR is not created. II. No. See Item I above. III. No. Technical Specification 3/4.7.3 is not affected by this change. L
Attachment 3 )' FY-CEI~NRR-0979 L Fage 264 of 278 SE No.: 88-385 Source Document: FSAR CR 88-258 Description of Change 1 Evaluation of a USAR change request to Sections 5.4, 6.2, 9.2, 9.4 and 9.5 to evaluate the impact of increasing the Emergency Service Vater (ESV) inlet temperature from 80*F (analytical design basis) to 82.2* @ 7,300 gpm flow and 84.4*F 0 7,900 gpm. Lake Erie temperature exceeded 80*F at the ESV intake. Summary The Emergency Service Vater (ESV) System serves as a decay heat
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I. No. removal system via the RHR heat exchangers. Engineering has performed a calculation with the ESV inlet temperature of 82.2*F
@7,300 gpm and 84.4'F of @7,900 gpm. The results do not change any of the RHR heat exchanger shell side inlet and outlet and tube side outlet design basis temperatures, therefore, there is no effect on the decay heat removal capabilities of the system. Engineering has also evaluated the impact of the higher temperatures or the other support equipment supplied by the ESV system and has determined that it has no effect on its performance. Therefore, the probability or the consequences of an accident or malfunction, previously evaluated is not increased.
II. No. No other design basis parameters are changed by increasing the ESV temperature as described above; therefore, no new accident or malfunction is created. III. No. From the calculational analyses performed, it is concluded that the increase in ESV temperature from 80*F to 82.2*F @7,300 gpm and 84.4'F @7,900 gpm, does not impact the interfacing systems' design basis parameters nor the basis to the Technical Specifications. Thus, margin of safety is not reduced.
Attachment 3 PY-CEI/NRR-0979 L Page 265 of 278 SE No.: 88-386 Source Document: DCN 2384 Description of' Change This drawing change notice (DCN) adds four design flags at the Steam Jet Air Ejectors (SJAE) of the Condenser Air Removal (N62) system to indicate their desten conditions on the corresponding P&ID, D-302-131. Summary I. No. This DCN vill not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as defined in the following sections of the USAR: Section 11.3 addresses the Condenser Air Removal System. This DCN vill not change the original function of the system as described in Sec. 11.3 and the sections referenced in Sec. 11-3; USAR Section 15.7.1 addresses the failure of the Air Ejector Discharge Lines to the offgas system. This DCN does not affect USAR Section 15.7.1 in any way. II. No. This DCN vill not change the original function of the Condenser Air Removal System, as mentioned in Item I of this evaluation; therefore, the probability of an accident or malfunction of a different type than any evaluated previously in the USAR does not exist. I1I. No. The Condenser Air Removal System still retains its original function with the addition of the design flags to P&ID 302-131. This DCN will not affect the operability or availability in Technical Specifications of the Offgas System (Base 3/4.11.2.4) or the Ventilation Exhaust Treatment System (Base 3/4.11.2.5). Neither hydrogen nor any other explosive gas mixture concentration in the Technical Specifications will be increased (Base 3/4.11.2). The restrictions on the gross radioactivity rate of noble gases from the main condenser (Base 3/4.11.2.7) vill not have a reduced margin of safety as defined in the Technical Specifications as a result of this DCN.
