RBG-33449, Annual Rept Per 10CFR50.59(b)(2) 890301-900301
| ML20059E396 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/01/1990 |
| From: | Plunkett T GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RBG-33449, NUDOCS 9009100169 | |
| Download: ML20059E396 (58) | |
Text
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GULF STATES UTILITIES COMPANY funn SEND 67ATiDN P061 Of fitt B0s 220 $1 f AAN0tisWLLE, LOVi$nANA 70776 Ant A CODt 6De 636 6394 346 8661 August 28, 1990 .
IBG- 33449 f File Nos. G9.5, G9.25.1.5 U.S. Nuclear Regulatory Ccanmission Document Control. Desk Washington, D.C. 20555 Genticment River Bend Station - Unit 1 Docket No. 50-458
. Enclosed is Gulf States Utilities' Annual Report pursuant to \
s 10CFR50.59 (b) (2) . Rio report describes facility changes,
, procodure changes, tests and experiments from March 1,1989, to March 1, 1990. These changes are included in Revision 3 to the River Dend Station Updated Safety Analysis Report which was sutunitted to the NRC pursuant to 10CFR50.71(c) on August 28, 1990 0
(RBG- 33450 ) .
W ne changes are organized generally by ascending ICN/Section
' A number. If you have any questions concerning this report or rcquire additicnal information, please contact Mr. L. L. Dietrich
' at (504) 381-4866.
Sincerely,
. T. F. Plunkett General Manager l Business Systems & Oversight t
River Bend Nuclear Group
/
/RTS/hul/mrg bu cc: U.S. Nuclear Regulatory Cm mission ho 611 Ryan Plaza Drive, Suite 1000 SP Arlington, TX 76011 8
d NRCResidentInspectoM wa P.O. Box 1051
$8 St. Francisville, IA 70775 80"-
. Claudia Abbate ~
h oo ,
U.S. Nuclear Regulatory Cmmission 11555 Rockville Pike
- Rockville, MD 20852 ,[hf7 q,
c .
GULF STATES UTILITIES ANNUAL REPORT PURSUANT TO i
MARCH 1, 1989 THROUGH MARCH 1, 1990 P
l l
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h Chance Nn=her/USAR sections LCN 3.2-7 / Table 3.2-1 (pg 1 of 34)
/ Table 3.2-1 (pg 34 of 34) '
/ Figure 5.1-3a Description and Basis for Chance This modification replaced condensate chamber B21*TKD004A with - a larger condensato chamber to improve the reliability and securacy of +
chamber level indications. ,
gn===ry of Safety Evaluationt This modification increases - the reliability of the level ;
instrumentation for the condensate chamber. It has no adverse impact on the types or consequences of accidents or malfunctions.
Therefore, it was concluded that this change does not represent an unreviewed safety question. ,
Chance Nn=her/USAR Sectig.n LCN 3.7A-5 / Table +3.9A-3 (pg 4 of 4)
/ Table 3.6A-20
/ Table 3.6A-4a
/ Table 3.6A-17a
/Page 3.7A-15
/Page 3.7A-29
/Page 3.7A-37
/Page 3.7A-18 Description and Basis for chanas This change revised the response spectrum peak broadening to +/- 15%
in conformance with Regulatory Guide 1.122 and incorporates Revision 1 to Code Case N-411. This response spectrum is utilized in a method for testing seismic category I piping systems within the plant. This
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change also included additional explanatory notes and revised i affected tables to incorporate snubber reduction per this regulatory ')
guidance.
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Eggaarv of Safety Evaluations-l The ability of the affected systems to continue to withstand design basis conditions - and remain within the ASME III limits has been demonstrated by analysis. The analysis considers all hypothetical and actual loading conditions previously analyzed. Therefore the 1 probability of an accident previously evaluated in the SAR is not increased. No new line breaks were postulated as a result of this change and all postulated accidents previously evaluated were considered in the new analysis. The technical specifications ~do not
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specify total number of snubbers and the margin of safety of any technical specification is not reduced. The consequences of any 1
l malfunction of a safety-related structure or component has been considered. The methodologies utilized are consistent with the SAR, regulatory positions and good industry practice. Therefore it has been determined that this change does not constitute and unreviewed safety question. i Change Ma=her/USAR 8ection LCN 3.7A-6 /Page 3.7A-42 Descrintion and Basis for Chanaat This change revised the USAR to clarify the control room notification provided by the seismic instrumentation system and the general response taken by the operator in determining the impact of a seismic event. The instrumentation provided for determination and the subsequent evaluation of a seismic event complies with the requirements of Regulatory Guide 1.12.
Su==ary of Safety Evaluation This revision to the alarm response procedure for a seismic event provides clarification as to the operator's response to a seismic instrumentation annunciator activation. The revision also clarifies l
the operation of the instrumentation that provides visual and audible alarms to the control room. The existing instrumentation is not effected by this change, therefore the probability of occurrence or the consequences of an accident is not increased by this change.
There is no change in the possibility of a new accident because the added information changes no equipment or system function. Since this is only a clarification of operator actior.s-in response to a postulated seismic event, the margin of safsty as defined in the basis for any technical specification is not reduced. Therefore this change has been determined to not create an unreviewed safety question.
Chance Mn=her/USM 8ection LCN 3.8-6 /Page 3.8-31
/Page 3.8-38 Description and Basis for Chance This change was made to reflect the use of ASTM A194 GR 7 nuts in the place of ASTM A194-2H nuts. The USAR material specification was modified to reflect this interchangeability, an==ery of Safety Evaluations As these nuts have been evaluated to be physically and functionally interchangeable, any previously evaluated accident frequency or probability is not increased. Since these components are functionally interchangeable per evaluation no consequences of any 2
/ 1 1
l acuident are increased by this change. No new accidents are postulated as there is no change in the design basis of the plant.
Nor is there any increase in the probability of failure of safety-related equipment. The margin of safety of any technical specification is not reduced because the design basis remains I unchanged. Therefore this change has been determined to not create l
an unreviewed safety question. ,
Chance Number /USAR Rectiont LCN 3.9B-15 /page 3.9B-4
/ Table 3.9B-1 (pg 1 of 2)
/ Table 3.9B-1 (pg 2 of 2)
Description and Basis for Changet This modification was performed to support a technical specification ,
change (Amendment 31) to permit single loop operation (SLO) mode of the reactor recirculation system. A plant specific SLO analysis was performed and indicated that several design changes were necessary.
These changes included revisions to the safety limit minimum critical power ratio,-MAPLHGR limits, average power range monitor (APRM) flow biased SCRAM setpoint and rodblock setpoints. This change revised the USAR to reflect these revisions.
sn==Srv of Safety Evaluationt This modification does not introduce any new equipment, structure or component, therefore the probability or consequences of a previously evaluated accident is not increased. Since tripping of one recirculation pump has been considered in USAR Section 15.3, the probability of an accident different from any previously analyzed is not increased. This modification imposed new surveillance requirements to avoid thermal overstressing of the control rod drives and in-core housings. This surveillance is performed during conservative plant conditions such that the probability During of a malfunction of safety-related components is not increased.
SLO the performance characteristics used to demonstrate jet pump operability are different than those used for two loop operation. A new set of data has been incorporated into the startup test procedures for SLO to eliminate the possibility of a malfunction of
- safety-related components dif ferent than those previously evaluated.
The margin of safety as defined in the basis for any technical specification is not reduced by this change because in the SLO analysis all parameters r.ecessary for SLO have been considered and
~ necessary changes have been made to the appropriate documents.
! Therefore this change does not constitute an unreviewed safety question.
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r Ch nee Ma=her/USAR sociigat LCN 3A.0-2 /Page 3A.27-1
/Page 3A.27-2
/Page 3A.27-3
/Page 3A.28-1 Descrintion and Basis for Chanaat During the design and construction phases at River Bend Station additional computer programs were either selected or generated for static and dynamic analysis of Category 1 systems and structures.
This change to the SAR delineates the use of these programs for reference. The addition of this information is made for completeness of documentation.
sa---ev of safety Evaluation:
There is no increase in the probability of an accident as the incorporation of computer programs used does not-change the design basis of the plant. Nor is the consequences of an accident increased because this change is a documentation of programs for which the design methodology has been previously approved. There are no new accidents created by this change as no new design cri+ aria has been introduced. The margin of safety as defined in the basis for any technical specification has not been reduced. Therefore this change does not create an unreviewed safety question.
Chance Numher/UBAR section LCN 4.6-14a / Figure 4.6-Sc Description and Basis for Chance This modification removed plugs from control rod drive (CRD) vent / drain valves (1C11*V101 and 1C11*V102) and replaced them with
" quick connect" hose fittings. These fittings are intended to facilitate venting and reduce contamination from water spillage.
an===ry of safety Evaluation This modification did not compromise the performance of the vent / drain valves nor did it delete a component necessary for it te perform its safety function. In addition, the margin of safety as described in the technical specifications is not reduced. Therefore, this has no adverse effect on safety and does not constitute an unreviewed safety question.
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r Chanae wa=her/U8ha Sec Qggt LCN 4.6-15 / Figure 4.6-5c Description and Basis for change This was a USAR nomenclature revision to mark-numbers which represent two control rod drive safety-related solenoid valves (IC11*SOVT110A more accurately reflect Category and 110B). This modification wil.
I solenoid valves as safety-related. equipment.
8"===rv of Safety Evaluations l'he revision of the USAR figure will correctly reflect the safety-t; related VMv9 This modification ~ does not change the physical configuracion of any equipmen. to increase the probability or consequen~m* of-any previously evaluated accident in the SAR. In addition, i.: margin of safety-is reduced by making-the nomenclature revision. Therefore, it has been concluded that this modification-does not constitute an unreviewed safety question.-
Chance N"=her/U8AR Sectient LCN 4.6-17a / Figure-4.6-Sa Descriotion and Basis for Chance This modification relocated the relief valve connection (C11-RVF025A) to the' reactor recirculation pump-seal purge supply line so that it is upstream instead of downstream of the seal flow purge indicator (C11-FIR 020A). Also, the relief valve discharge _ piping was shortened so that any leakage or flow through the relief valve is readily visible to the operator. These changes are intended to prevent pump operation for prolonged periods without seal purge flow.
Sumagry of Saigiv Evaluationt ;
The relocation of the relief valve connection does not increase the probability.or consequences previously evaluated.. In addition, the modified discharge piping meets Seismic Category I ASME requirements and the probability of a malfunction of a safety-related system or component is not affected. Furthermore, the reactor recirculation pump seal purge is not addressed in the-technical specifications and does not adversely af fect any margin of safety. Therefore, this j modification does not constitute an unreviewed 7,afety question.
Chance Nn=her/USAR Section LCN 5.1-8 / Figure 5.1-3a Descrintion and Basis for Chancet )
This' change adds a panel identification number. to a USAR figure which represents level transmitter B21*LTN044E. This modification was implemented to more accurately reflect current plant conditions.
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Sa--=ry of Safety Evaluation: {
I Addition of the panel location of the subject transmitter to th nuclear boiler instrumentation drawing will not have any effect on any safety-related components or systems. The probability of a malfunction of a safety-related structure, system or component is not '
increased. This addition has no effect on the- technical specifications for accident monitoring instruments. Therefore, it i has been concluded that - this change does not -create an unreviewed safety question.
Chance M"=her/USAR section: LCN 5.1-9 / Figure 5.1-3a ,
DescriDtion and Basis for Chancet- l This change revised the nuclear boiler instrumentation piping and instrumentation diagram to reflect the panel location of pressure. ;
transmitter .C33*PTN008B.
This change was made to more accurately reflect the nuclear boiler instrumentation system by the-addition.of the detail.
Sn==ary of 8_afety Evaluati.g.n t ;
The revision of the system drawing _ has no effect on the- system configuration and no plant modification was performed. No accident previously evaluated is increased, nor vere the consequences of any accident increased by this change. Furthermore, this change only ,
serves to include additional details regarding location of the.above transmitter. Therefore, this modification does not constitute an unreviewed safety question.
Chance Nn=her/USAR Section: LCN 5.4-50 / Figure 5.4-12a
/ Figure 5.4-12b DescriDtion and Bas.is for Chance:
This modification installed of a 3/4 inch pipe between the residual heat removal (RHR) system valves *V3011 and *V3012 and also between .
valves *V3013 and *V3014. These valves are now maintained in~the '
locked opened position. This modification provides a flow path from the bottom drain pipe of safety-related motor operated valves E12*MOVF004A and B to the suppression pool via the existing relief valve discharge header thus preventing the hydraulic binding of these valves due to bonnet overpressurization. This change will ensure that the residual heat removal system is available for low pressure core injection (LPCI) mode.
