SVP-99-102, Summary Rept of Changes,Tests & Experiments Completed, Covering Period 990201-0430. with

Summary Rept of Changes,Tests & Experiments Completed, Covering Period 990201-0430. with

ML20209B479
Person / Time
Site:	Quad Cities
Issue date:	04/30/1999
From:	Dimmette J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
SVP-99-102, NUDOCS 9907070125
Download: ML20209B479 (58)

Text

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, Comumnwcann rdm,n Conyuny Quad Citics Generating Station s' 2r10 206th Asenue North .

Cordova. II. 61212 9" no 1 f Tei.w 6s w2n June 25,1999 SVP-99-102 l

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D C 20555 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 l

Subject:

Summary Report of Changes, Tests, and Experiments Completed in accordance with 10 CFR 50.59 and 10 CFR 50.71(e), we are forwarding Quad Cities Nuclear Power Station's Quarterly Summary Safety Evaluation Report. These safety evaluations cover the period of February 1,1999 through April 30,1999.

Should you have any questions concerning this letter, please contact Mr. W. J. Beck, at (309) 654-2241, extension 3100.

Respec Ily l

Ca? ,

~.

J l P. Dimmette, Jr. I Site Vice President - k.

Quad Cities Nuclear Power Station E l i

Attachment:

Summary Report of Changes, Tests, and Experiments Completed cc: Regional Administrator-NRC Region lll NRC Senior Resident inspector - Quad Cities Nuclear Power Station j

-% A4 O 9907070125 990430 PDR R ADOCK 05000254 PDR  !

A llmcom Conyuny

, SAFETY EVALUATION INDEX E04-1-93-101 SS-H-98-0161 SS-H-99-0006

. SE-97-I l4 SS-H-99-0008 SE-97-118 SS-H-99-0010 SE-97-119 SS-H-99-0022

. SE-97-120 SS-H-99-0029 SE-98-072 SS-H-99-0035 SE-98-085 SS-H-99-0037 SE-98-088 SS-H-99-0038 SE-98-097 SS-H-99-0044 SE-98-099 SS-H-99-0045 SE-98-100 SS-H-99-0047 SE-98-101 SS-H-99-0049 SE-98-109 SS-H-99-0054 SE-98-125 SS-H-99-0056 SE-98-167 SS-H-99-0059 SE-99-002 SS-H-99-0060 SE-99-005 SS-H-99-0063 )

- SE-99-008 SS-H-99-0065 SE-99-009 SS-H-99-0066 SE-99-010 SS-H-99-0067 i SE-99-014 SS-H-99-0078 SE-99-015 SS-H-99-0079 SE-99-016 SS-H-99-0080 SE-99-018 SS-H-99-0084 SE-99-021 SS-H-99-0085 SE-99-023 SS-H-99-0086 SE-99-025 SS-H-99-0090 SE-99-033 SS-H-99-0091 SE-99-044 SS-H-99-0113 Attachment A, SVP-99-102, Page 1 of 57

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Tracking No. None (Unique Numbers Were Not Assigned Prior to 1997)

Activity No. DCP 9300065; E04-1-93-101 DESCRIPTION:

The sensing lines to the RHRSW cubicle cooler,1-5745-C, supply and discharge pressure )

indicators, PI l-1041-010C and 1-1041-011C, are experiencing pipe stress. This design change added supports to the associated sensing lines in order to reduce these stresses.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of )

equipment important to safety previously evaluated in the safety analysis report is not increased because the design change does not connect to and is not in close proximity to any high energy lines, and this results in no increased probability of an accident. All pipe supports that were added were seismically designed. The new support configuration

' reduces pipe stresses; therefore, the reliability of the IC RHRSW cubicle cooler will be increased. Since the reliability of the cubicle cooler is improved, the probability of an equipment malftmetion is less likely to occur and the consequences of an accident in which

- the room cooler needs to perform its cooling function is improved.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because all components added to the design are passive. There are no changes to any process parameters or system interaction.

The RHRSW cubicle coolers will function as designed; therefore, there is no possibility for creating an accident or malfunction different than has already been evaluated.

~3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because since the new design increases the reliability of the RHRSW system there is no reduction in the margin of safety. Technical Specifications require that each RHRSW pump j and cubicle cooler be operable in Modes 1,2, and 3, and when the control room HVAC f emergency train is required to be operable. This design change enhances the room cooler i such that this Technical Specification is still met. This design change provides greater assurance that the components will continue to perform their required function.

Tracking No. SE-97-114 Activity No. DCP 9700187

~ DESCRIPTION:

The DCP changes the time delay setpoint for relay 27XTD from 2 seconds to 3 +/- 0.15 seconds. If the time delay were to actuate below 2 seconds, then potential damage could occur to either the Diesel Generator or ECCS pumps.

Attachment A, SVP-99-102, Page 2 of 57 i

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the censequences of an acci&, m a alfunction of

! equipment important to safety previous!y evaluated in the E n r . .- 1 's Report is not l increased because the setpoint will not interfere with tbc reqd.s.. fn;; time of the diesel.

The worst case delay is still within the crieria for the DG sutc+ nenergization of the emergency bus of10 seconds.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the setpoint is enveloped by the time for the diesel getting up to rated speed and rated voltage permissive contact closures. The change is to incorporate instrument uncertainties and does not impact the EDG or 4160 volt systems or functions.-

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the increase in time for the time delay relay for the breaker does not affect the 10 i

second closure time of the breaker.

l l

Trackin; No. SE-97-118 Activity No. DCP 9600384 DESCRIPTION:

This DCP will replace the currently installed Penn pressure switch PS 1/2-4641-43A, used to start and stop the Unit 1/2 Diesel Generator 1/2A Starting Air Compressor, with a new pressure switch

' manufactured by Static-O-Ring (SOR) used in conjunction with a new unloading solenoid valve.

In addition, the sensing tap for the pressure switch will be rotated up from its current bottom orientation on the process piping. In order to implement this change, a control cable between the DG Aux Control Panel and the new solenoid valve will be installed.

SAFETY EVALUATION

SUMMARY

l 1. The probability of occurrence or the consequences of an accident or a malfunction of

! equipment important to safety previously evaluated in the Safety Analysis Report is not increased because the new SOR switch is safety-related and seismically qualified. This

, . provides a high level of confidence that the new switch will not malfunction, thus maintaining the required pressure boundary. The currently installed copper tubing wil! be replaced with stainless steel tubing. The installation of the new SOR pressure switch and the associated tubing and instrument tap has been evaluated per calculations QDC-4600-M-0428 and QDC-4600-S-0237. Because of the similarity in the design function and

, perfonnance, the consequences of a malfunction of equipment important to safety will not be increased.

l.