Attachment 3 PY-CEI/NRR-0979 L Page 266 of 278 SE No.: 88-387 Source Document: FSAR CR 88-259 Description of Change Revise the maximum allovable temperatures for the Emergency Service Vater (ESV) inlet from 80*F to 95'F, and the Service Water (SV) inlet from 80*F to 81*F. Summary I. No. Raising the ESV System temperature from 80*F to 85'F (using 7,300 gpm flow through the RHR Heat Exchangers) has been evaluated against the DBA analyses and the results show that Dryvell, \' Containment and Suppression Pool design parameters of 185'F and 15
\ psig are not exceeded. A review of the 5'F increase against the s
performance of the individual equipment and associated sub-systems shows that there is no impact on system operation and safe shutdown of the plant. Thus, the ESV system vill perform its decay heat removal capability as described in the USAR and maintain safe shutdown of the plant. Raising the inlet temperature of the SV system from 80'F to 81'F has been evaluated and it has been concluded that the l'F change is insignificant with respect to the non-safety cooling functions of the system. Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the USAR is not increased. II. No. Evaluation of the performance of the ESV pumps, ESV screen wash system equipment, RHR Heat Exchangers and other safety-related equipment supplied by the ESV system with a 5'F increase in the inlet water temperature shows that there is no effect on safe operations and shutdown of the plant. Thus, no new accident or malfunction of a different type is created. Raising the SV inlet temperature by l'F does not create an accident or malfunction of a different type than any evaluated in the USAR. III. No. From the analyses performed, it is concluded that increasing the ESV temperature by 5'F does not impact the containment design basis parameters nor the basis which the Technical Specifications are based on. Thus, margin of safety is not reduced. SV is a non-safety system which is not covered by the basis of the Technical Specifications.
l Attachment 3 PY-CEI/NRR-0979 L Page 267 of 278 SE No.: 80-388 ] Source Document: SXI-0028 Description of Change Performance of Special Test Instruction (SXI)-0028, Radvaste Programmable Logic Controllers A&B Chemical Vaste Distillate Tanks A5B Auto Program Test. Summary I. No. The performance of this Special Test does not increase the probability of a radioactive liquid release, because any discharges vill be controlled by SVI-G50-T5266, Liquid Radvaste Release Permit. II. No.. This test does not change any design configuration; therefore, there is no change in evaluated accidents or malfunctions. III. No. The performance of this test does not affect any Liquid Radvaste discharges. Any discharges vill be controlled by SVI-G50-T5266.
'l SE No.: 88-389 Source Document: DCP 87-0739, Rev. O Description of Change Crud accumulation is restricting flow of the Turbine Building Closed Cooling Systein (TBCC-P44) to the Feed Vater Booster Pump 1N27-B007A,B,C,D Hotor Coolers. This design change installs four, in-line strainers, three low point drains and the associated differential pressure instrumentation. These additions vill allow flushing of these cooling water lines during operation.
Summary I. No. The turbine building closed cooling system is not required for safe shutdown of the reactor. (USAR Section 9.2.9.3) II. No. This is a preventative maintenance modification. It will improve the reliability of the Reactor Feed Booster Pump Hotors. III. No. No plant component or system is changed in a manner which would affect Technical Specifications.
Attachment 3 PY-CEI/NRR-0979 L Page 268 of 278 \ SE No.: 88-390 3 Source Document: DCP 88-0124, Rev. O Description of Change Installation of automatic temperature regulating valves to the Turbine Building Closed Cooling (TBCC) (P44) system inlet to the Motor Feed Pump (HFP) Lube Oil Cooler, IN27-B005A&B. Also a temperature sensor vill be installed on the oil outlet side of the HFP Lube Oil Coolers to control the new TBCC automatic regulating valves. Summary I. No. USAR Section 10.4.7.2.4. does not address the failure of the HFP or of the HFP lube oil cooler IN27-B0005A&B. Therefore, the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the USAR has not increased. The Turbine Building Closed Cooling System (USAR Sect. 9.2.9.3.) is nonsafety-related and is not required for safe shutdown of the reactor, see Feedvater system discussion above. II. No. The portion of the Feedvater System which is affected by this design change is nonsafety-related. The addition of the TBCC temperature regulating valves and the N27 (lube oil) temperature sensor vill not change the overall design function of the HFP Lube Oil system but, vill rather increase the HFP reliability. The installation of the flow control valves / sensor and piping vill meet all applicable codes (B31.1). Therefore, the possibility for an accident or malfunction of a different type than any evaluated previously has not been created. III. No. The portion of the Feedvater system which is addressed in the Technical Specifications is not affected by this design change. Turbine Building Closed Cooling system is not addressed in the Technical Specifications.
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- J 6 Attachment 3 !
D PY-CEI/NRR-0979 L Page 269 of 278 L
'SE ' No . 's - ~.' d 8 -3 91.