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Summary o" Safety Evaluation This modification ensures the opening of valves E12*MOVF004A & B as required for LPCI mode of the RHR system. This modification has been thoroughly evaluated and does not affect containment isolation and containment leak rate testing requira'neni.s. This change does not increase the probability or consequences of any accidents previously evaluated. In addition, the margin of cafety as described in the specifications is not affected. Therefore, this technical modification does not constitute an unreviewed safety question.
Chance M"=her/USAR section _LCN 5.4-54 / Figure 5.4-12a
/ Figure 5.4-12b-Descrintion and Basis for Chances This modification bored out to full pipo diameter the restriction orifices (RHS*R04A and RHS*R04B) in the test return loops A and B of the residual heat removal (RHR) system to eliminate cavitation-in that location. In addition, two new restriction orifices (RHS*R0208A and RHS*R0208B) were added to the test return loop inside the containment. These new orifices are sized to provide the same additional system resistance as was previously provided across restriction orifices (RHS*R04 A -and _ B) , thereby preventing pump run out while still maintaining the required system minimum flow rate during full. flow test-and suppression pool cooling modes of-the RHR system operation, sn= mary of safety Evaluation The RHR A and B loops are designed for the following modes:-shutdown cooling, low pressure coolant injection, and suppression pool cooling. In addition, these loops have the capability for full flow testing during normal . operation to verify pump capacity by discharging to the suppression pool via a test return line (same line utilized for suppression pool cooling mode). Each rode has been evaluated with the conclusion that this change does not increase the probability or consequences of any accident previously evaluated.
The modification meets all of the previous design and functional requirements and does not affect the performance capability of the RHR and low pressure core spray (LPCS) systew Furthermore, the margin of safety as defined in the bauls of the technical specifications has not been reduced. Therefore, -it has been concluded that this modification does not constitute an unreviewed safety question.
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Chance Nn=her/USAR Sections LCN 5.4-55 / Figure 5.4-15b D ngrintion and Basis for Chance:
This modification revised the mark number of two filter demineralizer strainers (1G36*STRTD009A and 1G36*STRTD009B) utilized in the reactor water cleanup system (RWCU) to correctly reflect the removal of internal start-up elements. These elements were only needed during plant start-up.
Summary of Safety Evaluation This modification does not effect the probability or consequence of an accident or malfunction. The only possible impact of removing the strainer element is a slight increase in the probability of RWCU filter demineralizer resin migrating upstream into the RPV. However, this is a negligible probability and does not contribute to any postulated accidents. This modification does not affect the performance of the RWCU or hinder the performance of any other plant systems. In addition, the margin of safety as defined in the basis to the technical specifications has not been reduced. Therefore, it has been concluded that this change does not constitute an unreviewed safety question.
g]}]u}ae Number /USAR Sectiont LCN 5.4-57 / Figure 3.6A-19
/ Figure 5.4-8 Descrinti_qn and Basis for Chanas This change installed a 2.5 inch test connection in the reactor core isolation cooling (RCIC) steam supply line upstream of safety-related motor operated valve 1E51*MOVF045. The modification will allow RCIC system testing to be performed.
Summary of Safety Evalutt.lqnt RCIC system operatior is not adversely impacted by the addition of a test connection. Also the addition of the test connection has no effect on the high energy line break locations in the RCIC steam supply line. ASME class piping was used in installing the test connection so the possibility of an accident which is different than any previously evaluated is not created. Installation of a test connection does not impact the margin of safety to any technical specification. There is no unreviewed safety question created by this change.
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l Change Number /USAR Section LCN 5.4-62 / Figure 5.4-12b Description and Basis for Chance:
This modification revised a- piping and instrumentation drawing to include a conductivity element (E12*CEN001A) in the residual heat removs1 system (RHR) loop A to reflect current plant conditions.-
i This change was made due to a drawing ~ incorporation error ' and provides consistency with loop B of the RHR system.
Summary of Safety Evaluation:
This modification only revised a drawing to reflect current plant '
l conditions. - This change has no adverse impact on the types or consequences of accidents or malfunctions since no changes were made-to the current plant configuration. In addition, the margin of safety as defined in the basis of the--technical specifications has not:been reduced. Therefore, it was concluded that this change does - not' represent an unreviewed safety question.
Change Numher/USAR Section LCN 5.4-65 / Figure-5.4-8 Descrintion and Basis for Change This modification was a nomeaclature revision of a USAR figure mark-number which represents a safety-related valve in the reactor core -
isolation cooling (RCIC) system. The figure now' accurately reflects-the Category I safety-related valve.
Sn===ry of Safety Evaluation:
This modification made no . changes to - the physical system configuration and has no effect on .the system design basis, i performance, or reliability. In addition, the margin of safety as defined in the basis to the technical-specifications is not reduced.
- Therefore, it ' has been concluded that this modification does not constitute an unreviewed safety question.
Chance Number /USAR Section: LCN 5.4-66 / Figure-5.4-15b-DescriDtion and Basis for Chance This-drawing modification deleted a millipore filter holder (1G36- '
LT010) from a reactor water cleanup (RWCU) system figure. This revision was implemented to more accurately reflect current plant conditions, f 9
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Sa===ry of Safety Evaluation:
This modification is a drawing revision only and does not increase the probability or consequences of any accidents. In addition, since the filter holder was outside the reactor-coolant boundary, this drawing revision does not' impact any safety-related function of any ;
plant systems including the isolation capability of RWCU. Therefore,- l j' has- been cencluded that this change does not constitute an I L eviewed safety question. j Chanum ,_ ~%er/USAR Sections LCN 5.4-68 / Figure _5.4-15b Description and. Basis for Chances This figure modification' reversed the indicated flow direction :l between the. main steam positive leakage control system (MS-PLCS) and i two reactor water cleanup system (RWCU) motor operated valves (MOVs)
(WCS*MOV172 and WCS*MOV173) to-reflect the actual flow path, sum =ary of Safety Evaluation This drawing revision has no adverse 'aafety implications on physical system configuratione. This modification does not incriase- the-probability or consequences of previously evaluated accidents. nor ,
does it impact the performance _ or reliability of the RWCU MOVs or MS- !
PLCS system. In addition the margin of safety as defined in'the basis ,
to the technical specifications of these = systems - hau not been reduced. Therefore, it has been concluded that this-change does not constitute an unreviewed safety question.
Chance Nu=her/USAR Section LCN 6.2-34 / Figure 6.3-1
/ Table 6.2-35 (pg-1 of 3)
/ Table 6.2-40 (pg 18 of 18) ;
/Page 6.3-14 Descrintion and Basis for Chanaat This change removes the lever arm to disconnect the remote manual - ;
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operability test capacity of the high pressure core spray (HPCS) check valve 1E22*AOVF005. This modification will not remove any functional capacity of this safety-related check valve as originally designed.
Su==ary of Safety Evaluation:
Since this check' valve will retain all of its functional capability as originally designed except for the remote testing of the valve, there is no increase in the probability of an accident previously 10
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evaluated in the SAR. The check valve will function as originally l required, therefore the consequences of an accident will not be increased. The air actuator for the check valve is left in place,.
only the lovar has been removed. The integrity of the actuator is l not Effected by this change. No possibility of a different accident than~LOM6 previously evaluated is created. The check valve is tested for operability in the same manner and the local leak rate requirements remain in effect, therefore the possibility for a malfunction of a safety-related structure or component is not created or increased. The margin of safety as defined in the basis for the technical specifications is not increased. There is no unreviewed safety question created by this change.
l Chance Nn=her/USAR Section LCN 6.2-35 / Figure 5.4-12c
/ Tables 6.2-35 (pg 2, of 3)
/ Table 6.2-40 (pg la of 18)
Description and Basis for Change This change removes the lever arm to disconnect the remote manual operability test capacity of the low pressure core spray (LPCS) check-valve (1E12*AOVF041C). This modification will not remove any functional capacity of this safety-related check valve as original' designed.
Su==ary of Safety Evaluation Since this check valve will retain all.of its functional capability as originally designed except for the remote testing of the valve, there is no increase in the probability of an accident previously evaluated in the SAR. The check valve will function as originally l required, therefore the consequences of an accident will not be increased. The air actuator for the check valve is left in place, only the lever has been removed. The integrity of the actuator.is not affected by this change. No possibility of a different accident than those previously evaluated is created. The' check valve is tested for operability in the same manner and the local leak rate requirements remain in effect, therefore the possibility for a malfunction of a safety-related structure or component is not created or increased. The margin of safety as defined in the basis for the technical specification is not increased. There is no unreviewed-safety question created by this change.
Chance Number /USAR Sectiont LCN 6.2-36 / Figure 5.4-8
/ Table 6.2-40 (pg 18 of 18)
/ Table 6.2-35 (pg 3 of 3) 11 P
Description and Basis for Chances This change removed the lever arm to disconnect-the remote manual ,
operability test capacity of the reactor c o r e - i s o l a t i o n -- c o o l i n g -j (RCIC) check valve 1E51*AOVF066. This modification did not remove ;
any functional capacity of this safety-related check valve as {
originally designed. The removal of the lever arm was= initiated to- ,
allow more_ accurate check valve local leakirate testing.
Summary of Safety Evaluations ,
Since this check valve retains all of its functionalicapability as l originally designed except' for the remote testing of the-valve, .there is no increase in the probability of an accident previously evaluated-in the SAR.- The check valve functions as, originally required,_
therefore;the consequences of an accident have not increased. The, 3 air. actuator for the check valve was left in place, only the lever i was removed. The integrity of the actuator was not affected'by this .;
change. No possibility of a different accident than those previously l evaluated is created. The check valve is tested for. operability.in- i the same manner and - the ' local leak rate requirements remain, in I
effect, therefore'the possibility for a malfunction of a safety-related structure or component =is not created or increased. The margin of safety as defined in the basis for the technical' I specification is not increased. There - is no unreviewed : - saf ety question created by this change.
Chance Mn=her/USAR Section LCN 6.3-19 / Figure 6.3-1 !
Description and Basis for Chances
-I This drawing revision deleted an instrument rack panel identification ;
mark-number H22*PNLP024 from three high pressure core spray (HPCS) system transmitters (E22*PTN051, E22*PTN052, and E22*PIR001) . These -
i transmitters are located on' local instrument _ racks, i
-8"==ary of Safety Evaluation: i This modification is intended to increase t'he ' reliability - of the instruments for all modes of HPCS operation. These changes had no adverse impact on the types or consequences of accidents: or malfunctions. In addition, the instrument rack on which the HPCS ,
suction and discharge pressure transmitters are located _does not reduce the margin of safety as defined in the basis of the technical specifications. Therefore it has been concluded that this change does not represent an unreviewed safety question.
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i Chance Nn=her/UshR Sectient_LCN 6.3-20 / Figure 6.3-1 Descriotion and Basis for Chanaat This drawing modification revised the mark-numbers of two safety--
related 3 inch flush line valves to reflect the actual system identification prefix (E22*VF003 and E22*VF004). These valves are utilized in the high pressure core spray system (HPCS). >
Su==ary of Safety Evaluations j This revision correctly reflects the safety-related flush line valves and does not change the physical configuration of- the plant. In i addition, the modification does not increase the probability or- 1 consequences of an accident previously evaluated. Furthermore, the j margin of -safety as defined in the basis of the technical l specifications- has not been reduced. Therefore, it has been j concluded that this modification-does not constitute an unreviewed !
safety question. l i
Chance Nn=her/USAR Baction: LCN 6.3-21 / Figure 6.3-1 l Descrintion and Basis for Chance:
3 This figure revision added an instrument mark number (*LY3G(J-))
which identifies a safety-related high pressure flow controller. The !
existing flow controller is currently utilized in the:high-pressure ;
core spray system (HPCS). The change was made to be consistent with other associated' design drawings and current plant conditions.
Sn==ary of Safety Evaluation This modification corrected only a minor error in a USAR figure 1and does not change the physical configuration of any safety-related systems, components, or structures. In addition, the change does not increase the probability or consequence of any previously evaluated accident. Furthermore, the margin of safety-as defined in the basis for technical specifications is not reduced. Therefore, it has been concluded that this change does not represent an!unreviewed safety question.
Chance Nn=her/USAR Section LCN 6.4-3 /Page 6.4-3
/Page 6.4-11 DescriDtion and Basis for Change:
This change was initiated to clarify the USAR description of the main control room air conditioning paramoters. The ULAR was modified to 13 Y
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e a i
J add that the parameters in which the control room air conditioners I operate are within the 104 F maximum temperature limit for which the main control room equipment is designed to operate.
Summary of Safety Evaluation This clarification to the USAR in no way changes the design bases or the operation of the plant. This change is being made only to add detail to the descriptions previously provided in the SAR. .The
! probability of an accident previously evaluated is not increased nor are the consequences of any previously evaluated accident increased by this text change. The technical specification for the main control equipment is not affected by this change. Therefore, this change does not constitute an unreviewed safety question. ,
Chance Nn=her/USAR Section: LCN 6.4-4 /Page 6.4-11 Descriction and Basis for Chance This change deletes requirements for the availability of full face positive pressure air purifying respirators in the main control room.