Attachment A, SVP-99-102, Page 3 of 57 l

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2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the equipment changed by this DCP is associated only with the Diesel Generator Starting Air System. The result of a failure of this equipment is limited to the failure of the Diesel Generator to start when needed. This failure has been previously analyzed and is discussed in section 8.3.1.6.4 of the UFSAR. For this reason, the proposed change does not create the possibility of an accident or malfunction of a different type than has been previously evaluated in the SAR.

1

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.

I i

Tracking No. SE-97-119 {

Activity No. DCP 9700029 DESCRIPTION:

This DCP will replace the currently installed Penn pressure switch PS 1/2-4641-43B, used to start and stop the Unit 1/2 Diesel Generator 1/2B Starting Air Compressor, with a new pressure switch manufactured by Static-O-Ring (SOR) used in conjunction with a new unloading solenoid valve.

In addition, the sensing tap for the pressure switch will be rotated up from its current bottom orientation on the process piping. In order to implement this change, a control cable between the DG Aux Control Panel and the new solenoid valve will be installed.

SAFETY EVALUATION SUMM ARY:

1. The probability of occurrence or the consequences of an accident or a malfunction of l equipment important to safety previously evaluated in the Safety Analysis Report is not I increased because the new SOR switch is safety-related and seismically qualified. This provides a high level of confidence that the new switch will not malfunction, thus maintaining the required pressure boundary. The currently installed copper tubing will be replaced with stainless steel tubing. The installation of the new SOR pressure switch and the associated tubing anc istrument tap has been evaluated per calculations QDC-4600-M-0428 and QDC-4600-S-0237. The existing switch is obsolete and difficult to obtain, when necessary. Because of the similarity in the design function and performance, the consequences of a malfunction of equipment important to safety will not be increased.

' 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the equipment changed by this DCP is associated only with the Diesel Generator Starting Air System. The result of a failure of this equipment is limited to the failure of the Diesel Generator to start when needed. This failure has been previously analyzed and is discussed in section 8.3.1.6.4 of the UFSAR. For this reason, the pro' posed change does not create the possibility of an accident or malfhnetion of a different type than has been previously evaluated in the S AR.

Attachment A, SVP-99-102, Page 4 of 57 J

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Techmeal Specifications are based.

Tracking No. SE-97-120 Activity No. DCP 9700276 DESCRIPTION:

On July 18,199_7 Problem Identification Form (PIF) Q1997-02921 identified that the presently installed overload relay heater elements that protect the 2B RHRSW Cubicle Cooling Fan C Motor do not provide sufficient margin during a reduced or degraded voltage condition. Further

. investigation has determined that all the RHRSW Vault Cooling Fan Motor's on Unit I and Unit 2 are equipped with the same size overload heater element. The above listed DCP has been initiated l to install properly sized elements that will adequately protect the associated motors and prevent erroneous trips.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malftmetion of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because the RHRSW cooling fans provide air flow across the coils for the RHRSW vault coolers. The RHRSW pumps are used to mitigate the consequences of accidents. The RHRSW pumps and cooling fans as well as the thermal overloads for the cooling fans do not cause or contribute to the cause of any accident or transient. Therefore, the probability of any of these accidents or transients is not increased. Installing the new heater elements decreases the chance of a nuisance trip of the RHRSW cooling fan motors during a reduced or degraded voltage condition. Therefore, the ability of the RHR system to perform its design function and mitigate the consequences during and/or after any accident or transient is improved.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the new overload heater elements are the same type of element as the old element. The likelihood of a failure and

]

failure modes of the new element are the same as the old heater element. A failure of the element may cause the associated fan motor to malfunction so that the affected room cooler l would not operate properly and would not provide adequate cooling for the RHRSW pump j motor. This could ultimately cause a malfunction of the RHRSW pump motor and affect '

the ability of the RHR system to remove decay heat in a post accident condition. After the new elements are installed, a malfunction or failure would be identical to what is currently evaluated. Therefore, the installation of the new elements will not create the possibility of an accident or malfunction of a different type.

Attachment A, SVP-99-102, Page 5 of 57 I

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3. The margin of safety, as defined in the basis for any Technical Speciliation, is not reduced because the change does not affect any parameters upon which Technical Specifications are based.

There were no Unreviewed Safety Questions identified as a result of this evaluation. There are no changes to the UFSAR required.

Tracking No. SE-98-072 Activity No. UFSAR-97-R5-055 DESCRIPTION:

This evaluation addresses the following UFSAR changes:

a. Delete specific P&ID sheet numbers from seclions: 9.2.1.2,9.2.2.2,9.5.5,10.4.5.2 (P&ID references remain).

b. Change Figure 9.2-2 as follows to match as-built condition:

- Revise layout of Service Water supply to B Control Room HVAC Refrigerant Unit,

- Show correct type of valve on the outlet of the Off Gas Glycol Chillers, j

- Show Standby Coolant Supply MO valves as 'Normally Closed',

- Show Service Water supply to Fire Protection MO valve as 'Normally Closed'.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because the changes are unrelated to the events initiating analyzed accidents and transients; do not affect the reliability, flow, or heat capacity of the Service Water System; ,

and do not affect equipment required to function during analyzed accidents and transients. l Fission Product barriers and the equipment protecting them are unaffected by this change.

1

2. The possibility for an accident or malfunction of a different type than any evalua+ed previously in the Safety Analysis Report is not created because the proposed changes do not affect the function or failure inodes of the components involved under either normal or accident conditions. Since functions and failure modes are unchanged there is no potential for a previously unanalyzed condition to be created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the changes do not affect parameters upon which Technical Specification or UFSAR limitations are based.- No accident probabilities or consequences are affected.

4 Attachment A, SVP-99-102, Page 6 of 57

Tracking No. SE-98-085 Activity No. UFSAR-97-R5-060 DESCRIPTION:

This safety evaluation is for the addition of detailed information to UFSAR Table 8.3-1 (Sheet 1 of 5), there are no physical changes to the transformers or the plant electrical distribution system.