I: Source Document:' DCN 2385 USAR CR 88-267 i. l-Description of Change ' l Evaluation of a USAR change ~ request to Section 9.4'.1.3. and Figure 9.4-1 i (drawing change notice' applies to this figure) to indicate that local: 't smoke detectors do not send a signal.to automatically close the 1 corresponding fire dampers for the MCC Switchgear and Cable Spreading Areas. Remoto damper actuation is not necessary since local fusible link 1 i n capability exists. . This change is intended to eliminate the possibility 1 l of remote. damper closure during velding/ maintenance or other smoke / dust ! generating evolutions in adjacent areas. Summary LI. No. The probability,of occurrence or the' consequences.of a malfunction l-are not increased since local fusible link capability continues to exist. This(USARichange request aligns the vording in Chapter 9.4
- to' reflect the changes to Electrical Lineup Instruction.(ELI) R25-c <
' TCN 5, and FSAR Chr.nga Request 88-088. A separate evaluation.
.(SE 88-133).vas performed to support FSAR Change Request 88-088,
' which eliminates the refe' rent.e in the USAR (Section 9A.4) to fire -
.. damper actuation ~ from sinoke detector panels.
a
~II. No= The possibility,for.an accident or malfunction of a different type y'~ , ' than previodsly' + evaluated in the USAR is not created since the
. dampers vill operate with the fusible links. Since the spaces supplied.by.these dampers are not CO r Halon protected, the 2
capability for remote closure is not necessary to contain the 1 CO 2 /Halori in the event of fire. This change lessens the-possibility of an' accident not previously evaluated since it . l "i reduces the possibility of. isolating ventilation to spaces ' containing safe shutdown equipment. i III..No.- The margin of safety as defined in the Technical Specification 1 Bases is not reduced as a result of'this change. In fact.the { margin of safety associated with equipment redundancy which is addressed in the bases.'of Section 3/4.8 (Electrical power systems) ; is increased since the probability of unnecessary damper closures i is reduced. I l
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Attachment 3 PY-CEI/NRR-0979-L Page 270 of 278 SE No.: 83-392 Source Document: DCP 85-0558, Rev. 1 Description of Change Replace Residual Heat Removal (RHR-E12) Dresser valve 1E12-F102 with a Kerotest packed valve. Permanently lock closed check valves 1E12-F103A&B, and F104A&B so that they act as locked closed valves. They are no longer required to provide vacuum protection (see Safety Evaluation 88-325 which addresses this area). Summary I. No. The modification / alteration to the RHR vacuum line maintenance isolation valve in no way affects any componeit or system which could cause the probability of occurrence of an accident or transient (USAR Chapter 15) to increase. Replacement of an existing 1 1/2 inch diameter Dresser diaphragm globe valve with a 2 inch diameter " packed" Kerotest globe valve does not increase the probability of malfunction of equipment. The new globe valve is more reliable than the existing Dresser valve when performing system testing or maintenance. The consequences of an accident, as stated in the USAR (Chapter 15) are not increased by this removal of the existing Dresser valve and replacing it with a " packed" Kerotest valve. This DCP is unrelated to Chapter 15 accidents such as " Inadvertent RHR Shutdown Cooling Operation" or " Failure of RHR Shutdown Cooling". Replacing the existing " passive" valve with a " passive" valve does not negatively affect safety. The consequences of failure of equipment important to safety are not increased by this design change where a Dresser globe valve is being replaced with a Kerotest valve. The new Kerotest valve meets the design requirements (ASME III) of the existing Dresser valve. II. No. The proposed clarification to the USAR vould not create a new type of accident or malfunction. This change does not relate to events or disturbances that are considered as potential initiating causes of threats to the fuel and/or the reactor coolant pressure boundary. III. No. The margins of safety as defined in Technical Specifications 3/4.4.9, 3/4.5, 3/4.6.3, 3/4.9.11 are unchanged and unaffected by this proposed modification to the RHR vacuum system. This design change vill remove the troublesome Dresser valve and allow operators to isolate the RHR system as necessary to perform maintenance. Retesting per PTI-GEN-P0009, Dresser Valve Operability Testing, vill no longer be required.