These respirators were previously provided in the control room emergency equipment locker. There is no regulatory basis for this type of respirator as they were provided as additional equipment only. NUREG-0654 does address respiratory protection in general for the main control room as a backup to facility design. Negative pressure air purifying respirators provide this means of respiratory protection.
Su==ary of Safety Evaluati @
These powered air purifying respirators provide for filtration of radioactive particulates, however they provide . operators no protection against airborne halogens and noble gases. The design of the main control room ventilation system provides for automatic isolation of the normal' intake pathway and for automatic realignment to provide intake from a separate, filtered remote intake. Therefore the probability or consequences of an accident is not increased by this change. No basis for any technical specification is reduced as the technical specifications do not specify the type of respirator available for control room use. The currently available respirators in the main control room provide adequate protection for operators in the event of an accident. Therefore this change has been determined to not create an unreviewed safety question.
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i Chance Nn=her/USAR Section: LCN 7.2-3 / Figure 7.2-1 (sh 2 of 4)
/ Figure 7.3-2 (sh 4 of 7)
/ Figure 7.3-11 (sh 2 of 26)-
/ Figure 7.3-22 (sh 1 of 10) j
/ Figure 7.3-23 (sh 2 of 44)
/ Figure 7.5-3 (sh 5 of 6) '
/Page 6.4-3
/Page 6.4-11 Descrintion and Basis for Chances This modification provides keylock switches and indicating lights to assist operators in performing actions required by emergency operating procedure (EOP)-1, " Emergency Procedure - RPV Control".
Sn==ary of safety Evaluations j This change provides an easier means for performing actions as described in EOP-1 which are emergency measures to be performed af ter an accident. For example, the - EOP-1 " Enclosure Actuation" -will eliminate the requirement for jumpering- and lifting leads within ,;
control room panels during emergency conditions and thus aid in operation actions. All accidents addressed in this: procedure have been previously evaluated in the SAR and this modification.does not introduce any new components or circuitry which may- increase the probability of such an accident. This modification:will not in any way affect the function of any plant safety system under normal conditions. No new failure modes not postulated in the SAR-are created by this change. This modification does not affect any plant setpoints, safety limits or failure points described in the technical specifications. Therefore this' change does not constitute a unreviewed safety question.
_ Chance Nn=her/USAR Section LCN 7.3-68 / Figure 7.3-5 Descrintion and Basis for Chances This change will install an interlock mechanism to deactivate a reactor water clean up (RWCU)_ blowdown line high/ low pressure alarm (2485) when the upstream isolation valve (G33*MOVF034) is fully closed. Prior to this modification, -the subject alarm was continuously energized due_to leakage across the RWCU blowdown flow control valve (FCV). The alarm is only needed when the blowdown isolation valve is open to protect the condenser and prevent the condenser from pulling vacuum on the RWCU system. Deactivating the '
alarm when the isolation valve is shut eliminates the continuously energized alarm.
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3
)
Sa==ary of Safety Evaluationt The only safety-related function of the RWCU system is to maintain the pressure boundary and to isolate the system under loss of coolant accident (LOCA) conditions. The probability of LOCA occurrence.is not increased as the reliability of ' the pressure boundary / system isolation is not affected. No new accidents were postulated as a i' result of this modification, the probability and ' consequences of malfunctions of safety-related equipment as- a result of this modification are not increased. Margins of safety were not affected as the change did not affect the ability of RWCU to maintain ;
chemistry limits (Technical Specification 3/4.4.4) nor doer it impact ;
system isolation capability (Technical Specification 3/4.3.2). For j these reasons,.it was determined that this modification does not j result in an unreviewed safety question. ;
' Chance N"=her/USAR Sections LCN 7.3-70 ./ Figure 5.1-3b
/ Figure 7.3-2 (sh 5 of 7) 4 Descrintion and Basis for Chances This modification installs a dual alarm unit to the reactor recirculation instrument panel to monitor reactor pressure- vessel shutdown' level and provide the control room operator-with a high and low level alarm. This common high/ low annunciator. will only be activated during modes 4 and 5. This mo 'ification will increase the capability of monitoring the reactor water lavel during -in-vessel activities and allow operators to more accurately prevent radiation over exposure of maintenance personnel.
Sn==ary of Safety Evaluations l
This modification provides for enhanced Leactor Pressure Vessel (RPV) I shutdown level indication only and does not in any way effect the .
operability of any plant safety system, therefore the probability or )
consequences of an accident previously evaluated in the SAR is not increased. This additional shutdown level indication will not introduce any possibility of any new accident scenarios. The RPV shutdown level monitoring instrumentation neither provides- or supports any safety-related control function. However, the implementation of this change will increase operator awareness of potential overexposure of maintenance personnel during refueling.
Therefore, this change has been determined not to involve any unreviewed safety question.
Chance Number /USAR Section LCN 7.3-71 / Figure 7.3-3 (sh 1 of 2)
/ Figure-7.3-4 (sh 1 of 4)-
16 1
Descrintion and Basis for Chances This modification revised the control logic ' for the residual heat removal -(RHR) and low pressure core spray (LPCS) injection valves, 1E12OVF042A,B & C and 1E21*MOVF005 to eliminate the possibility of an : os. rator inadvertently opening a low pressure emergency core cooliny system (ECCS) injection valve when the reactor pressure is high, and causing over-pressurization of leak.
the Inlow addition,-
pressure piping certainif the testable- check valve- should inconsistencies in USAR figures were corrected.
Su==wv of safety Evaluation The modification involved only changes in the manual control logic 'of theflow pressure ECCS injection valves; the automatic initiation andTherefore, the pro operation of the ECCS were not affected.and consequences of an' accident pr increased. By eliminating the possibility of this inadvertent actuation, ' the modification will ' reduces the possibility of an In accident which is different than any previously evaluated.
addition the modification does not -increase the consequences of > a safety-related system but -will reduce the malfunction. of a previously evaluated; possibility of malfunction of this type notThe change does not af fect any bas therefore this modification does not constitute an unreviewed safety question.
/ Figure 7.3-14 (sh 3 of 16)
Chance N"=her/USAR Sections LCN 7.3-73 / Figure 7.3-14 (sh 12 of 16)
Descrintion and Basis for Change This modification included a time delay relay to the in each chilled control water building control building ventilation system (HVK) spurious / nuisance tripping during chiller trip circuit to prevent normal and emergency starts.
Sunnary_of Safety Evaluationt water The . control building ventilation system (HVK) chilled The configuration is ' virtually unaf fected by this modification.
electrical controls are being improved to insure start Asreliability described and eliminate erroneous spurious / nuisance trip signals.
in USAR Section 9.2.10.3, the system operates during normal, shutdown, and accident conditions, as well as in a remote shutdown.
The change does not affect these Since -modes the of operation revised design or constitute adheres to' any single new postulated accidents. would be the failure criteria, the worst case malfunction 17
. e catastrophic f a.4 lure of a chiller. Based on redundant trains and the availability of a second 100% capable chiller in each division control room, habitability and equipment environmental qualifications ;
in the control building will be maintained. The operability of the HVK system as described in Technical Specification 3/4.7.2 is not af fected by the modification, therefore, the margin of safety has not been reduced. It was concluded that this modification does not
- constitute an unreviewed safety question.
Chance Numher/USAR section LCN 7.3-74 / Figure 7.3-4 (sh 4 of 4)
Description and Basis for Chance:
This modification installed an interlock on residual heat removal (RHR) valve 1E12*F004(B) such that it is permitted to open when the upstream valve is fully closed. The . change will minimize the
- probability .of draining the reactor vessel to the suppression pool via the RHR System.
Sn==ary of Safety Evaluationt l This change will eliminate the possibility of opening residual heat removal (RHR) valves 1E12*F004A(B) and 1E12*F006A(B) simultaneously from the control room thereby minimizing the probability of draining the reactor to the suppression pool via-the RHR System. Failure of a limit switch contact added by this modification would at worst cause inability to open valve 1E12*F004A and 1E12*F004B (N it not both) from the control room. However, during plant operati t, the RHR system valves are aligned in the LPCI/ standby position. Under design basis accident (DBA) conditions, these valves would not be required to operate in order for RHR to fulfill its emergency. core cooling system (ECCS) tunctions. In addition, the RHR system is designed to meet single failure criteria and the modifications being made are consistent with this design basis. Therefore, the possibility for an accident or malfunction of a different type than any evaluated previously in the SAR is not created. All automatic and manual actions required for the RHR system to operate are unaffected by this modification. Technical Specifications 3/4.5, 3/4.9.11 and their bases are not affected as per the previous discussion. Therefore, the margin of safety is not affected. This change does not constitute an unreviewed safety question.
Chance Number /USAR Section: LCN 7.3-76 /Page 7.3-36
/ Figure 7.3-21 (sh 16 of 17)
DescriDtion and Basis for Chance:
This change was made to reflect discharge of the fuei building ventilation system to the environment and deletion of the fuel 18
l l
building ventilation filter train actuationThe from fuel building filter the particulate channel of radiation monitor 1RMS*RE5B.
trains provide for removal / decay of radioactive airborne material in the event of a fuel handling accident or LOCA. Radiation monitor
! 1RMS*RE5B provides automatic filter initiation. Deletion of the I automatic function from the particulate channel does not effect the
! ability of the monitor to respond via the gas channel to an accident condition.
8"===rv of Safety Evaluations Radiation monitor 1RMS*RE5B is not postulated to initiate any previously evaluated accident. It provides initiation of the fuel building ventilation filte.r trains which are used to mitigate the consequences of fuel har.C !.rw accidents and a LOCA as part of secondary containment. In wach of these accidents the primary source of airborne radioactiva interJel is failed fuel. The postulated airborne radioactive reiecse is composed of noble gases and iodine, with noble gases as the major constituent. In each of these accident -
scenarios, particulates are not considered as part of the release.
In a fuel handling accident the particulates would remain in the spent fuel pool and the gaseous channel of 1RMS*RE5B would provide '
initiation of the fuel building ventilation filter-train....In a LOCA condition, particulates would be expected to remain in the water phase of the primary coolant, emergency cooling water or the suppression pool. Thus the probability or consequences of a previously evaluated accident r.re not increased by this change. This change does not effect all 02 its required functions as defined in the design basis, so the probability of a new accident is not increased. The margin er safety in maintaining the radiation dose within the values set forth in 10CFR20 and 10CFR100 are unaffected by this change. Therefore it has been determined that this change does not create an unreviewed safety question.
Chance N=her/USAR Section LCN 7.3-77 / Figure 7.3-9 (sh 13 of 25)
Description and Basis for Chance The editorial change re-identified inputs from radiation monitor 1RMS-RE126 to the main plant radiation alarm to show the correct-terminology and units of measure.
Summary of Safety Evaluation This modification makes only editorial changes and has no impact on system operation or function. There will be no changes to the design bases and no effect on the safety or reliability of the plant as previously analyzed. This document change does not affect the margin of safety for any Technical Specification basis, including monitoring 19 l
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- i instrumentation and radioactive effluents per sections 3/4.3.7 and i 3/4.11.1, respectively. This change does not constitute an i unreviewed safety question.
Change Mn=her/USAR 8ections LCN 7.3-78 / Figure 7.3-23 (sh 26 of 44)
Descrintion and Basis for Change:
This change revised a USAR figure of the emergency diesel generator engine and turbocharger vibration switches to show them as nonsafety- i related. Vibration switches for the emergency diesel generator engine and turbocharger are designated as nonsafety-related because the trip functions of these switches are designed to be bypassed in the emergency mode of operation.
An==ary of Safety Evaluations These switches perform no safety-related function because the trip functions are bypassed in the emergency mode. No new failure modes are created by this change and no new accidents are postulated. The requirements for these vibration switches are for protection of the emergency diesel in testing Eand have no effect on any previously evaluated accidents. The emergency modes of diesel generator operation are loss of offsite power and/or loss of coolant accident.
The basis for Technical Specification 3/4.8.3 is not effected by this change. Therefore this change doos not create an unreviewed safety i question.
Chance Nn=her/UShR Sections LCN 7.3-80 / Figure 7.3-18 (sh 2 of 7)
/ Figure 7.3-18 (sh 4 of 7)
- / Figure 7.3-18 (sh 6 of 7)
Descriction and Basis for Chances ,
This change was made to reflect modifications to the plant diesel generator building ventilation system to provide transfer switches in various fan circuits. This modification provided the required isolation capability to meet 10 CFR EO Appendix R isolation requirements and was performed prior to plant start-up. This is a document change only, made to accurately reflect the current plant configuration.