This change includes the 65 degree Celsius rise Winding Ratings for the Unit Auxiliary Transformers (UATs) and the Reserve Auxiliary Transformers (RATS). These transformer

. winding ratings are currently shown on Single Line Diagrams 4E-1301 Sht.1 (Rev. AF) and 4E-

'2301 Sht.1 (Rev. AA). The impedance ratings for Transformer TR-12 (RAT) will also be added to UFSAR Table 8.3-1 (Sheet 1 of 5).

S AFETY EVALUATION

SUMMARY

1. The probability of occurrence at the cor: sequences of an accident or a malfunction of equipment important to safety preMously evaluatd in the safety analysis report is not increased because the loss of normal AC power would generally be caused by large grid disturbances which in turn would de-energize buses that supply power to auxiliary equipment.-

The probability of a Loss of Auxiliary Power, Loss of Offsite AC Power or Loss of Normal AC Power will not be increased by this revision to UFSAR Table 8.3-1 (Sheet 1 of 5).

There are no physical changes being made to the transformers or the plant electrical distribution system. The addition of detailed infonnation about the existing UATs and RATS does not affect the transformer failure rate.

This change to UFSAR Table 8.3-1 (Sheet 1 of 5) does not change the system configuration or the control logic of the auxiliary power system. The auxiliary power system will function the same to mitigate the consequences of any accident or transient after this change to the UFSAR.

This change to UFSAR Table 8.3-1 (Sheet 1 of 5) will not impact the probability of a malfunction of equipment important to safety. The scope of this activity is limited to the

- revision of UFSAR Table 8.3-1 (Sheet 1 of 5) to include the 65 degrees Celsius rise Winding Ratings for the Unit Auxiliary Transformers (UATs) and the Reserve Auxiliary  ;

- Transformers (RATS). The impedance ratings for Transformer TR-12 (RAT) will also be added to UFSAR Table 8.3-1 (Sheet 1 of 5). There are no physical changes being made to the transformers or the plant electrical distribution system. This change to the UFSAR will not affect plant operation since the function of the UAT and RAT is not changed.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the scope of this activity is limited to the revision of UFSAR Table 8.3-1 (Sheet 1 of 5) to include the 65 degrees Celsius rise Winding Ratings for the Unit Auxiliary Transformers (UATs) and the Reserve Auxiliary Trr.nsfom;ers (RATS). The impedance ratings for Transformer TR-12 (RAT)

Attachment A, SVP-99-102, Page 7 of 57

will also be added to UFSAR Table 8.3-1 (Sheet 1 of 5). There are no physical changes being made to the transformers or the plant electrical distribution system. This change to I the UFSAR will not affect plant operation; therefore, no accidents or malfunctions of a different type are created. . The addition of detailed information about the existing UAT's j

and RAT's does not affect the transformer failure rate. 1 l

c3. The margin of safety, as defined in the basis for my Technical Specification, is not reduced l because this revision of UFSAR Table 8.3-1 does not affect any parameters upon which Technical Specifications are based; therefore, there is no reduction in the margin of safety, i Tracking No. SE-98-088 Activity No. DCP 9800228 DESCRIPTION:

Remove existing electro-pneumatic time delay relay and install new model electro-mechanical time delay relay.The new relay will be installed in a new panel and a new control cable will be routed from new panel to existing engine control panel.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because this relay does not affect an initiating event for any accident. The new relay performs in the same manner as the existing relay. The new relay has been qualified for the environment it will be installed in. The new relay has a much tighter accuracy than the existing relay. The replacement relays duty cycle requirements are the same as the existing relay. The replacement relay has the same basic architecture as the existing relay.

The new relay does not utilize software. The new relay has the same human-machine interface as the existing relay.  ;

This change involves an analog to digital conversion. 5!PRI " Guideline on Licensing Digital Upgrades" (EPRI TR-102348) was reviewehnd addiessed in this Safety  ;

Evaluation.

2. The possibility' for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the replacement relay will perform in the same manner as the existing relay. It will exhibit the same failure characteristics as the existing relay.

3. The margin of safety, as described in the basis for any Technical Specification, is not reduced because this change does not affect any parameters upon which Technical Specifications are based.

Attachment .s, SVP-99-102, Page 8 of 57

l Tracking No. SE-98-097 Activity No. DCP 9700270 DESCRIPTION:

A modification will be perfonned on both Units to install a manual bypass switch in the Power-Load Unbalance Trip Test circuit and another manual bypass switch in the Backup Overspeed Turbine Trip circuit.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because new components are being introduced to the Turbine Trip System. These components are designed to meet the electrical requirements of the system. As such, they pose no additionsl potential for failure above that incurred by the current components.

The nuclear industry has experienced numerous turbine trips due to failure of the pushbutton and time delay during turbine testing. This modification will add indicators that the circuit is bypassed prior to injection of a trip signal.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the accidents analyzed do not exceed any design parameters for the protection of the fuel or the protective boundaries.

As such it was not evaluated for radiological (off-site dose). Only these circuits were effected and the function of the circuits remains unchanged.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the number of Turbine Trip Transients is limited due to fatigue of the Reactor Coolant Pressure Boundary. These changes make spurious transients less likely. Therefore, the margin of safety is not reduced.

Tracking No.' SE-98-099 Activity No. DCP 9700367 DESCRIPTION:

The Unit 1 Main Turbine trip control logic is being modified by including a spare voltage comparator (VC2-A15) in the circuitry of the EHC panel that will bypass the automatic high temperature trip function of the Low Pressure Turbine Exhaust Hood, when operatmg at or above 30% turbine / generator power. This design change will retain the automatic high temperature trip function at 225 F when operating below 30% turbine / generator power, but will require Operator intervention to manually trip the Main Turbine if high temperature is reached at or above the 30%

. power level.

~ Attachment A, SVP-99-102, Page 9 of 57

m l

l l SAFETY EVALUATION

SUMMARY

1

1. The probability of~ occurrence or the consequences of an accident or a malfunction of i equipment important to safety previously evaluated in the Safety Analysis Report is not increased because:-

Turbine Missiles Transient:

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Of concern is the potential for damaging the turbine by overheating and causing harmful distortions or clearances of the last stage Low Pressure (LP) Turbine buckets such that rubbing to the casing or improper bearing loading could occur. High temperature conditions within the LP turbine exhaust hood are detected by temperature sensors which signal the Control Room via high temperature alarms. Operators are then directed to take actions to protect the turbine by the annunciator procedures prior to turbine damege.