v Attachment 3 PY-CEI/NRR-0979 L Page 271 of 278 SE No.: 88-393 Source Document: DCP 88-0144, Rev. O Description of Change l This design change installs local instrumentation and a level alarm (High) in the Control Room to monitor the Condensate Storage Tank (CST) dike level. Summary I. No. Addition of level instrumentation to the condensate storage tank's retaining basin and the addition of a 1 inch bypass line and valve around drain valve 1P11F0622 does not increase the probability of an accident or malfunction of equipment important to safety as described in the following sections of the USAR. The level indicators, alarms and bypass line vill prevent water from ( collecting in the retaining basin and possibly freezing the impulse lines to the high and lov vater alarms for the CST. Section 9.2.6 of the USAR describes the condensate storage facilities. This DCP does not affect this section of the USAR. Sections 6.3.2.2.1 and 7.4.1.1 describe the CST's role in the HPCS and RCIC systems operation. This DCP does not affect these sections of the USAR. Figure 9.2-13 (P&ID 302-102) vill be changed to indicate the level instrumentation additions, the bypass line and valve, and that valve 1P11F0531 is being changed from normally closed to normally open. USAR Section 3.5.1.4 states "....to prevent an uncontrolled release of radioactive liquid and to provide a minimum 150,000 gallon reserve for the RCIC and HPCS Systems, the tank is located within a Seismic Category I concrete dike". The statement "and to provide a minimum 150,000 gallon reserve for the RCIC and HPCS Systems" falsely implies that the CST is a safety related source for the HPCS and RCIC Systems. For consistency with USAR Section 5.4.6.1.5, the statement "and to provide. . .RCIC and HPCS Systems" will be deleted. II. No. This DCP will not change the intended function of the system. Therefore, there is no newly created possibility for an accident or malfunction of a different type than previously evaluated in the USAR. See Item I of this evaluation for a detailed description. III. No. The CST is discussed in Sections 3.5.2.e.2, 3.5.3.b.3, 4.5.2.2, and 4.5.1 of the Technical Specifications. The level instrumentation to the CST dike basin and bypass line and valve vill not reduce any margin of safety as defined in the Technical Specifications.
Attachment 3 PY-CEI/NRR-0979 L Page 272 of 278 SE No.: 88-394 Source Document: DCP 85-0295, Rev. O Description of Change Add supply line from the Two-Bed Demineralized (P21) and drain line to the Floor and Equipment Drains (P68) system for the decontamination sink in the Small Tool Decontamination Room, in the Intermediate Building on the 574 foot elevation. Summary I. No. A drain extension off of the Intermediate Building Tool Decontamination Room Sink to an existing floor drain has no impact on any equipment important to safety. Sink and floor drains are non-safety. (USAR Section 9.3.3). II. No. The scope of this DCP is simply to route the discharge from the Tool Decon. Room sink to the existing floor drain system (574'-10" Intermediate Building). The discharge line is hard piped along the vall to avoid any potential safety hazard. There are no new accident or malfunction possibilities created by this design change. III. No. This minor drain line modification to properly route sink discharge does not affect the Technical Specifications. The DCP does not reduce the margin of safety as defined in any bases of Technical Specifications.
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, y Attachmznt 3 l l
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PY-CEI/URR-0979 L 7) i Page 273_of 278. ~ i SE No.:? "08-395-r Source' Document: USAR CR 88-249- d L
' Description'of Change. ]
Evaluation of a USAR< change request _to Table 3.7-1 to allow the,use of- l ASME Code _ Case.N411 for diesel' engine / skid piping and' tubing stress'
- analysis.