Eggmary of Safety Evaluation:
The addition of transfer switches to the exhaust fan circuits of the diesel generator building ventilation system does not increase the probability of an accident because the design basis of the system remains unchanged. The consequences of an accident previously evaluated in the SAR are not increased because the consequences of a 20
l' . e failure of a diesel generator rcmains unchanged. The failure of a diesel generator _ has been previously considered in the accident analysis, therefore failure of a diesel due to failure of an exhaust fan does not represent a new accident scenario. The design basis of 1 the ventilation system is not altered by this modification, thus the l probability of a malfunction of safety-related equipment is not !
increased. This modification does not effect the margin of safety as defined in the basis of any technical specification, including Technical Specification 3/4.8.1 (AC sources). This change has been determined not to create an unreviewed safety-question. ,
Chance Nn=her/USAR Sections LCN 7.3-81 / Figure 7.3-14 (sh 4 of 16)
DescriDtion and Basis for Changel This change included a 30 second time delay to the service water normal flow start permissive logic for the control building chilled water chillers. It also added a 39 second time delay to the service water low-low flow trip function .for these chillers. This modification will allow the chillers to operate for a short period of time during startup sequences or during system transients with low service water flow present and - allow momentary - flow swings in to occur without preventing a chiller from starting'or continuing to operate.
Sn==ery of Safety Evaluations e Should a "No Service Water" condition occur'in an operating chiller, the refrigerant pressure will rise and the chiller will trip on "High Refrigerant Pressure". This is an instantaneous trip which provides additional protection for the chillers without compromising any of the operational function. The addition of a 30 second time delay will still trip the chillers under degraded flow conditions, therefore this change does not increase the probability or the consequences of an accident. No - new accident possibilities are created by the failure of the time delays. Failure of a time delay relay to operate as designed will cause the service water flow transmitter to operate in previously analyzed modes. These new relays are qualified to replace the previously installed instantaneous time delay relays. There is no reduction in the margin of safety as defined in the Technical Specifications for the control room ventilation system 3/4.7.2. Therefore it has been determined that this change does not create an unreviewed safety question.
Chance Numher/USAR Section LCN 7.5-17 / Table 7.5-1 (pg 10 of 12)
DLescriction and Basis for Chancet This design modification replaced the fuel pool level (SFC) indicator 21
scales in the main control room with new range parameters depicting actual feet above fuel pool bottom, top of fuel, or top of reactor flange, as applicable. The purpose of this change is to provide the main ;ontrol room operators with more representable indication of I
actual fuel pool level, therefore, maintaining the reliability of I operator control.
8"===rv of Safety Evaluation In providing the operators with more representable indicator scales, the consequences of an accident previously evaluated in the SAR due to a violation can be more effectively controlled and/or corrected.
This will ensure that minimal release of radioactivity is subjected to the atmosphere, and that adequate fuel cooling is provided to-avoid fuel damage. Since the function of the subject level indicators has not changed, failure of the indicators will not result in an accident of any kind. There are existing painted marks on the pool walls, delineating minimum water level in case of indicator failure. The SAR does not analyze malfunctions to the fuel pool cooling and clean-up system on a sub-component level. However, replacement of the subject indicator scales will not in any way result in a structure, system, or component malfunction. Even though two safety-related level indicators are associated in this change, they are only required for safety during refueling operations.
Failure of these indicators to function during this period would only result in the loss of level indication, not system operation. No new
, components are being added as a result of this change. The SFC l system will still operate and function as per design intent. _The margin of safety for restrictions on minimum water level in the spent fuel pool, upper containment fuel pools, and the reactor cavity,-as defined in the basis of Technical Specification 3/4.9.9 and 3/4.9.11, is not affected as a result of this change. The subject level indicators will still function as per design intent to ensure that sufficient water depth is available. Therefore it has been concluded that this modification does not constitute an unreviewed safety question.
Chance Number /USAR Sections LCN 8.1-2 / Figure 8.1-4
/ Figure 8.1-6 Description and Basis for Chances This nonsafety-related modification changed the normal power source to the auxiliary boilet from transformer 1RTX-XSRIA (Fancy Point Substation) to the 13.8KV construction loop. The modification will reduce the probability of transformer 1RTX-XSRIA failure.
22
.i I
i s
an===ry of safety Evaluations This modification will decrease the probability of. an . accident because station power will be unaf fected by the nonsafety-related auxiliary boiler energization/ operation, therefore station power becomes more reliable. Since the non- saf ety related- 13.8KV construction loop (new aux boiler power source) is isolated from- '
station power,.the loss of power fed from 1RTX-XSRIA will not result in an increase in consequences of an accident nor will it create possibilities of an accident not previously evaluated. - The auxiliary boiler is not described in the Technical Specifications Electrical Power Systems (Technical Specifications 3/4.8 Bases and LCOs). But the modification will actually--increase the reliability of safety margins by isolating the auxiliary boiler from the plant's electrical ,
power system as described previously.
Chang 0 Mn=her/USAR sections LCN 8.3-27 /Page 8.3-35 Description and Basis for Chance This modification revised a requirement within the text of.the-.USAR section describing the " Electrical Cable Arrangement". The subject requirement which stated that.all-electrical wire splicec made should conform with the manufacturer's procedures, was not .always applicable. Therefore, this requirement was revised to include that approved equalities to the manufacturer's recommended procedures >
would be acceptable. The RBS Equipment Qualification Group can-approve this type of equivalent procedure.
Sa===rv of safety Evaluation:
This modification is a document enhancement only and does not represent a new design. Therefore the probability and consequences of an accident previously evaluated has not. increased. In addition, no new failure modes or postulated accidents have been created as a result of the revision. This change has no impact on the function or margin of safety of related components. It has been concluded that this modification does not , constitute .an unreviewed safoty question.
Chance N"=her/USAR sectiont ~ LCN 8.3-30 / Table 8.3-2a (pg 1 of 3)
/ Table 8.3-2a (pg'2 of 3)
/ Table 8.3-2b (pg 1 of 4)
/ Table 8.3-2b (pg 2 of 4)
/ Figure 8.3-14a
/ Figure 8.3-14b
/ Figure 8.3-15 i
23
< w , - . . , , , _
~j Description and Basis for Cha*Nt-I This change was a result of an engineering evaluation performed on tho automatic loading feature of existing standby emergency diesel l generators (EGS). The referenced USAR tables and figures were. !
revised to reflect: existing field conditions. ;
s===ary of safety Evaluatient !
The standby diesel generators provide power to emergency iloads necessary to safely shutdown the reactor after a loss of coolant .
accident -(LOCA) concurrent ~ with loss of of fsite power, . without exceeding the loading limits of the diesel generators. . Since, the existing (as built) automatic loading of the diesel generators 1EGS*EG1A' and 1EGS*EG1B does not exceed an authorized' loading. limit: -!'
t under any. postulated conditions, the margin of. safety cannot be reduced. Therefore, this modification does not constitute < an ,
unreviewed question. I chance Mn=her/USAR sections LCN-8.3-33 -/ Table 8.3-1 (pg 1 of 11)
/ Table 8.3-1 (pg 2 of 11) .j Descrintion and Basis for Chanaat This change modified the standby-station service loads to reflect deletion of the' standby service water pump 2C and cooling-tower pump i house supply fan from the Division I standby diesel generator loads.
This change is a document change only as this modification was.made ,
in 1985 to meet a license condition 1 (3) on the diesel -loading.
requirements. This change corrects this oversight .and - accurately reflects the plant configuration and to make Table 8.3-1 consistent with USAR Section 7.3.1.1.8 and the technical specifications.
Su==ary of safety Evaluationt 4
Per a pre-startup license condition one division of the standby service water pumps was removed from the Division-I standby. emergency diesel generator and placed on'the Division III diesel generator (HPCS) to allow adequate cooling of the diesel in the event of a. loss of offsite power concurrent with the loss of one diesel. These changes were made and evaluated at that time prior to startup and Table 8.3-3 was revised to reflect addition of these loads in FSAR amendment 16 (1985). Therefore this change having been previously evaluated does not increase the probability or the consequences of an accident nor-does it increase the probability-of any malfunction.
This change is a document change only to reflect information previously removed from the Division I diesel generator and was reflected in the USAR on the Division III diesel. Therefore it was 24 l
l
1 determined that this change does not create an unreviewed safety question.
Chance Mn=her/USAR sections LCN 9.1-21 / Figure 9.1-23b ;
Descrintion and Basis for Chances ;
This modification revised a USAR figure to correct system connection designations to a nonsafety-related liquid monitor (1RMS-RE120) which '
is utilized in the radiation monitoring system (RMS) to detect radiation levels in'the fuel pool cleanup demineralizer effluent. '
This change was implemented to be consistent with the current-configuration of the plant.
su===ry of safety Evaluation This modification was only a figure revision and no change was made to the physical configuration of the plant. As a result, th '.s drawing revision to a nonsafety-related component which is r.ot governed by technical specifications does not effect acci/.ent probability or consequences and does not reduce the margin of-sefety of any other safety-related system. Therefore, it has -been concluded that this modification does not constitute an - unreviewed '3afety question.
Chance Nn=her/USAR section LCN 9.2-48 /Page 9.2-68
/Page 9.2-69
/ Figure 9.2-24
/ Figure 9.2-24a Descrintion and Basis for Chancet- !
This change replaced three 50% cooling tower makeup water sludge pumps with two 100% pumps and added two seal water booster pumps to supply seal water to the sludge pumps. This is a system enhancement to increase availability and efficiency to the cooling tower makeup water system.
Sn===ry of safety Evaluation:
The cooling tower makeup water sludge pumps are not safety-related and are not evaluated in the SAR. They are used to support power generation only, therefore this change does not increase the probability or the consequences of an accident. There are no new postulated accidents created by this modification. These pumps are not addressed in the basis for any technical specification.
Therefore this change does not create-an unreviewed safety question.
25
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Change N=her/USAR section: LCN 9.2-104 /Page 9.2-2 Descrintion and' Basis'for'Chancet l
- This modification provided a backup hypochlorite (SWP) injection- '
t system to chlorinate the service water system in the event the main
- hypochlorite system is out of service. The modification'will ensure. ,
that _ optimum residual chlorine levels within the service water system
- are maintained.
- l l
8"--ev of safety Evaluations i
The backup hypochlorite injection system will perform ' the same-function'as the current system; control water quality of the-service
- water-system to minimize sealing, corrosion, and biological fouling. ?
The-hypochlorite; system is not required for safe shutdown and the backup system does not increase . the probability. or addition of a consequences of an accident previously evaluated. The hypochlorite injection system does not perform any safety-related functions and will not create any safety-related requirements _ not_ previously.
evaluated. In addition, this modification is not required to support-4 any safety limits set.forth in the' technical specifications. It has been . concluded that this modification does not . constitute an unreviewed safety question.
Change Number /USAR Sections LCN 9.2-119./Page 6.4-3 l /Page'7.3-31'
/Page 9.2-61 I /Page 9.2-62 i /Page 9.2-63 l /Page 9.2-65.
l
/Page.9.2-66 l
/Page 9.4-3 I /Page 9.4-5 I
/Page 9.4-9' i
/ Table 8.3-2a (pg 1 of 3)
/ Table 8.3-2a_(pg 2 of 3)
/ Table 8.3-2a (pg 3 of 3)
/ Table 8.3-2b (pg 1 of 4)
/ Table 8.3-2b (pg 2 of 4)
< / Table 8.3-2b (pg 3 of 4)
/ Table 8.3-2b (pg 4 of 4)
/ Table 9.2-1 (pg 1 of 3)
/ Table 9.2-15 (pg-1 of'2)
/ Table 9.2-19 (pg 1 of.1)
/ Table 9.4-1 (pg 1 of 4)
/ Table 9.4-1 (pg 3 of;4) 4 / Table.9.4-2 (pg 1 of 4) 26
' o-- g =+ ---w.v-
- .- - .-_ ~- _ _ . _ _ _ , _ - _ . - - - _ . . . . _ .
I I
. o
/ Table 9.4-2 (pg 2 of 4)
/ Figure'7.3-12-(sh 1 of 17)-
p
/ Figure 7.3-12-(sh_3 of 17) -
E /Pigure'7.3-13-(sh 1 of 15)=
l / Figure 7.3-13 (sh:3 of 15)
/ Figure 7.3-13 (sh 6 of 15)- :
/ Figure 7.3-13 (sh 9 of 15) )
/ Figure 7.3-13_ (sh 12~ of 15)
/ Figure 7.3-13_(sh 13 of 15)
/ Figure 7.3-13 (sh 14 of 15)
/ Figure-7.3-14-(sh 1.of'16)
/ Figure-7.3-14f(sh'2 of 16)-
/ Figure 7.3-14 (sh:3.ofL16) !
/ Figure 7.3-14-(sh 4 of 16)
-/ Figure 7.3-14 (sh 8;of_16).