Therefore, the probability of a missile hazard being produced is not increased.

A turbine missile event from a failure of a turbine trip due to high LP Turbine Exhaust Hood Temperature does not have any consequences related to off-site dose because the UFS AR states that the low-pressure rotors do not pose a missile hazard to the primary containment system.

Turbine Trio Transient:

The reduction'of Turbine Trips caused by false actuation of LP Turbine High Temperature l circuit is the objective of the Modification, with the ultimate goal of reducing potential reactor scrams.

. The addition of a new contact (which is open above 30% power) is in series with the existing high temperature trip contact that closes to give a turbine trip. To produce a turbine trip, both contacts would have to fail closed. Failure of both contacts in the closed position is a low probability and outweighed by the reduced probability of a spurious turbine trip at i high power as a result of the change. Therefore, the possibility of this failure is not 1 increased.

The turbine trip does not have any consequences that are directly related to off-site dose.

One of the most significant consequences of the turbine trip is the reactor scram, which is

' designed to minimize the release of effluent to off-site. Since this modification does not alter any system or component designed to mitigate the consequences of the turbine trip (such as reactor scram), consequences of the turbine trip will remain unaffected after installation of the new components.

2. The possibility for an accident or malfunction of a different type than any evaluated j previously in the Safety Aralysis Report is not created because the turbine trip logic will be i changed from 'always trip on High LP Turbine Temperature' to 'only trip on high temperature below 30% load'. This increases the probability that the automatic turbine trip Attachment A, SVP-99-102, Page 10 of 57 l

L will not be initiated on the actual High LP Turbine Temperature, although this failure mechanism is not new (as the existing trip circuit contact may fail to close). However, the probability 8his occurrence is small, because the wiring and contact used meet the electrical duga requirements of the Turbine Trip System, and the new components will be adequately tested to ensure intended turbine trip function. Furthermore, the duration that the turbine is operated at less than 30% is very short as compared to the time the turbine is operated above 30% power. In addition, if a high temperature condition is created in the LP Turbine, Hood Sprays automatically initiate to cool the LP Turbine. Finally, the condition is annunciated in the main control room. Quad Cities annunciator procedure (QOA 900-7, C-4), which currently provides actions to protect the turbine, is being revised as part of the design change to trip the turbine on high exhaust hood temperature above 30%

turbine / generator power.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the turbine trips from equipment failures are reduced by this proposed change. A

- reduction of the number of turbine trips will resu?t in reduced cycles on the vessel. The reactor coolant pressure safety limits are not impa:ted by the elimination of unnecessary turbine trip transients and reactor scrams. Therefoe, the margin of safety has not been reduced.

Tracking No. SE-98-100 l Activity No. DCP 9700346 DfSCRIPTION:

l The logic for the turbine trip due to low EHC pressure will be changed. The existing trip logic is

! one-out-of-one (i.e. if pressure switch 1(2)-5650-101 fails, the turbine will trip). The trip logic will l be changed to two-out-of-two once by adding an identical pressure switch in series with the l existing pressure switch. A 3-second time delay relay contact will also be added in series with the pressure switch contacts to mitigate the potential of a turbine trip due to a momentary pressure fluctuation. The installation and testing of the components will be performed in accordance with Quad Cities Station approved procedures.

l This DCP only affects the turbine trip logic. The Safety-Related EHC Low Pressure Scran, Turbine Stop Valve Closure Scram, and the Turbine Control Valve Fast Closure Scram instrumentation and the associated Reactor Protection System (RPS) logic are not affected by this DCP.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because a turbine trip (with and without bypass) is addressed in UFSAR sections 15.2.3.1 and 15.2.3.2. This modification will not increase the probability of either event.

The existing trip logic is one-out-of-one. The modified logic will require a low EHC l Attachment A, SVP-9.9-102, Page 11 of 57 l

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pressure signal (1100 psig decreasing) to be present for 3 seconds on both pressure switches before initiating a turbine trip. Ifit is postulated that both the second (new) pressure switch and the time delay relay contacts associated with the turbine trip failed closed, a trip signal would not be generated unless the existing pressure switch had also failed closed. This modification will not impact the potential failure of the existing pressure switch. Therefore, the probability of a spurious turbine trip will not increase when this change is implemented.

The probability of a turbine trip due to a short circuit of the new components installed by this DCP is considered insignificant when compared to the reliability gained by the elimination of a turbine trip caused by a more likely event such as instrument setpoint' drift or a momentary pressure fluctuation.

2. _ The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because the component additions and logic changes made by this modification are contained within the EHC system and the associated turbine trip logic. In the unlikely event the new components fail to operate properly, two events could occur:

a. The turbine could trip spuriously. This would cause the reactor pressure to increase.

This event is analyzed in UFSAR Section 15.2.3. Mitigation of the event is unaffected by this design change.

b. The turbine could fail to trip at under a low (1100 psig) EHC pressure condition. There are several other turbine trip signals which wouid trip the turbine. The potential for this event already exists with the present logic [i.e. PS 1(2)-5650-101 contact fails to close]

and the results of such an event are unaffected. The failure of the turbine to trip on low EHC pressure is not safety significant with respect to potential impact on the reactor core and is not specifically evaluated in the SAR. Decreasing EHC pressure will eventually result in closure of the turbine stop and control valves. Even if the low EHC pressure trip logic failed, the scram functions designed to protect the reactor from turbine valve closure would be unaffected.

Based on the above discussion, no new accidents or malfunctions are introduced that have not been previously evaluated.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based; therefore, there is no reduction in the margin of safety.

Attachment A, SVP-99-102, Page 12 of 57

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1 Tracking No. SE-98-101 Activity No. FPR Change Package 98-07 l

DESCRIPTION:

The change to the Safe Shutdown Analysis (SSA) removes a sentence contained in a note to Table 1.2-1 and adds information desenbing three modifications completed for Appendix R. The sentence removed from the note in Table 1.2-1 is " Generic Letter 86-10, Supplement 1, is not part of this acceptance criteria since Quad Cities does not use any thermo lag fire wrap material." The I

modifications completed were to the Reactor Core Isolation Cooling (RCIC) Condensate Pump Level Switch, Residual Heat Removal (RHR) Room Cooler Fans, and the Core Spray Room Cooler j Control Circuit. Information describing the modifications will be added to section 3.4 of the SSA. 1 SAFETY EVALUATION

SUMMARY

! 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because plant operation will not be affected by the changes identified. The Fire Protection System is not affected by the change to the SSA. The fire wrap material installed within the plant will function as designed since no change has been made to any fire wrap material. The chans provides clarifying information to more clearly define the analysis.