3
- Summary I (I..No. The use of Code Case N411.is for piping. stress analyses ;
reconciliation. purposes only. No changes:in allowable piping- tj stresses.or any other changes.in materials,. installation
' procedures, inspection, or' testing.are caused by invoking ASME Code Case N411. '
The limiting conditions associated with the Code' case as listed in the description above villzbe strictly followed for all Diesel l r Generator (DG) engine / skid mounted piping stress analysis reconciliation activities. Meeting these requirements as defined' in Revision 24~.of Reg. Guide 1.84, which provides for the use of the subject Code -Case, essentially 'specifles design / analyses e parameters that vill not compromise the piping / tubing'on the DG engine or skid. The use of this Code Case vill be limited to the piping.or tubing { supported on the Diesel Generator engine or skid as supplied by q DeLaval under SP-562. .Since no other system other than this DG ' system piping or tubing is affected by use of'this Code Case, an . increase of the'above occurrences or consequences is'not expected to occur because the DG by itself cannot initiate a design basis a accident. II. No. The_pos'sibility for an accident or a malfunction of a different type than any previously evaluated in.the USAR is not created by this Change Request to allow use of Code Case N411. Since this Code Case vill be solely utilized to reconcile existing pipfng stress / load analyses on the diesel generators that have resulted in i recommendations as delineated in the DR/0R Report for existing on-engine /on-skid piping and tubing, the possibility of a different type of accident or malfunction is non-existent. III. No. The margin of safety as defined in the basis for the standby diesel generators is not reduced by utilization of this Code Case because the level of engine reliability will be maintained. The use of this Code Case, along with its limiting conditions for stress reconciliation purposes on the standby diesel generators and associated engine / skid piping, will result in essentially equivalent levels of engine reliability to analyses performed per ! the ASME Code without benefit of the Code Case, y _ _ _ _- - -_-__D
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gg Attachment 3 , PY-CEI/NRR-0979 L- 'l Page 274 of 278 SE No.: 88-396 J 1 5ource Document: USAR CR 88-260 Description of Change
' Evaluation of a USAR change request-to Table 1.8-1 to update to the latest approved revision of Regulatory Guide (RG) 1.84; " Design and Fabrication Code ~ Case Acceptability-ASME Section III, Division 1" and i Regulatory Guide 1.85; "Haterials Code Case Acceptability-ASME Section III. Division 1". ;
Summary I. No. ASME Boiler and Pressure Vessel Code Cases are approved by the appropriate ASME B&PV Section Committees and therefore are inherently consistent with safety margins within the code provisions. NRC Regulatory Guides 1.84 and 1.85 list those Code ; Cases which the NRC finds generically acceptable along with ! conditions which must be fulfilled for selected Code Cases. ( Thus, use of the listed Code. Cases in conformance with the ' provisions of these Regulatory Guides cannot result in an ;
"Unreviewed Safety Question". '
This.USAR change request only changes-the latest revision of these l Regulatory Guides which may be applied. Previous commitments as to
" degree of conformance" to these Regulatory Guides are unchanged in '
. intent. Changes in this area are only editorial for purposes of clarification. Code Case applications vill continue to be performed in a manner that is consistent with the provisions of ;
Regulatory Guides 1.84 and 1.85. Therefore, no "Unreviewed Safety Question" exists. II. No. See Item I sbove. I l III. No. See Item I above. L. i o
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,.. Attachment 3.
PY-CEI/NRR-0979 L;
- r. ;
Page 275 of-278?
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t SE No.il ;88-397- , , L, l Source Documents. -DCP 85-0295X,-Rev. O ~
- -c i Description of Ch'ange Installation of Instrument'AirL(P51) system tubing and associated devices to support the installation of the charcoal Filter Unit:in'the
-Intermediate Building Ventilation (M33) system for.the Contaminated Tool i p -Storage / Decontamination Room..
m' : Summary : r I. No. No, this change is linityf to the installation of mechanical devices in support of th? Installation of a charcoal filter unit. , This change.does not: adversely affect the. fire hazards analysis or-the SSCR (see Fire Protection Design Evaluation for further details).- Therefore, this change will not: 1
- a. i Increase the. probability of occurrence or the consequences of a malfunction of equipment important to safety as evaluated in-the USAR.
-b. Increase-the-probability of occurrence or'the consequences of .
an accident as evaluated in the USAR.'
- II. No.- ,The probability and c: consequences of a fire is not changed by this DCP; therefore-, this change.will not create the possibility of an accident or malfunction of a different-type than described in the USAR.