/ Figure 7.3-14: (sh 11_of 16)
./ Figure 7. 3-14 (sh 12 of 16) .
/ Figure 7.3-14 (sh 13 of 16) .;
/ Figure 7.3-14 (sh 15' of 16)
/ Figure 7.3-14' (sh 16 of 16)
/ Figure,7.3-23 '(sh 40 of _44) '.
/ Figure 8.3-14a
/FigureL8.3-14b q
/ Figure 8.3-15^
/ Figure 9.2-8h
/ Figure 9.2-87
/ Figure 9'.4-la
/ Figure 9.4-1b Descrintion and Basis for Chances.
This modification revised the control building' ventilation chilled water system by upgrading four-50%: capacity water chiller unitsito operate as four 100% capacity units. This resulted'inLa spare?100%
1 capacity chiller.in each division of the control building ventilation This change also enhanced the modulation controls of'the
~
- system.
L main control room air handling unit heaters to maintain control room temperature within design limits. _j j
l t
8"===rv of Safety Evaluations ;
This modification conforms to the_ design concepts of ' a reliable L system as described - in USAR Section 9.2, such,that thereLare two redundant and independent trains which ^ meet the singla failure criterion. In addition the automatic starting-of one 100% chiller and the control room duct heater will enhance the USAR commitment to- l provide a fully automatic safety' systemz .to handle ~ postulated accidents. Therefore the probability and consequences' of an accident previously evaluated are not increased. Since this modification 27
requires less equipment for the same system capabilities, the possibility of a new accident is not created. Furthermore, the probability of a malfunction of safety-related equipment is reduced because fewer chillers are operating to handle the required loads.
This equipment meets the required equipment qualification criteria and conforms to all existing applicable standards. The margin of r safety as defined in Technical Specification 3/4.7.2 and the bases of same is not reduced by this change. Therefore it has been concluded that this change does not create an unreviewed safety question.
Chance Nu=her/USAR section LCN 9.2-130 / Figure 9.2-1b Description and Pasis for Chance This modification removed expansion joints 1SWP*EJ4E, 4F, 4G, and 4H which were utilized in the service water system (SWP) located at the inlet and outlet of two control building chillers (1HVK*CHL1A and 1HVK*CHL1C). These expansion joints were replaced with hard pipe spools analyzed to meet ASME design requirements.
Sn===ry of Safety Evaluation:
This modification was made in accordance with ASME design l requirements which verify that. associated piping supports, "
l components, and nozzle loadings meet all applicable allowable stresses and loads. It follows that the probability or consequences of an accident previously analyzed is not increased and that no postulated accidents have been created as a result of'this change.
In addition the margin of safety as defined in the basis to the l technical specification has not been reduced. Therefore, it has been concluded that this modification does not constitute an unreviewed safety question.
Chance Nn=her/USAR Section: LCN 9.2-131 / Figure 9.2-1f Description and Basis for Chances This modification revised a USAR figure to indicate that service water supply valves E12*VF014A and E12*VF014B to the residual heat removal system (RHR) heat exchangers are locked open. This modification is intended to prevent overpressuring the channel section of the heat exchangers in the event of a tube failure. There was no physical change to the system since the valves are currently locked open via administrative procedures. This modification was implemented to be consistent with plant conditions.
Sn= mary of Safety Evaluation:
This modification was only a figure revision and no new hardware was 28
introduced to the system. The change did not increase the probability or consequences of any postulated accidents. In addition, this revision did not reduce the margin of safety as defined in the basis the for technical specifications. Therefore, it has been concluded that this change does not require an unreviewed safety question.
Chance N"=her/USAR Secti9.B: LCN 9.2-133 / Figure 9.2-1b pescriotion and sasis for Change This modification removed expansion joints 1SWP*EJ4A, 4B, 4C, and 4D which were utilized in the service water system (SWP) located at the inlet and outlet of two control building chillers (1HVK*CHL1B and 1HVK*CHL1D). These expansion joints were replaced with hard pipe spools analyzed to meet ASME design requirements.
Sn===vy of Safety Evaluation This modification was made in accordance with ASME design requirements which verify that associated piping supports, components, and nozzle loadings meet all applicable . allowable stresses and loads. It follows that the probability or consequences of an accident previously analyzed is not increased and that no postulated accidents have been created as a result of this change.
In addition the margin of safety as defined in the basis'to the technical specification has not been reduced. Therefore, it has been l
concluded that this modification does not constitute an unreviewed safety question.
Chance Nn=her/USAR Section LCN 9.2-134 / Figure 9.2-la Descriotion and Basis for Chance:
This modification removed the internals from the service water turbine plant component cooling water (TPCCW) heat exchanger outlet check valves 1SWP-V14, V15, and V16. The original function of the check valve internals was to prevent drainage of a TPCCW heat exchanger following an interruption of flow. However, current administrative controls are sufficient to prevent this.
Sn===ry of Safety Evaluation The TPCCW system is a nonsafety-related system and is not required ~
for the safe shutdown of the plant nor is it required to mitigate the i consequences of an accident. In addition, the check valves are not essential for the operation of the plant nor are they essential in preventing drainage of the TPCCW heat exchangers. It follows that this modification does not increase the probability or consequences l
l 29 l
of a previously postulated accident and the margin of safety as defined in the basis to the technical specifications has not been reduced. Therefore, it has been concluded that this modification does not constitute an unreviewed safety question.
Chance _ Number /USAR Section LCN 9.2-135a/ Figure 9.2-8h
/ Figure 9.2-8j
/ Figure 9.3-lb Descrintion and Basis for Chance This modification changed two safety-related pressure control valves (1HVK*PDCV25 A & B) within the control building HVAC system (HVK) by converting them into globe valver. (1HVK*V3007 and V3008). This change was implemented to insure a minimum flow througr, evaporator i
and maintain stable operation of associated HVK chilled water pump. !
I gn =ary of Safety Evalu,31LSD:
. This modification changed the existing HVK pneumatic pressure control f valves to manual globe valves and disconnected the instrument air l l lines. The valves were adjusted during chilled water balancing and l were left locked in that position, therefore insuring-an adequate continuous flow of chilled water in all modes of operation. The j functional capability of the system is maintained and the margin of l safety as defined in the technical specifications has not been
! compromised as a result of this change. Therefore, it has been concluded that this change does'not constitute an unreviewed safety 1
question.
d Chance Nn=her/USAR Sectient LCN 9.2-138 / Figure 9.2-89 i
Descrintion and Basis for Chance:
This modification revised a USAR figure to reflect as-built l(
conditions of two . strainers located on the suction side of the l radwaste chilled water recirculation pumps 1HVN-P4A and P4B.
s S n = *'= r y of Safety Evaluati_QD3 h s
This modification was a drawing revision only and did not change the current system configuration. These recirculation pumps are ;
essential for operation of the radwaste chilled water system and a j means of protection is the use of strainers on the: suction side of the pumps. Showing these strainers on this drawing does not increase j the probability or consequences of a previously evaluated accident nor does it decrease the margin of safety as defined in the basis to j the technical specifications. Therefore, it has been concluded that this change does not constitute-an unreviewed safety question.
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l Chance Ma=her/USAR Section: LCN 9.2-140 / Figure 9.2-10 Description and Basis for Chances l
This modification corrected the air operated valve -( AOV) identification numbers utilized in the sand filter backwash as part ,
of the sanitary sewage treatment system. This change was implemented to be consistent with_ current plant conditions.
sa---ev of safety Evaluation This modification _ revised a USAR figure- to reflect as-built conditions of the sanitary sewage treatment system. This was a drawing change only and did not modify any plant equipment, systems, ,
l or' structures. In addition-the probability or consequencesrof an
. accident previously analyzed has not- been increased - nor has- the' margin of safety as defined in the basis to the technical l specifications been reduced. Therefore, it has been concluded that this change does not constitute an unreviewed safety question. 1 Chance Nn=her/USAR 8ection: LCN 9.2-149'/ Figure-9.'2-7d Descrintion and Basis-for Chances. i This modification corrected the mark number (1CCS-V378)- which
. identifies a nonsafety-related closed cooling water system (CCS) drain valve on' instrument air compressor intercooler (IAS-C1B) . This
~
drawing change was made to be~ consistent with plant conditions'and '
other associated drawings.
Sn===ry of Safety Eva'luation This revision correctly reflects the identification of the-nonsafety-related drain valve. This modification does not change the physical configuration of any equipment to increase the probability or consequence of.any previously evaluated accident-nor does it hinder the cooling capability or operation of the_CCS system. In addition, no margin of safety as defined in the basis to . the' ~ technical specifications has been compromised. Therefore, it has 'been concludad that this modification does not constitute an unreviewed safety question.
Chance Nn=her/USAR Section LCN 9.2-154 / Figure 9.2-1b Description and Basis for Chance:
This modification-revised a USAR figure to correctly reflect that four safety-related normal service water _ supply header pressure
-transmitters 1SWP*PT21J, K, L, & M are locally mounted instead of 31 j
panel mounted. This was a document change only and did not constitute any physical work in the field. ,
Sa===ry of Safety Evaluations The margin of safety as defined in any technical specification is not i reduced by correcting - editorial errors associated with the figure symbolism. These are editorial corrections only-and do not change the "as-built" condition of the SWP system. In- addition, the probability or consequences of an accident previously postulated have not ' been increased. Therefore, it has been concluded that this change does not constitute n unreviewed safety question.
Changg_Mgahgr/Jl&pgj;1gn LCN 9.2-155 / Figure 9.2-24b
-Description and-Begia for Chances This modification installed two cleanout valves to the makeup water !
system (1MWS-V3057 and 1MWS-V3058 and their associatnd flanges) to j provide a flushing mechanism at the river makeup -structure . to Lj mitigate suction line clogging of river sand and silt. The associated - t design documents have been revised to reflect this change. ;
sn==arv of safety Evaluations-As described in-the USAR the cooling tower makeup-water system is nonsafety-related and is only-required for normal plant operation.
Since this modification enhances the flushing capability of the MWS- ,
system, the performance and reliability of the system have act been> i compromised nor have the consequences or probabilities of an accident previously postulated been increased. In addition, the installation ,
of the valves does not reduce the margin of safety of any interfacing ,
systems as defined in the basis to the techni' cal specifications.
Therefore, it has been determined that this change does not ,
i constitute an unreviewed safety question, Change Numher/USAR Sectiont LCN 9.2-156 / Figure 9.2-1d L Description and Basis for chanaat This modification changed the normal operating position from open to closed for the reactor plant component cooling water (RPCCW) heat exchanger supply valve (1SWP*MOV501A) and return valve (1SWP*MOV511A). These motor operated valves (MOVs) are utilized to isolate loop A and return lines of the standby service water system for CCP heat exchangers. This modification was based on the potential of- the Division III pump " running out" due to start failure of the Division I diesel generator and the RPCCE heat exchangers not isolating. The normai v10: d position of these MOVs will ensure that 32
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the Division III pump will not "run out" upon a start failure of the Division I diesel generator, ar- ov of safety Evaluation:
The intent of this modification is to prevent damaging of the Division III service water pump and therefora increasing ths reliability of the system. In ad:11 tion, this modif'4 cation does not increase the probability or consequenacs of an accident previously postulated and analyzed nor does it reduce the ha7 gin of safety as defined in the basis to the technical specifications. Therefore it has been concluded that this change does not constitute an unreviewed safety question.
Change Muaber/USAR Section: LCN 9.3-24 / Figure 9.3-b0 Descrintion and Basis for chance:
This modification replaced the existing Velan steam traps (NJ64-TRP004A and 4B) in the drain lines of two off gas preheaters. The E_
replacement steam traps are more suitable to the offgas system operating conditions by indirectly increasing hydrogen recombiner efficiency in addition to decreasing hydrogen concentration in the system and therefore reducing the potential for explosionn.
s====ry of safety avaluation:
The replacement of tha-Velan steam traps does not change the system function, performance, or reliability nor does it increase the probability or consequences of an a.ccident previously postulated and analyzed . In addition, since thiri modification enhances the performance of the traps it increases the margin of safety as defined in the basis to Technical Specifications 3/4.3.7.11. by reducing the potential for explosions. Therefore, it has.been determined that this change does not constitute an unreviewed safety question.
Change Number /USAR section: LCN 9.3-28 / Figure 9.3o8c paperintion and Basis for chanaat This modification added two globe valves upstream of each of the two solenoid operated valves (SOVs): IN64-SOVF010A and B. These globe valves are intended to allow pressure in the associated off gas system (OFG) preheater to be maintained in case of an SOV or steam trap failure.
sn===ry of safety Evaluat.4.gn:
The use of the globe valves to maintain effective preheater operation 33 w ~ .