The RCIC Condensate Level Switch, RHR Room Cooler Fans, and the Core Spray Room Cooler Control Circuit will function as designed.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change to the SSA does not create the possibility of an accident or malfunction of a type different from those evaluated in the SAR. The equipment and its operation remain the same as identified within the SFA. The removal of the statement about Generic Letter 86-10, Supplement 1, does not impact any system or function. Quad Cities does not have thermo lag fire wrap material installed at the plant and the requirements of the Generic Letter deal with the documentation requirements for fire wrap material. The statement was removed to prevent confusion in the interpretation of the requirements for documentation. Addition of modification descriptions to the SSA does not impact the possibility of any accident or malfunction ditTerent from the SAR. The modifications were evaluated under separate 10 CFR 50.59's.

3. The margin of safety, as defmed in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based; therefore, there is no reduction in the margin of safety.

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Attachment A, SVP-99-102, Page 13 of 57

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Tracking No. SE-98-109 Tracking No. NSP-CC-3010 Rev. 0; UFSAR-97-R5-079 DESCRIPTION:

There are two activities that are to be addressed under this Safety Evaluation. The first is to evaluate the implementation of procedure NSP-CC-3010 Rev. O for Station use. The second is to evaluate the change associated with UFSAR section 13.5.1.3.3 to address the use of the NSP for the change control processing of Setpoint/ Scaling change requests (SSCRs). The attached QCAP 2300-05, Appendix A (Tracking Control # UFSAR-97-R5-079) form describes the editorial change to be made to the second sentence of section 13.5.1.3.3. The change in no way is intended to change the intent of the sentence but to include the addition of the new NSPs. l SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report is not increased because there is no specific system or equipment directly impacted by the implementation of NSP-CC-3010 Rev. O, as described in the UFSAR. Thus, there are no new equipment failures introduced during normal or accident conditions by the implementation of the NSP. Therefore, the probability of occurrence and the consequences of any accident are not impacted.

The clarification associated with section 13.5.1.3.3 in no way changes system or plant operation as described in the UFSAR. Therefore, the probability of occurrence and the consequences of any accident are not impacted

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created because there is no specific system or equipment directly impacted by the implementation of NSP-CC-3010 Rev. O, as described in the UFSAR. Therefore, there is no possibility of a different type of accident or malfunction.

The clarification associated with section 13.5.1.3.3 in no way changes system or plant operation as described in the UFSAR. Therefore, no different accident or malfunction is introduced.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced i because there is no specific system or equipment directly' impacted by the implementation  !'

of NSP-CC-3010 Rev.0, as described in the Technical Specification. Therefore, there is no possibility of a change in the margin of safety. In addition, the clarification associated with section 13.5.1.3.3 in no way changes Technical Specifications. Thus, the margin of safety is not impacted at all.

Attachment A, SVP-99-102, Page 14 of 57 l

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L Tracking No. SE-98-125 Activity No. DCP 9800271 DESCRIPTION:

Modify Main Turbine trip logic to reduce unnecessary scrams.

l l SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because reduction of turbine trips caused by false actuation is the objective of this modification, with the ultimate goal of reducing reactor scrams. By placing two contacts in parallel, the probability of a false activation of a Turbine Trip is reduced. Since the failure mechanism of oxidized contacts from arcing on opening and closing is reduced by this configuration.

The Turbine Trip does not have any consequences that are directly related to the off-site dose. One of the most significant consequences of a Turbine Trip is the Reactor SCRAM, which is designed to minimize the release of effluent off-site. Since this modification does not alter any system or component that is designed to mitigate the consequences of the Turbine Trip (such as Reactor SCRAM), consequences of the Turbine Trip will remain 1

unaffected after connection of the new contact.

, 2. The possibility for an accident or malfunction of a different type than any evaluated l previously in the safety analysis report is not created because components being installed and control logic change being initiated by this modification are all within the Turbine Trip logic. Failure modes for these changes have been addressed and found to be within the boundaries of the existing Turbine Trip components. Although adequate testing will be performed to ensure reliability in the unlikely event that the new contact fails to function properly, a Turbine Trip may or may not occur, which is an analyzed condition. Therefore, no new accidents are being introduced by this modification that have not oeen previously analyzed.

l l 3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based; therefore, there is no reduction in the margin of safety.

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i Attachment A, SVP-99-102, Page 15 of 57 L

Tracking No. SE-98-167 Activity No. DCP 9800297 DESCRIPTION:

' Replace and Relocate Temperature Element TE 0-5795-317.

. SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because replacement or relocation of the temperature element cannot cause a LOCA. The element simply cycles the Refrigeration Control Unit (RCU) to provide cooling to the control room emergency zone when required. The probability of a LOCA will not increase.

The new temperature element is similar to the existing element in construction and function.

They both use a 100 ohm platinum Resistance Temperature Detector (RTD) to provide an input into the RCU control system. A failure of the new element would produce the same results (i.e. open circuit, short circuit) as the existing element. The change in location of the element from the wall of the control room to the exhaust duct also has no effect on consequences of a LOCA. Both the new and existing location of the element is in the control room. The chances of damage from a fire, missiles, etc. is the same at both locations. The occurrence or consequences of a LOCA remain the same.

1 2.- The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because as stated in the previous steps, the failure modes of the temperature element remain the same. The worst case scenario

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. would be loss of the RCU which would prevent the Control Room HVAC "B" Train system i from removing the required heat load from the control room emergency zone. This  ;

possibility, however, already exists with the current configuration. The temperature element and the new conduits will be supported such that they will not fall on any equipment important to safety during a seismic event. The possibility of a different type of malfunction of equipment important to safety than any previously evaluated remains the same.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because currently, the RCU control system is set to maintain the control room emergency zone between 70 and 80 degrees F. The Technical Specifications state the RCU must maintain the control room emergency zone below 95 degrees F. The replacement and

' relocation of this temperature element will not affect either of these settings. The margin of

- safety remains the same.

Attachment A, SVP-99-102, Page 16 of 57 i

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1 Tracking No. SE-99-002 Activity No. UFSAR-97-R5-107 DESCRIPTION:

Change the basis for the 125 and 250 Vdc battery 4-hour capacity as described in UFSAR sections 8.3.2.1,8.3.2.2 and Technical Specification Bases B 3/4.9.C to.be loss of offsite power plus a single active failure without taking credit for the battery chargers as opposed to a loss of all ac sources.