, III. No. This-change does not affect the aspects of the Fire Protection Program included in the Technical Specifications in any way.
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Attachmsnt 3 PY-CEI/NRR-0979 L Page 276-of 278 ye SE No.: 88-398 Source Document:1 -DCP 86-06090,.Rev. O m Description of Change Provide additional instrumentation in the Control Room to indicate
' parallel Instrument Air (1P52,2PS2) system header. pressure and provide alarm on low pressure.
Summary I. No. This design modification adds indication and alarm to the parallel instrument air header. The indicator for instrument air header pressure is being. replaced with a dual scale in order to indicate both air pressure systems. An alarm is being added to indicate low instrument air header pressure for the parallel system. 'I The addition of the indication and alarm do not compromise the
;/ stem integrity nor the system function since the same alarm 1
-I function is being annunciated by the low pressure. The. logic of the P52 system is unaffected and the function of the Instrument Air system is unaffected as previously established in the USAR. .The ;
probability of occurrence and/or consequences of an accident or ; malfunction of equipment previously evaluated in the USAR is not- i increased. II. No. .The control system circuit function did not change nor was the previously analyzed safety evaluation affected. The same design basis was used. This change, therefore, does not create the possibility for an accident or malfunction other than those i previously analyzed in the USAR. ' III. No. The instrumentation for the instrument air header pressure in not included'in the Technical Specifications. This DCP enhances the system operation by providing a parallel alarm and indication for Instrument Air Header pressure. ( ) a
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Attachm:nt 3 FY-CEI/NRR-0979 L Page 277 of 278 SE No.: 88-399 Source Document: DCP 87-0508, Rev. 2 Description of Change Install cable, reel and hardware to provide a 480 volt receptacle on the bottom block of the Fuel Handling Area (125 ton) Crane (0L51-E0003) to supply power to the Fuel Inspection Hoist. This also provides an evaluation to a USAR change request to Sections 9.1.1.2 and 9.1.4.1 to indicate that for new fuel handling operations a Fuel Inspection Holst is added to the 125 ton crane, I. No. i USAR Section 15.7.4 (Fuel Handling Accident Outside Containment) specifies that a fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism resulting in the dropping of a raised fuel assembly onto stored fuel bundles. The frequency is categorized as a limiting fault. As identified by this section of the USAR, the most severe fuel handling accident from a radiological release viewpoint is the drop of a channeled spent fuel bundle onto unchanneled spent fuel in the spent fuel racks in the fuel handling building. The accident analyzed in the USAR bounds any event involving the temporary hoist mounted to the 125 ton hoist because the temporary hoist:
- 1. Is only to be used for new fuel handling and
- 2. Is physically lb,ited to the travel of the fuel handling area crane rails, vl.ich do not extend over any portion of the spent fuel pool (USAR Section 9.1.4.2.2.2).
II. No. Since there is no significant radioactive material present in unirradiated fuel, the handling of new fuel with a temporary hoist mounted to the 125 ton hoist creates no accidents or malfunctions not evaluated in the USAR. As stated in USAR Section 9.1.4.3, there are no nuclear safety problems associated with the handling I of new fuel bundles, singly or in pairs. :) i III. No. The Technical Specification bases do not define any margin of safety applicable to this item. i l
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' Attachment 3 PY-CEI/NRR-0979!L Page 278 of 378 SE No.: 88-400 Source Document: DCP 88-0146, Rev. 0' Description of Change ..
1 1 4
- . Replace 2 inch.Yoloy potable water line to'the. Transmission' Yard Control- I House vith aL2 inch copper line.. Revise USAR Figure 9.2-16 to shov this line..
. Summary I. No. Modification of the yard potable water piping does not affect equipment-importantLto safety as described in the USAR.
II. No. The water line can not adversely: affect the safety:of the plant. as described in the USAR.' III. No.- The. vater line does not affect the basis for any Technical' !
. Specification.