I l
l i
l allows the recombiners to more ef ficiently perform their design 1 function of reducing hydrogen concentration in the off gas stream i thus keeping the possibility of a hydrogen explosion to the very !
minimum. This aids in OFG system availability and reliability as well as maintaining the release of any radioactive gaseous activity well within ALARA limits. In addition, this modification does not increase the probability or consequences of an accident previously l postultted and analyzed nor has the margin of safety as defined in ,
the basis to Technical Specification 3/4.21.2 been reduced. l Therefore, it has been concluded that this modification does not constitute an unreviewed safety question. l Chance Nu=her/USAR 8ection LCN 9.3-118 / Figure 9.3-4a Dgscription and Basis for Changst This modification revised the tubing and valve configuration on the reactor sampling panel (G33-PNLZO20) by relocating existing valves and add'"g three-way valves with inline relief valves to the oxygen monitor sample lines. The reactor sampling system (SSR) is a subsystem of the process sampling system and is utilized for monitoring reactor coolant chemistry. This modification was implemented to improve the accuracy of grab sampling by reducing
, process temperature and to mitigate overpressure conditions by adding relief valves.
Bu==ary of Safety Evaluationt Relocating and adding to the tubing and valve configuration of the reactor sample panel does not compromise the performance, reliability, and function of this system nor does it have any impact on interfacing plant systems. The modification does not increase the probability or consequences of an accident previously evaluated nor has it created any new postulated scenarios. In addition, the margin of safety as defined in the basis to Techrical Specification 3/4.4.4 has not been reduced. Therefore, it has been concluded that this change does not represent in unreviewed safety question.
Change.. Eusttsr/USAR Sections LCN 9.3-135 /Page 9. 3-3
/ Table 3.2-1 (pc 9 of 34)
/ Table 3.2-1 (pg 34 of 34)
/ Figure 9.3-lb Description and Basis for chances l
This change adds 2 banks of compressed air bottles (4 bottles per I bank) te the air accumulators in each division in the control l building instrument air system to provide a backup air supply, These J bottles were added to assure adequate capacity of safety-related air ]
l 34
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l accumulators in loss of instrument air events. This modification will allow minimum operator action during accident scenarios )
< concurrent with loss of instrument air compressors.
Su===ry of safety Evaluation The addition of air bottles to the instrument air accumulators will add a margin of air reserve without removing any of the safeguards of the system. The new installation is seismically qualified and designed and built to applicable codes and standards, therefore the probability of an accident previously evaluated is not increased. .
The enhancement of the air reserve is physically implemented without any effect to the existing system, so the consequences of a previously evaluated accident is not increased nor is the probability of a dif ferent accident increased. This modification will ensure the ;
availability of the safety-related air supply post-DBA thus enhancing the margin of safety as defined in the technical specifications.
Therefore this change has been determined to not create an unreviewed safety question.
Chance N"=her/USAR 8ectigst LCN 9.3-137 / Figure 9.3-1b Description and Basis for Change This modification revised the normal operation condition status of four safety-related and four nonsafety-related instrument air system (IAS) root valves. This change was implemented to reflect current operating conditions, however, the valve positions depicted in the USAR figures are for information only and station operating procedures are consulted for actual valve lineups.
Sumagry__of Safety Evaluation I The revision of valve positions within the IAS system does not impact l the safety, performance, reliability, or operability of any plant system. In addition the probability or consequences of an accident has not been increased as a result of this change. Furthermore, the margin of safety has not been reduced as tefined in the technical specifications. Therefore, it has been concluded that this change does not constitute an unreviewed safety question. ,
1 I
Chance Numher/USAR Sections LCN 9.3-139 / Figure 9.3-7c Description and Basis for Chanaat 1
This modification removed a flexible hose and a portion of the piping and then capped the line remaining downstream of valve B33*F025B which is utilized in the reactor recirculation system. A blind flange was added and the flanged off downstream piping was downgraded i
i 35 l 1
4 4 to class 4.
J ury of safety Evaluation:
' Rcr ,a1 of the flexhose and closing both of the open ends with the l : , and blind flange disables . an unnecessury bonnet vent system. )
l i is modification does not hinder the performance, operation or
.eliability of the recirculation system. Furthermore, the downgrading of the downstream pising and valve does not affect the margin of safety as this line Ls no longer connected to primary system and is totally isolated. Therefore, it has been' concluded that - this modification does not constitute an unreviewed safety question. !
Chance Ma=her/Ushe sections LCN 9.3-146 /Page 9.J-23 Description and Basis _for Chamaet This change was made.to add a statement to the SAR on the evaluation of flooding due to pipe cracks or breaks and to indicate the associated SAR sections in-Phich this evaluation can be.found. This !
is only a clarifying statement. This change did not result in any ,
plant modifications, su---ry of safety Evaluation This addition to USAR Chapter 9 was made to clarify the design capability of the auxiliary building drainage system and does not alter any hardware in the system. Therefore the probability nor the consequences of an accident are not. increased. The system configuration in not altered nor are any system requirements reduced so the possibility of a new accident is not increased. This revision reduces vagueness and improves SAR chapters interrelationships.
Therefore it has been determined that this change does not create an unreviewed safety question.
Chamae M"=her/USAR sections LCN 9.3-147 / Figure 9.3-1C Descriotion and Basig for Change _
This nomenclature change revised an equipment mark number (1H22*PNLP011) which identifies a safety-related standby liquid ;
control panel.- The change was made to the USAR figure to De consistent with plant conditions and other associated design drawings.
Summary of safety Evaluation This revision will correctly reflect the safety-related standby 36
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liquid control panel. This modification does not change the physical configuration of any equipment to increase theIn probability or addition, no consequence of any previously evaluated accident.
margin of safety is reduced by this change. Therefore, it has been concluded that this modification does not constitute an unreviewed safety question.
Change..Bumber/USAR ..Section: LCN 9.3-153 /Page 9.3-2
/ Table 9.3-4 p_escription and Basis for Change:
This change added a statement to clarify in the SAR that air operated components with Category 2 actuators are not required to meet the maximum particulate size restrictions outline in Chapter 9. Air operated valves which are safety-related but have no active safety function (eg. open or close) are exempted from meeting these requirements.
Summagy of safety Evaluation:
This statement was added to clarify the fact that a Catogory 2 air operated actuator for a valve where the valve is safety-related on the basis that it is required to maintain a pressure boundary without an active safety function is not required to meet particulate size restrictions. This change does not reduce any system requirements previously set forth in the SAR nor does it modify any system hardware and therefore does not increase the probability nor the consequences of an accident. There is no reduction to the margin of safety as defined in the basis for any technical specification. .
Therefore this change has been determined not to created an l
unreviewed safety question. ,
Change Nn=her/USAR_#_ection: LCN 9.4-25 / Figure 9.4-7b D.gspyintion and Basis for chance:
This change added a localized, manually operated, self contained filter unit to provide continuous ventilation for reactor water sample panels and the reactor water cleanup (RWCU) backwash tank.
This modification is considered to be another subsystem to the main containment purge system. It is designed to run continuously and provide an alternate means for ventilation of the reactor sample panels and the RWCU backwash tank.
Summary of Rafety Evaluation:
This subsystem is designed as Quality Class 2 and does not have any safety function. In addition, implementing this alternative 37 4
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A filtratien system for ALARA considerations does not impact any other plant system function or operability. Therefore the probability of occurrence nor the consequences of an accident is not increased.
This filter is isolated and separated from the main containment purge system and cannot create any malfunction of any safety-related system or structure. Furthermore, the margin of safety as defined in the i technical specifications has not been compromised. Therefore, it has been concluded that this change does not constitute an unreviewed safety question.
Chance Nu=her/USAR Sections LCN 9.4-29 / Figure 9.4-4d Description and Basis for Change This modification installed a blanking plate in the outdoor air suction duct for 1HVT-FN10A and 10B. This change prevents the in-leakage of outdoor air into the refrigeration system.
Summary of safety Evaluatigst The refrigeration system for the charcoal adsorber vault operates in low temperature range; any moisture in the subject air handling system gets deposited (freezes on the cooling coil of the unit). To minimize the total moisture in-leakage into the system, and since no outdoor air is required for the normal refrigeration cycle, this modification was implemented. This change has no impact on the operation of this nonsafety-related system; it does not constitute an unreviewed safety question.
Change Mn=her/USAR Sectiont LCN 9.4-81 / Figure 9.4-2a Descrintion and Basis for Chances i
( This modification changed .the fail position of the fuel building charcoal train isolation dampers 1HVF*AOD20A, 20B, 31A, 31B from f ail closed to fail open.
Summary of Safety Evaluation This change increases the availability of the filter train. This enhances the ability of this system to perform its intended design function of mitigating the consequences of a fuel handling accident.
The probability or consequences of an accident previously evaluated is not increased nor is the possibility of any new accidents created.
This change does not constitute an unreviewed safety question.
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l Chance Ma=her/Ushe sections LCN 9.4-83 /Page 9.4-85
/ Figure 9.4-4 (pg 2 of 4)
/ Figure 9.2-1c
/ Figure 9.2-1f Description and Dr. sis for Changgs l This change is being made to reflect the installation of replacement 1 coils in vario.as unit coolers in the reactor building HVAC system. l These new coils were installed in safety-related unit coolers and have the same dimensions as their replacements but have greater heat removal capacity ,at rated flows.
Summary of Safety Evaluatient ,
i Since the-heat removal capabilities of these new coils exceeds the previous ones, there is no increase in the probability or the consequences of an accident previously evaluated in the USAR. No Wew '
accident scenarios are created by this modification as the overall
~
system configuration remains unchanged. The consequences of a malfunction of a safety-related component or system are unchanged as ,
the overall system operation and performance has not been altered. '
The basis for Technical Specification 3/4.6.5 and 3/4.7.8 are unaffected by this change as the operating characteristics of the new coils are bounded by the calculations that support these technical specifications.' Therefore it has been determined that this change does not create an unreviewed safety question.
Change Number /USAR Sections LCN 9.4-84a / Figure 9.4-7c t Descrintion and Basis for Chance This modification replaced annulus pressure control fans (HVR-FN16A/B) low flow cut out switch HVR-FS163 with motor control center electric contact. A fan motor thermal overload condition will now automatically start the standby fan.
8"===ry of Safety Evaluation 1 The annulus pressure control system is designed to maintain a negative pressure in the annulus. This change enhances the ability of the system to perform its intended design function without adversely affection system operation. It has been determined that this change does not represent an unreviewed safety question.
I 39 1
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1 1
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h ection: LCN 9.4-89 / Figure 9.4-lb Descrintion and Basis for chanag: l This modification revised low pressure tube routing associated with- '
the control room air handling units (HVC) such that the flow switches !
are sensing duct pressure rather than being influenced by ambient pressure. ]
S: -ev of safety Evaluation:
The function of these flow switches is unchanged and the rerouting of ,
the low pressure tubing to a different location to prevent !
abnormalities associated with the ambient pressure fluctuatien will ;
not increase the probability or consequences of an accident previously. postulated and analyzed. In addition, the margin of safety r.s defined in the basis to the technical specifications-has not been compromised as a result of this change. Therefore, it has ,
been concluded that this change does not constitute an unreviewed ,
safety question.
Chan i Ma her/UsAR section: LCN 9.4-91 /Page 9.4-69 :
DescLotion and Basis for Change. ,
This change deleted the logic to automatically close the drywell unit cooler temperature control valve (TCV) when the drywell unit cooler ,
fan stops running by deenergizing the TCV solenoid valves. This will prevent any silt / crud and corrosion product buildup in the unit coolers by maintaining a flow of service water through the coolers at manually controlled flow rates, sa===ry of safety Evaluation This change to maintain a flow of service water through the unit I coolers will improve system reliability by decreasing the buildup of .
! corrosion causing silt and crud in the service water piping.
Deenergizing of the solenoid valves does not impact the failure mode, >
which are; failure of power or air, of the temperature control valves. Therefore the probability or consequences of an accident are not increased. This modification does not alter the inlet and outlet temperature sensors on the unit cooler. They will monitor unit l cooler tsmperature regardless of fan operating status, so the probability of a new accident is not increased. The drywell unit, coolers, temperature control valves and the associated solenoid valves are nonsafety-related equipment and are not required to perform any safety function. Technical- Specification 3/4.6.2.6 requires that the drywell average temperature shall not exNed 40
145 F. Eliminating the control permissive to close the drywell unit coolers TCVs when the fans are not running will have no effect on the i margin of safety as defined in the basis of this technical specification. Therefore this change has been determined to not create an unreviewed safety question.