Removes the 8-hour discussion for operation of the 125 V and 250 V battery charger as described in UFSAR section 8.3.2.1 and 8.3.2.2 to provide agreement with the description of the chargers I given in the Technical Specification Bases. I Revises the stated configuration for the 125 Vdc battery charger input busses to be connected to  ;

one of several sources of power rather than any source of power. l S AFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because there is no change to the initiating events for any of the accidents discussed in the SAR. The proposed UFSAR change in battery capacity criteria is currently reflected as the basis for the battery sizing calculations. These calculations demonstrate that the batteries are appropriately sized to supply the required loads for a four hour duration following a LOCA with a LOOP and assuming a single active failure.

The design basis of the ECCS system is for a single failure concurrent with a LOOP. The change is to bring the UFSAR description for the 125 and 250 Vdc Battery systems in compliance with the single failure design basis. The failure modes have not changed. The time for a loss of a charger is not essential. The design basis during accident conditions is that no credit is taken for a battery charger. During normal operation the loads on the battery charger are low enough that upon a loss of a battery charger, the battery can operate for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The bases for the battery during normal operation is that if both chargers are lost, the battery can maintain loads for a certain period of time provided the DC system can be maintained within the required Technical Specification parameters. The eight hour limit for operation without a charger is ambiguous in that the batteries' parameters must be maintained for a loss of a charger in order to be available for a LOCA.

The stated configuration of"any source" for the power to the busses feeding the 125 Vdc chargers is incorrect. There are other sources of AC power available in the plant that cannot be connected to the battery charger (i.e. security diesel generator and 13.8 KV system). The 125 Vdc battery chargers cannot be physically connected to all plant AC sources. This change clarifies the connection capabilities to valid AC sources. The chargers are currently fed from class lE busses that are picked up by the EDG on a loss of power.

Attachment A, SVP-99-102, Page 17 of 57 i

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l 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the ability of the 125 Vdc and 250 Vdc batteries to perfomt their required function has not changed by the UFSAR change. As such, the relationship to the onsite power system is maintained. The current wording of a LOCA concurrent with a loss of all AC sources implies that both EDGs would l be unavailable during the event. The current wording in the UFSAR implies an accident l which has not been evaluated in the UFSAR accident analysis in that the wording seems to l reference a LOCA concurrent with a Station Blackout Event. This is inconsistent for the  !

l ECCS systems which have a single failure of one EDG. The change in wording clarifies the description of the sizing of the battery to provide consistency with the accidents and malfunctions evaluated in the SAR.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the acceptance criteria for the battery sizing as defined in the Technical Specification bases and UFSAR section 8.3 is that the battery is sized to provide a load

profile for four hours for a LOCA concurrent with a LOOP as well as the loads required for l safe shutdown on the other unit. This change is a clarification of the failure modes, not a l change in parameters which affect the Technical Specification limit.

Tracking No. SE-99-005 Activity No. DCP 9900001; UFSAR-97-R5-112 DESCRIPTION:

This activity will be to modify the control circuitry for the 1 A Fuel Pool Cooling Water Pump to alarm for a low discharge pressure condition only when the pump is running. The existing configuration for the low-pressure pump discharge alarm circuit is such that it alarms for any low discharge pressure condition as sensed by a pressure switch. This change will be performed by modifying the alarm logic circuit to have a breaker contact in series with the pressure switch contact.

l SAFETY EVALUATION

SUMMARY

l l 1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this change does not affect the initiating events of any accident in the UFSAR. Any new potential failures are already bounded by the existing design and do not result in a malfunction of equipment important to safety.

2. ' The possibility for an accident or malfunction of a different type than any evaluated  !

previously in the safety analysis report is not created because the operation of the fuel pool cooling water pump has not changed. The change to the alarm circuitry affects only the

- conditions that give the alarm. Any new types of failures will not result in a condition that has not already been analyzed.

Attachment A, SVP-99-102, Page 18 of 57

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications or safety functions are based. Therefore, there is no reducti .1 the margin of safety.

Tracking No. SE-99-008 Activity No. DCP 9700106 DESCRIPTION:

Install flex tubing cn the Electro-Hydraulic Control (EHC) FASTC and FCD lines. Install isolation valves on the FASTC line. These changes are being made to reduce vibration being transmitted from the Main Turbine Contro! valve to the EHC tubing, and provide improved isolation capability for the EHC FASTC and FCD lines.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment importa*1t to safety previously evaluated in the safety analysis report is not increased because the installation meets or exceeds the design requirement. The flexible hoses reduce vibration being transmitted from the Main Turbine Control valve to the EHC tubing. The isolation valves allow faster isolation of EHC leaks and reduce the consequences of an EHC leak.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because except for the installation of the manual valve, this is a change to the piping configuration. If the manual valve is required to isolate, the valve does not prevent safety features of the reactor protection system from operating and may reduce the probability of a turbine trip while maintaining the reactor in a safe condition within Technical Specification Limits.

3. TL margin of safety, as defined in the basis for any Technical Specification, is not reduced because Pressure Switches on the Control Valve (CV) provide the scram signal to the RPS system. Installation of this modification does not affect these pressure switches or isolate them from the CV actuator. All other changes are bounded by the design requirements.

Therefore, the margin of safety is not reduced by this change.  !

Attachment A, SVP-99-102, Page 19 of 57

e Tracking No. SE-99-009 i Activity No. UFSAR-97-R5-108 DESCRIPTION:

Revise UFSAR Section 6.2.5.2, Page 6.2-48, to accomplish the following:

(1) Delete the reference to Figure 6.2-39. The CAM System sample lines do no: penetrate the primary system; excess flow check valves are not required and are not appropriate for process sample lines which require flow. I (2) - Revise the third sentence at endnote 6.2-97 to specify that a check valve is installed in the retum discharge line for primary containment. This change correctly specifies a single s check valve in the return discharge line, and that the check valve serves a primary containment function.

(3) Add the statement: "In addition, a check valve is installed in each reagent and calibration gas line for primary containment." The check valve in each reagent and calibration gas line provides a primary containment isolation function in the event that a gas line should break.

These check valves, therefore, serve a critical design function that should be included in the UFSAR.