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Attachment 1 PY-CEI/fiRR-0979 L Summary of 1988 Perry Safety Evaluations by Category The safety evaluations are divided into the major categories listed below. Percentage Category Number of Total
- 1. Design Changes (except setpoint changes) 99 26
- 2. Drawing Changes 34 9
- 3. Setpoint Changes 4 1
- 4. FSAR/USAR Changas 179 47
- 5. Procedure / Instruction Changes (revisions, temporary' changes) 10 2.5
- 6. Lifted Lead & Jumper, Electrical Devices and Mechanical Foreign Item Changes 18 5
- 7. Nonconformance Report Evaluations 20 5
- 8. Special or Temporary Test Instruction Evaluations 16 4
- 9. Miscellaneous _2 0.5 Total 382
Attachment 2 PY-CEI/NRR-0979 L FORMAT DESCRIPTION Each 50.59 Safety Evaluation summary is presented in the following format: SE N..: A sequentially assigned number from one (001) to end of the period, preceded by the year; e.g. 86-025. , Source Document: There are several sources of evaluations which are abbreviated as shown. DCN - Drawing Change Notice DCP - Design Change Package EPI - Emergency Plan Instruction FSAR CR - Final Safety Analysis Report Change Request LL&JED - Lifted Lead and Jumper and Electrical Device MFI - Mechanical Foreign Item NR-MMOX - Nonconformance Report; Maintenance & Modification Quality Section NR-NEDX - Nonconformance Report; Nuclear Engineering Department NR-00SX - Nonconformance Report; Operational Quality Section NR-PPDX - Nonconformance Report; Perry Plant Department (s) where X - S or N, safety or nonsafety reln'ed PAP - Plant Administrative Procedure PEI - Plant Emergency Instruction PTI - Periodic Test Instruction SCR - Setpoint Change Request SOI - System Operating Instruction SVI - Surveillance Test Instruction SXI - Special Test Instruction TXI - Temporary Test Instruction USAR CR - Updated Safety Analysis Report Change Request WO - Vork Order Description of Change: A short narrative' describing the location ar.d type of plant change. For multiple evaluations the discipline is identified in parenthesis for example, (Mechanical Evaluation). Summary I. Response to 10 CFR 50.59(a)(2)(i) - is the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report increased? II. Response to 10 CFR 50.59(a)(2)(ii) - is the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report created? III. Response to 10 CFR 50.59(a)(2)(iii) - is the margin of safety as defined in the basis for any Technical Specification reduced? NJC/ CODED /1863
t THE CLEVELAND ELECTRIC IL P.O. BOX 97 5 PERRY, OHIO 44081 5 TELEPHONE (216) 259 3737 FROM CLEVELANO: 241 1650 W ADDRESS 10 CENTER ROAD Serving The Best location in the Nation Al Kaplan PERRY NUCLEAR POWER PLANT
$7,$p March 15,'1989 PY-CEI/NRR-0979 L
- U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Annual Report of 10 CFR 50.59 Safety Evaluations for 1988 Centlemen:
Attached is our summary report of 10 CFR 50.59 safety evaluations for the interim period of January 1 through September 18, 1988. An interim report is being submitted to provide consistency with the annual USAR update schedule. Full year summaries will be submitted on March 18, 1990 and annually t.hereaf ter. An applicability check using the 10 CFR 50.59(a)(1) threshold criteria was performed on proposed changes to the design of the plant, to procedures / instructions, and to tests. All those meeting the threshold criteria were further evaluated pursuant to the 10 CFR 50.59(a)(2) criteria 1 and are summarized herein. l This report summarizes a total of 382 safety evaluations, none of which resulted in the identification of an unreviewed safety question. Safety evaluations not included in this summary, have either been voided, withdrawn or are still under consideration though not approved at this time. Attachment 1 lists the safety evaluations divided into their major categories by type of item being evaluated. Attachment 2 defines the acronyms and fermat 94 description. Attachment 3 provides the summaries of the safety evaluations described above. Please feel ftee to call if you have any questions or comments. Ver tru y ou s, Al Kaplan Vice President Nuclear Group AK:njc / d h Attachments f; cet T. Colburn Sr. Resident Inspector f USNRC, Region III
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