Change.. Number /UshR Sections LCN 9.5-C1 /Page 9.5-10
/Page 9.5-1
/Page 9A.2-2 Description and Basis for_Changst This change exempted valve trim piping in the fire protection system from seismic support requirements.
s"-==ry of safety Evaluation:
Failure and collapse of the valve trim piping on the fire protection risers will not damage or disable any Category I equipment needed for safe shutdown. Therefore, the probability or consequences of any previously analyzed accident will not increase. Rupture of the fire suppression system will not impair the capability of safety-related equipment to function. In addition, no different accidents than those previously analyzed are possible, and the probability or consequences of system malfunctions will not increase. Furthermore, fire protection following a safe shutdown earthquake (SSE) is provided by hose stations rather that by water spray and the water supply to the hose stations is seismically supported thus maintaining
- fire protection. The margin of safety as defined in the technical specifications has not been reduced, thus an unreviewed safety question is not created.
shange. Number /USAR Section LCN 9.5-63a / Figure 9.5-Ic Description and Basis for Chances This change revised a USAR figure to show the correct identification numbers for flow paths utilized in the fire protection system directed to the diesel generator rooms. This change was implemented to more accurately reflect the actual plant configuration.
En===ry of Safety Evaluation The changes involved the drawing revision only of identification numbara to more accurately reflect the plant. These changes do not hapact the operation or function of any portion of the fire protection system. These changes do not increase the probability or consequences of any accident previously evaluated nor do they create 41
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I i ;
the possibility of any new accidents. These corrections do not represent an unreviewed safety question.
- Change Number /UshR Section LCN 9A.2-15 /Page 9A.2-5 ,
1 Descrintion and Basis for Chancet ,
This-change added the status of valve 1E12*MOVF009 to the USAR to make it consistent with the fire hazards analysis. This valve is deenergized when reactor pressure exceeds 135 psi to protect the RHR/RPV high/ low pressure interface.
sa=ury of safety Evaluation This valve is deenergized whenever reactor pressure exceeds 135 psi '
to prevent spurious actuation which could cause a possible fire j induced interfacing LOCA. By removing power from this valve, ;
repositioning due to a fire induced hot shott cannot occur. This '
valve is not required to place reactor in a afe condition, so no immediate operator action is required to rest >re . the breaker and ;
therefore there is no increase in the probability of an accident.
This valve is required to place the reactor in a cold shutdown condition, so an accident leading to a cold shutdown would require operator action in the auxiliary building to restore power. This could lead to increased exposure for the operator required to restore power. This valve, however may be manually repositioned in the I drywell, which would be acceptable to achieve' cold shutdown. The margin of safety as defined in the technical specification is increased through the use of positive action to prevent a fire )
induced interf acing LOCA. Therefore it has been determined that this change does not create an unreviewed safety question.
Change _Nu=her/USAR 8ection: LCN 10.3-13 / Figure 10.3-1c Descriction and Basis for Chance This modification revised a USAR figure to correctly identify strainers 1 MSS-STR3A, B, C, and D which are utilized at the steam inlet to the first stage main steam air ejectors. These ejectors are part of the original plant design and this revision was implemented to reflect actual system configuration.
Summary of safety Evaluation:
This change was made for document correction only. No change was made to the system design, operation, or function. The system continues to perform its design function to ensure that gaseous 1 offluents are monitored and treated to prevent uncontrolled release of gaseous effluents and provide assurance that releases are 42
maintained ALARA and below 10CFR20 limits. The existence of these strainers in the steam supply lines to the air ejectors has no effect on the instrumentation operability or setpoints or system operability requirements and therefore does not reduce the margin of safety employed in the plant design. Therefore, it has been concluded that this modification d = not constitute an unreviewed safety question.
Chance Nu=her/UshR sections LCN 10.4-21 /Page 10.4-22
/ Figure 9.2-la
/ Figure 10.4-4 Description and Basis for Chance This change modifies the routing of the piping system for the acid injection line to the circulating water system. The acid injection line is used to control the pH of the circulating water system at the fiume. Also the injection valve WTA-V015 is being modified from a manual to an air operated valve. This system is not safety-related and not required for safe shutdown of the plant, su==ery of safety Evaluation:
The relocation of the acid injection line will not inhibit the dispersion of the acid into the flume, therefore system operation is unchanged. The probability of an accident or malfunction of any safety-related equipment is not increased by this change. The systems affected by this change are not addressed in the basis for any technical specification, therefore the margin of safety is not reduced. This change does not create an unreviewed safety question.
I Chance Numher/UshR section LCN 10.4-66 /Page 10.4-22
/ Figure 10.4-4 paperintion an4 Basis for Chance:
This change added a backup hypochlorite injection system to the service water system (SWP) to assure maintenance of optimum residual chlorine levels in service water whenever the normal system is out of service, su==ary of safety, Evaluation:
This change will not modify the chlorination rate of the SWP. This system will only serve as a backup to the main injection system to control water quality, thereby reducing biological fouling and minimizing scaling. The hypochlorite system is not required for safe shutdown of the plant. Therefore the probability of an accident previously evaluated is not increased. Nor are the consequences of any previously evaluated accident increased by this change. The 43
i e
hypochlorite system does not interface with any safety-related '
equipment or functions. It is not required to support any of the safety limits as set in the technical specifications. Therefore this change does not create an unreviewed safety question.
I Chance Number /USAR Sectigst LCN 10.4-69 / Figure 10.4-6a Description and Basis for_ Change This modification deleted pressure test connections, two associated nonsafety-related valves (ICNM-V96 and V98), and a bypass line with an associated nonsafety-related valve (1CNM-V108) which were all utilized within in the condensate system (CNM) for testing purposes.
These components did not provide any safety function and are not necessary for CNM system or overall plant operability.
Summary of Safety Evaluation:
The components above are not required for the performance, operability, or reliability of the condensate system nor do they provide any type of safety function. This modification does not increase the probability or consequences of an accident previously analyzed nor does it reduce the margin of safety for the CNM system or interfacing systems as defined in the basis to the technical l specifications. Therefore, it has been determined that this modification does not constitute an unreviewed safety question.
Chance Number /USAR Sections LCN 10.4-75 / Figure 10.4-4
/ Figure 10.4-3a Q33_cription and Basis for Changet This modification provided a new acid injection support design to reduce pipe movement due to high turbulence in the circulating water flume. The change modified the existing injection tubes to maintain a positive pressure and to reduce corrosion of the injection lines due to acid / water mixing.
A3nnaarv of Safety Evaluation:
The piping and automatic injection modifications that were implemented will not have any adverse affect on the performance, operability, or reliability of the CWS system or any interfacing systems. This change was made to a nonsafety-related system which will not increase the probability or consequences of an accident previously postulated and analyzed. Additionally, the technical specifications do not specifically address the' acid injection system.
Therefore, it has been concluded that this change does not constitute an unreviewed safety question.
44
Chance Na her/USAR section LCN 10.4-77 / Figure 9.2-3b
/ Figure 10.4-6a l
Description and Basis for Chanaat l This modification replaced the existing main condenser motor operated vacuum breaker valve (MOV) with an air operated valve (AOV) and an associated in-line isolation valve which will provide a faster acting speed control function for turbine coastdown.
l so--ry of safety Evaluation The modified breaker will result in a faster acting breaker, an increase in air flow to the condenser, and a faster coastdown of the turbine through critical speeds and wl:1 not affect any safety-related systems or components within the plant. .This modification does not effect the operability or reliability of the condensate system nor does it create new postulated accidents. In addition, the technical specifications do not address the condensate vacuum breaker however the margin of safety with respect to associated: systems as defined in the basis to the technical specifications has not been reduced. Therefore, it has been' concluded that this-change-does not constitute an unreviewed safety question.
Change..Mumber/UsAR sectiont LCN 10.4-79a/ Figure 10.4-3c
/ Figure 1.7-2c Descriptign_and Basis for Change This modification shows the completed sections of a partially installed spongeball type condenser tube cleaning system, = the purpose of which is to improve the cleanliness to the main condenser which will result in lower turbine back pressure and better fuel economy. These USAR figures have been updated to show the isolation valves which interface with the operating system.
sn===ry of safety Evaluations ,
This partial-modification has no impact on current plant operations and wall not have any adverse safety affects on the circulating water system or other plant systems. The current status of the . j ob 1 implementation is such that the installed portion of the new system l does not jeopardize systems needed for plant operation-and-safety.
In addition, the modification will not increase the probability or consequences of an accident previously postulated nor will it effect the margin of safety in associated systems as defined in the i I
technical specifications. Therefore, this modification does not constitute an unreviewed safety question.
i 45
Chamas Mn=her/UshR sections LCN 10.4-80 / Figure 10.4-7b pascrintion and Basis for Chance This modification involved the removal of a 3/4 inch safety-related feedwater system (FWS) valve (1FWS*V118) which was utilized during I
preoperational testing for measuring differential pressure and confirming proper flow distribution but is currently no longer required. This codification eliminates potential leakage of I contaminated water to the drywell.
Summary of Safety Evaluation:
Removing this valve from the FWS system introduces no new safety hazards since the modification has been tested and inspected per ASME requirements to ensure that the probability or consequences of an
.cecident previously evaluated have not been increased. In addition, 1 this change decreases the potential of contaminated water leakage to l the drywell and therefore does not reduce the margin of safety as {
defined in the basis to the technical specifications. It has been '
l concluded that this modification does not constitute an unreviewed safety question. f Change Number /USAR section: LCN 10.4-82 / Figure 10.4-6a Dascription and Basis for Chance This modification revised a USAR figure to assign identification numbers for eight root valves associated with instrumentation connected to the main condenser. This change was implemented to more accurately reflect plant conditions. The valves were supplied along.
with the.. instruments by the vendor and were not previously assigned l numbers.
I so-- rv of safety Evaluations l
! This modification ,::: a document revision only and no change was made
! to the physical configuration of the condensate- system or other related pl. ant systems. The correct identification of these nonsafety-related valves eliminates the potential for inadvertent modifications in future design changes. Furthermore, the margin of safety as defined in the technical specifications for this system and associated components has not been affected. Therefore, it has been concluded that this change does not constitute an unreviewed ,
safety question.
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Change Number /USAR Sectior LCN 10.4-83 /Page 10.4-22
/ Figure 10.4-3a
/ Figure 10.4-3b Description and Basis for Channes This change modifies the circulating water system to provide dechlorination facilities to ensure that the water quality of the cooling tower blowdown line to the Mississippi River meets the National Pollution Discharge Elimination System (NPDES) discharge permit requirement for free available chlorine. This modification also added anti-scale / corrosion facilities to the circulating water system to minimize scaling, corrosion and biological fouling. Also valve mark numbers were added to previously existing valves on the drawings in the USAR to increase the clarity and provide additional-4
' information to aid in evaluation and future modifications or maintenance.
8"--ary of Safety Evaluation The circulating water system chemical injection system is not considered to be safety-related nor does it impact any safety-related i system function. This modification was made to ensure compliance with NPDES discharge limits and to decrease the probability of corrosion and scaling within the circulating water . system.
Therefore, this change does not increase the probability or the consequences of an accident. Nor will failure of this system or any of its subsystems increase the probability of any unpostulated accident. This system is not described in the basis for any technical specification and therefore no margin of safety is decreaned. This change has been determined not to create an unreviewed safety question.
Chance Mn=her/USAR 8ections LCN 10.4-86 / Figure 10.4-Sa !
D6scription and Basis for Chancet This modification was a nomenclature revision to a USAR figure to ,
correctly identify two Quality class II components within the condensate demineralizer system (CND) : air operated valve (A0V12B) and a sample point device (SMPT21A).
Anamary of Safety Evaluationt .
I This modification is a nomenclature change only and does not affect the as-built condition of the CND system or any other-related plant system. Correctly identifying plant equipment has no effect on the margin of safety as defined in the technical specifications of this 47
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s system. Therefore, it has been concluded that this modification does not constitute an unreviewed safety question. r Chance Mn=her/USAR 8ection LCN 10.4-88 / Figure 10.4-3b !
hacription and Basis for Chattgat This modification added a valve (CWS-V3002) and branch to the service water supply to the vacuum priming system (VPS) to ensure reliable operation of the bearing cooling system (BCS) by providing an alternate source of cooling water. This minimizes thermal stresses and wear on CWS and normal service water system (SWP) pumps and associated motors.
Summary of Safety Evaluation:
This modification provides a more reliable means of maintainina bearing cooling water for the CWS and SWP pumps. This change does not increase the probability or consequences of accidents previously evaluated nor does it impact the safety, performance, operability, or reliability of the above systems. In addition, the basis for the technical specifications has been reviewed and this modification has ;
no impact on the margin of safety. Therefore, it has been concluded that this change does not constitute an unreviewed safety question.
Chance Mn=her/USAR 8ection LCN 11.2-12 / Figure 11.2-1k
/Figura 9.3-12b
/ Figure 11.2-1c Descrintion and Basis for Chaqqat This modification installed a pressure regulating valve in each of the sample lines for two total organic control (TOC) analyzers. The ;
TOC analyzers are located in the liquid radwaste system (LWS) for I assisting in filter monitud ng and control. These installed valves are intended to maintain presbure within the rated parameters of the analyzers.