SAFETY EVALUATION

SUMMARY

1. . The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the CAM System is a containment air sampling system that is not connected to the primary coolant system. The primary coolant boundary is not affected by this change. The CAM System is initiated post-LOCA and does not provide leakage indication of drywell equipment as failure precursor information.

This change affects valves installed in containment air sample lines only, and therefore. has no effect on the source term for a LOCA. The CAM System is safety-related, and the pressure retaining portions of the CAM System were designed and installed to ASME Section III Division I. Each valve in the pressure retaining portion of the CAM System is tested regularly and its integrity verified with a Local Leak Rate Test (LLRT) in accordance with the station's In Service Testing (IST) Program. The consequences of a malfunction remain the same, which are leakage either through a 1" containment penetration line, or through a 1/2" sample line, if a sample line break or valve failure occur.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this change affects valves installed in the CAM System sampling lines only. The possibility of a sample line break exists, but no.new types of accidents are created. The possible malfunctions remain the same, which are sample line break and valve failure to close.

Attachment A, SVP-99-102,' Page 20 of 57

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there are no Technical Specifications applicable where the requirement, associated action items, associated surveillances, or bases may be affected.

Tracking No. SE-99-010 Activity No. QCTS 0300-06, Rev. 5 DESCRIPTION-Procedure QCTS 0300-06, Reactor Recirculation Pump and Valve Logic Test, was revised to provide manual manipulation of Residual Heat Removal (RHR) injection valves MO-1001-29A & -

29B, while ensuring that the PCI function for the valves remained intact. This required that the j Low Pressure Coolant Injection (LPCI) function associated with valves MO-1001-29A & -29B be disabled, and was accomplished via the installation of applicable logic system jumpers & blocks.

For short periods of time during the performance of the logic test, the recire pump suction and discharge valves are open, resulting in a bypass loop for shutdown cooling flow. This procedure revision also provides for placing the test on hold and closing either the recirc pump suction or discharge valve to eliminate bypass flow if shutdown cooling is required.

This procedure change facilitates the use of shutdown cooling during the performance of the logic  ;

test, and addresses the potential impact on shutdown cooling due to the bypass flow loop that will j occur through the recirc pump. The following additional changes were made. A prerequisite was .

added requiring verification that the Recirculation M-G Set scoop tubes have been reset, in order to l simulate the operating conditions needed to perfonn this logic test. A precaution regarding removal & reinstallation of relay covers was added, and steps requiring the installation of specific relay covers were moved to a more appropriate section of the test. This procedure revision also 4 makes various administrative and editorial changes.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of ,

equipment important to safety previously evaluated in the safety analysis report is not

' increased because this revision affects relay logic and valve position, but has no affect on the integrity of the primary coolant pressure boundary. This logic test is performed with the reactor in cold shutdown or refuel mode with the required redundancy in safety equipment available, such that the radiological source term associated with the accidents is not increased. Within the RHR logic circuitry, components will be bypassed or actuated using accepted maintenance practices, and the system will be returned to its design configuration upon test completion. Multiple equipment failures would have to occur in order for the consequences to increase due to valves MO-1001-29A & -29B either failing to close or having excessive closure time. The consequences of a malfunction of equipment important to safety remain the same.

Attachment A, SVP-99-102, Page 21 of 57

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2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this change performs actions to simulate signals for existing devices and does not produce any fundamental difference in how these systems and components interact with the rest of the plant.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the LPCI ECCS function and shutdown cooling are both available via manual realignment of valves, which meets the requirements of Technical Specifications 3.5.B l footnote a, and 3.6.P footnote a, respectively.

Tracking No. SE-99-014 >

Activity No. FPR Change 98-10 DESCRIPTION:

This change incorporates resolutions ofissues identified during the On-Site Review of the last revision to the Updated Fire Hazards' Analysis (UFHA). This includes additional rcferences, and more detailed description of some fire zones.

SAFETY EVALUATION

SUMMARY

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1. The probability of occurrence or the consequences of an accident or a malfunction of I equipment important to safety previously evaluated in the safety analysis report is not increased because the changes to the UFHA do not impact the combustible load or ignition sources in the plant; therefore, the probability of a fire has not changed. The changes do not impact safe shutdown of the plant; therefore, no change in the consequence.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the changes made to tne description of the plant are bounded by the current fire hazards analysis. The addition of the LTD building does not create any new type of fire scenario.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the fire protection program is not described in Technical Specifications. No physical changes have been made that would reduce the level of protection at the plant. j i

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l Attachment A, SVP-99-102, Page 22 of 57 i

l Tracking No. SE-99-015 Activity No. UFSAR-97-R5-119 DESCRIPTION:

l This 10 CFR 50.59 Safety Evaluation is for the r.ddition and removal of detailed information in UFSAR Section 8.2 (Offsite Power System) and Section 8.3 (Onsite Power Systems). There are no physical changes to the transformers, switchyard,4160-V Switchgear, Electrical Cable Installation or the plant electrical distribution system.

The effect of this revision to the UFSAR will be an improvement in the accuracy and clarity of the

mformation contained within the UFSAR.

i l SAFETY EVALUATION

SUMMARY

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1. _ The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the loss of normal AC power would generally be caused by large grid disturbances which in turn would de-energize buses that supply power to auxiliary  ;

equipment, i

The probability of a Loss of Auxiliary Power, Appendix R Fire, Loss of Offsite AC Power l or Loss of Normal AC Power will not be increased by this revision to UFSAR. There are no physical changes being made to the transformers, switchyard,4160-V Switchgear, Electrical Cable Installation'or the plant electrical distribution system. The addition of detailed information about the existing electric power system does not affect the system l failure rate.

l This change to the UFSAR does not change the system configuration or the control logic of the auxiliary power system. The auxiliary power system will function the same to mitigate the consequences of any accident or transient after this change to the UFSAR.

L These changes to the UFSAR will not impact the probability of a malfunction of equipment l important to safety. No physical changes to the plant will be made. The clarifications made to the UFSAR will show actual plant conditions and will not adversely affect equipment important to safety.