Summary of Safety Evaluation The TOC analyzers are designed to monitor and control processing in liquid radwaste internal to the LWS system (filter control) and do not directly affect any safety-related system. The addition of the pressure regulating valves serve the same function as the needle valve which it replaced except - that they will reduce pressure in static conditions so that the analyzer will not over pressurize.
This modification does not increase the probability or consequences l of an accident previously evaluated nor does it introduce any new 48
l postulated scenarios. In addition, the margin of safety as defined in the basis to the technical specifications for any related system has not been reduced as a result of this modification. Therefore, it has been concluded that this modification does not represent an unreviewed safety question.
Chance Nn=her/USAR 8ections LCN 11.2-41 /Page 11.2-2
/Page 11.2-4
/Page 11.2-5
/Page 11.2-6
/Page 11.2-7
/Page 11.2-8 ,
/Page 11.2-9
/Page 11.2-10
/Page 11.2-11
/Page 11.2-12
/Page 11.2-14
/Page 11.4-1
/Page 11.4-3
/Page 11.4-4
/Page 11.4-5
/Page 11.4-6
/Page 11.4-7
/Page 11.4-8
/Page 11.4-9
/ Table 11.4-1
/ Table 11.4-3
/ Table 11.4-4 Reigtigtion and Basis for chance:
This change revised the descriptions of the radioactive waste system ;
to ensure that the SAR accurately reflects current design. These changes were the result of no modification to the plant but resulted from a thorough system review which revealed a few minor .
inconsistencies. These changes include: revising text to reflect !
current figure numbers in SAR; reflect single condensate storage ,
tank; include regenerant waste tanks in waste and floor drain i subsystem; adding clarification of filter operational flow rates.
8"==ary of Safety Evaluation:
The permanntly installed radwaste system is unaffected by this change anc. continues to meet the requirements of applicable codes and standards. There is no effect on the level of equipment qualification nor any reduction in regulatory requirements. Controls used to mitigate accident consequences are unchanged and the volume and isotopic composition contained in radwaste system components is not affected. No new accidents are created as there is no change in 49 i
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1 the manner in which equipment will f ail. Therefore, it has been determined that this change does not constitute an unreviewed safety 1 question. ,
1 Chance Na=her/USAR Section LCN 11.3-10a/ Figure 11.3-2a
/ Figure 11.3-2c Description and Basis for chanaat This modification added flushing connections with manual valves in the offgas treatment system (OGT) hydrogen analyzer sample lines. ,
This modification was implemented to enhance capability of flushing i sample lines and performing leak tests.
Sa---ev of Safety Evaluatient The OGT system is a nonsafety-related system and is not rec [uired for safe shutdown. In addition the safety, performance, operabality, and reliability of this system and the associated hydrogen analyzers have .
not been compromised as a result of this modification. Therefore, it ,
has boon concluded that this change does not constitute an unreviewed safety question.
Chance Mu=her/USAR Section LCN 11.4-4a / Figure 9.4-3b
/ Figure 11.4-la peggriotion a h sis for chanas This modification installed a dry waste compactor in the radwaste building to allow for compaction and volume reduction of clry active waste using 52 or 55 gallon drums. Volume of waste may be reduced further using on-site or off-site supercompacter. This waste compactor is required in accordance with general design requirements of 10 CFR but the drum size modification has no safety impact.
Summary of Safety Evaluation:
The install" tion of a different size waste compactor does not impact the safety, performance, operability, or reliability of this system.
The compactor is not specifically addressed in the technical 1 specifications, and the drum size modification does not impact the margin of safety of any interfacing safety-related system as defined in the technical specifications. Therefore, it has been concluded that this change does not constitute an unreviewed safety question.
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i chance Na=her/Usha sections LCN 12.3-9 / Table 12.3-1 (pg 1 of 4) ]
/ Table 12.3-1 (pg 2 of 4) r
/ Table 12.3-1 (pg 3 of 4) ;
i
/ Table 12.3-1 (pg 4 of 4)
/ Figure 12.3-6
/ Figure 12.3-7 Description and Basis for chanaat This change revised the guidance for setting setpoints on area radiation monitors by radiation protection personnel by taking into account radiation zones,persont.al occupancy, plant operating mode and ,
other considerations rather than the upper radiation zone only. This .
change also reflected relocation of two radiation monitors in the t fuel building and the auxiliary building. ,
sn-==ry of safetv..Evaluationt Relocation of the area radiation monitors and allowing radiation protection personnel to determine setpoints of nonsafety-related, non-technical specification area radiation monitors will not effect the probability of any previously evaluated accident. Nor will any i consequences of any previously evaluated accident be increased.
These monitors will retain all original design features. Features ensuring that a monitor f ailure will have no effect on any other monitor are still in place. No margin of safety as defined in the basis of a technical specification is reduced because this change does not effect any monitors which are safety-related or are governed by technical specifications.
- Change... Number /USAR sections LCN 13.1-22 /Page 13.1-1 l
/Page 13.1-11 l
/Page 13.1-vi
/Pages 13.1-13 thru 13.1-27
/ Figure 13.1-1
/ Figure 13.1-la l i
/ Figure 13.1-2
/ Figure 13.1-2b l
/ Figure 13.1-2c
/ Figure 13.1-3
/ Figure 13.1-4
/ Figure 13.1-6
/ Figure 13.1-7 I
Description and basis for qhggggt i
This change to the USAR was made to revise Chapter 13.1 to reflect the current organizational structure at River Bond Station. This ,
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l I total chapter revision was required to report the results of a reorganization within the River Bend Nuclear Group.
sa-- ry of safety Evaluation:
This change reflects changes in personnel responsibilities and organizational structure and as such does not increase the probability of a previously evaluated accident. The probability of a new accident or malfunction of any safety-related equipment is not increased by this administrative change. No systems with any impact on safety-related equipment are effected by this change. Management structure is not addressed in the technical specifications, therefore
, the margin of safety is not reduced. Therefore it has been concluded that this change does not create an unreviewed cafety question.
Change Number /UshR section: LCN 13.2-4 /Page.13.2-1
/Page 13.2-13
/Page 13.2-14
/Page 13.2-19
/ Figure 13.2-1 DAR.cription and Basis for chance:
This change was made to the Training section of the USAR to reflect the status of full membership of the RBS Training Department in the National Academy for Nuclear Training. Previously RBS was accorded only branch membership form the academy board. Also minor changes were made to describe more accurately the training programs which are in place at River Bend.
Su===ry of safety Evaluatignt This change was made in accordance with NRC policy statements cn acceptability of INPO accredited training programs in meeting regulatory requirements (NUREG 1262 and NRC Generic Letter 87-07).
The deletion of material in this section are a result of cancellation of training no longer required and the deletion of course descriptions which have been replaced by reference to INPO accredited courses. These changes have resulted in an improved program which will be directly manifested by the plant being operated and maintained by personnel with inproved training qualifications. No increase in any probability or consequence of an accident is postulated by this change. Nor is there any greater possibility of a malfunction of safety-related equipment created by this change.
Therefore, this change does not create an unreviewed safety question.
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I chance N"=her/UskR section LCN 13A.0-4 /Pages 13A-1 thru 100 Description and Basis for Chances This change revised USAR Appendix 13A to reflect current resumes of key personnel associated with River Bend Station. As a result of a major reorganization which took place on February 1, 1990, numerous position descriptions and responsibilities were modified. Because of this, Appendix 13A was completely rewritten and restructured to more accurately reflect the current key positions and the resumes of holders of these positions at River Bend Station. Also reflected were new qualifications to existing resumes, s"---ev of safety Rvaluation This change' reflects changes-in personnel and qualifications from management, technical support and operating organizations. It also reflects the enhancement of individual qualifications by documenting significant improvements in qualifications of existing resumes.
Since all personnel changes involve individuals who meet or exceed position requirements and qualifications outlined in the applicable industry standard no increase in the probability or the consequences of an accident is created. Therefore this change does not create an unreviewed safety question.
Chance N"=her/USkR sectient LCN 14.2-36 /Page 14.2-157 Description and Basis for Chances This change added a note to the startup test section of the USAR to clarify the results of startup test number 22 with reference to test exception number 17. The acceptance criteria for the variation in incremental regulation was not met, therefore this test exception was created. This change documents and explains the basis for closure of this test exception, s"--ary of safety Evaluationt The f ailure of a pressure regulator is bounded by analysis in the SAR and therefore does not it.arease either the probability of an accident nor the consequences of a previously evaluated accident. The subject pressure regulator is a nonsafety-related, category 2 instrument.
There are no technical specifications associated with this pressure regulator. Therefore it has been determined that ?.his change does not create an unreviewed safety question.
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1 ghgggg_ggahgIf_q3&R_pection LCN 15.6-2 /Page 15.6-4
/Page 15.6-14
/ Table 15.6-2 (pg 2 of 2)
/Tabl9 1o.6-4 (pg 1 of 1)
/ Table 15.7-2 (pg 2 of 2)
Description and Basis for chanaat This change revised the control room X/Q values and control room thyroid doses to reflect revision of main stream line (MSL) failure analysis. The new MSL' failure analysis is based on X/Q values resulting from releases from the turbine building whereas the previous values were based on releases from the main plant exhaust duct.
'8*--wy of Safety Evaluatient The probability of accidents previously evaluated in the USAR will not be increased because atmospheric dispersion is not a causative factor in the occurrence of such accidents. The consequences of.an accident previously evaluated in the USAR will not be increased because the control room thyroid dose due to LOCA remains the limiting thyroid dose. Since the exclusion area boundary. dose due to a main stream line (MSL) f ailure is unaffected by this change, there is no increase in the consequences to the public due to ., previously ;
evaluated accident. This change creates no increase in the probability of a malfunction of any safety-related system- or structure, not any increase in the consequences of any malfunction of a safety-related component or system. The control room radiological consequences of a postulated main stream line f ailure are not used as the basis for any technical specification. Therefore, it was concluded that this change does not constitute an unreviewed safety question. .
i Chance N"=her/USAR 8ection LCN 15A.0-1 /Page 15A-1 Descrintion and Basis for Chanaat This change revised the USAR to include a statement on the basis of the Nuclear Safety Operational Analysis (NSOA) to clarify its usage in the development of the technical specifications. This was done to explain an apparent conflict with the " Repair Time Rule" ao stated in the USAR in Section 15A.S.3.
8_n===ry of Safety Evaluationt l The NSOA was developed in the late 1960's as a basis for showing compliance with the General Design criteria and to assure safety 54
design adequacy and consistency. The NSOA identifies on a generic system level basis those systems which should be the subject of technical specifications and the safety systems required to be operable during different modes of plant operation. The Repair Time Rule given in Section 15A.5.3 of the USAR was used as an assumption in early reliability of the BWR ECCS systems and was not intended to direct or reflect individual plant practices or activities. This change reflects this information in the USAR to aid in resolving apparent conflicts between these two methodologies. This addition has no effect on any system design basis or function therefore the possibility or consequences of an accident previously evaluated in ,
the SAR is not increased. The margin of safety as defined in the i basis for any technical specification is not reduced because this is l only a clarification of information. The possibility of a new accident is not created by this change because no new equinmeim or operating conditions are postulated. Therefore this change has been determined to not reflect an,unreviewed safety question.
ChADQ8 N"=her/USAR section: LCN 17.2-28 /Page 17-1 '
/Page 17-11
/Page 17-111
/Page 17-iv
/Page 17-v
/Pages 17.2-1 thru 17.2-40
/Page 17.2-45
/Page 17.2-46
/Pages 17.2-51 thru 17.2-54
/Pages 17.2-57 thru 17.2-64
/Page 17.2-69
/Page 17.2-70
/Page 17.2-75
/Page 17.2-77
/Page 17.2-78
/ Table 17.2-1 (pg 1 L' 6)
/ Table 17.2-1 (pg 3 of 6)
/ Table'17.2-2 (pg 1 of 5)
/ Table 17.2-2 (pg 2 of 5)
/ Table 17.2-2 (pg 3 of 5)
/ Table 17.2-2 (pg 4 of 5)
Description and Basis for Chancet This change was made to reflect organizational changes to section 17.2 of the Updated Safety Analysis Report. These organizational changes took effect February 1, 1990. Also descriptions from the.
construction phase of the Quality Assurance Program were deleted as these are no longer applicable to the operational phase QA Program.
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l c . .. 6 Summary of Safety Evaluation:
This change has no effect on the operation of safety-related systems or equipment, therefore the probability of a malfunction of safety-related equipment or an accident previously evaluated is not increased. No margin of. safety as defined in any technical specification is decreased by this change because only organizational changes have occurred. This change has been determined not to reduce the effectiveness of the QA Program nor does it reduce any commitments of the QA Program as previously approved by the NRC.
Therefore this change has been determined not to constitute an unreviewed safety question.
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