These changes to the UFSAR will not impact the consequences of a malfunction of equipment important to safety. The affected equipment will still be available to prevent or mitigate the consequences of an accident when necessary. This change to the UFSAR will not affect plant operation since the function of the electric power system is not changed.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the scope of this activity is limited to the revision of UFSAR as described in Step 8. There are no physical changes Attachment A, SVP-99-102, Page 23 of 57 L

4 being made to the transformers, switchyard,4160-V Switchgear, Electrical Cable Installation or the plant electrical distribution system. These changes will not affect the way the plant is operated or behaves. Therefore, no accidents or malfunctions of a different type are created. The addition ofdetailed information about the existing electric power system 1 does not affect the system failure rate. l l

There are no new failure modes created as a result of this change to the UFSAR. No l

physical changes to the plant will be made. These changes are for clarification and will have no effect on equipment failures or malfunctions. This change to the UFSAR will not affect plant operation since the function of the electric power system is not changed. ,

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3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this revision of the UFSAR does not affect any parameters upon which Technical )

Specifications are based; therefore, there is no reduction in the margin of safety.

Tracking No. SE-99-016.

Activity No. QCOS 0201-12, Rev. O  !

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DESCRIPTION:

QCOS 0201-12 is a new procedure which will be used during reactor startup to provide the necessary steps to perform repair / replacement pressure testing following non-welded replacement activities on ASME Section XI Class 1 piping components.

1 A significant aspect of this surveillance is that under specific conditions, the procedure permits certain required pressure tests to be performed when the reactor is critical and pressurization achieved by nuclear heat. The testing is performed in Mode 1 at a low reactor power level (210%

and <l5%). At this power level, reactor pressure can be increased to normal full power operating pressure using standard EHC Pressure Set controls.

The purpose of the procedure clearly states that the procedure is NOT to be used for the repair / replacement pressure testing of the RPV shell, RPV head, Control rod drive housing (s),

interior attachment welds to the RPV shell or head, or the requir.:d periodic pressure test performed at the completion of a refueling outage. The procedure is written to meet ASME Section XI testing requirements and conform with 10CFR50 Appendix G.The procedure includes specific limitations on the scope ofinspections that may be performed under this procedure to assure that ASME Code and 10CFR50 Appendix G requirements are met.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the performance of QCOS 0201 12 Rev. 0 will not increase the probability of a LOCA. The structural integrity of the repaired or replaced Section XI Class I components is assured because these repair or replacements are controlled activities.

i Attachment A, SVP-99-102, Page 24 of 57

Operating Procedures states that, A system leakage test at operating pressure is performed on the primary system following each removal and replacement of the RPV head. The system is checked for leaks and abnormal conditions which are then corrected before reactor startup. This specific prohibition is included in the procedure.

QCOS 0201-12, Class One ASME Section XI Post-Replacement Leak Test at Power Operation, Revision 0 is NOT a one-of-a kind test or experiment used to measure the effectiveness of new techniques or a new system configuration that can affect systems important to safety. Rather this procedure describes the methodology to ensure components are tested in accordance with approved Codes and Standards.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because Technical Specification 4.0.E requires that inservice Inspection be performed in accordance with ASME Section XI and applicable Addenda as required by 10CFR50.55a  ;

(Except where relief has been provided in writing by the Commission). This procedure j satisfies the applicable ASME Section XI,10CFR50.55a and 10CFR50 Appendix G i requirements.

Tracking No. SE-99-018 i Activity No. QCMM 5100-04 DESCRIPTION:

This procedure provides instruction for installation, start-up, operation, shutdown, and removal of a i temporary oil purification unit on the Main Turbine lube oil reservoir.

SAFETY EVALUATION SUMM ARY:

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1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the change potentially impacts the Turbine Trip, Loss of Service Water, and Appendix R Fire, but has no impact on equipment important to safety. The potential for occurrence of the above events is minimized by the design of the ir allation, the short time ofinstallation, and the procedural controls implemented by the ge @!g procedure.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change installs a standard component to use proven technology. Similar components are already installed in the system add the failure of the components installed by the change would have similar impacts upon the system and the plant.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change and the system it is installed on have no safety design basis and have no impact on the margin of safety as discussed in the basis to plant Technical Specifications. l Attachment A, SVP-99-102, Page 26 of 57

r I Installation is controlled by an approved work package which meets the stringent repair / replacement rules of ASME Section XI. The instructions contain appropriate detail to assure proper installation. Any new bolting materials used are required to be visually inspected prior to installation by ASME Section XI. These processes are designed to ensure quality work and the installation of the proper components. In the case of Class 1 Safety Valves, the valves are bench tested prior to installation to ensure proper operation and to i verify proper relief setting. Collectively, the process results in a high degree of confidence that the pressure boundary is intact and will perform as designed.  !

The perfonnance of this procedure following the repair / replacement provides additional assurance that the repaired / replaced components will perform as required.

10CFR50 Appendix G specifically requires that pressure tests and leak tests of the reactor vessel required by Section XI of the ASME Code must be completed before that core is j' critical. The testing performed by QCOS 0201-12 Rev. O is limited to those components i

beyond the reactor vessel boundary. The procedure contains specific restrictions to ensure this requirement is satisfied.

l The radiological consequences of a LOCA during the performance of QCOS 0201-12 are bounded by the existing large break analysis. Initial reactor power during this test is 210%

to <l5% of rated power which further reduces any adverse radiological consequences in the event of a LOCA. The ECCS systems used to mitigate the effects of a LOCA arc not affected by this surveillance.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the performance of QCOS 0201-12 Rev 0 does not place the reactor in a condition that deviates significantly from normal operating conditions. Since the actual inspection is non-obtrusive, an accident or transient of a different type than previously evaluated is not created.

The acceptability of performing this limited scope inspection with the reactor critical warrants additional discussion. QCOS 0201-12 Rev. O is based upon Comed BWR policy document DG99-000135 dated 2/19/99 that was researched specifically to support this limited scope pressure testing using nuclear heat. The referenced SAR documents describe l Quad Cities Station's commitment to Appendix G and ASME Section XI. This procedure i and its stated / explicit limitations fully reflect those commitments.

l The procedure is crafted to mirror and not affect the SAR. The procedur'e describes the two types of pressure tests (periodic & repair / replacement) and demonstrates how the 10 CFR 50 Appendix G prohibition against using nuclear heat does not apply to non-welded and ,

non-RPV-related repairs / replacement testing, as long as the Class 1 periodic pressure tests l- required by B-P of ASME Section XI, required at the completion of a refueling outage, is satisfied.

The SAR does not specifically address a Code pressure test for bolted replacements, EXCEPT for the removal and replacement of the reactor head. UFSAR Section 5.3.2.2 l

l L Attachment A, SVP-99-102, Page 25 of 57

i Neither the component being installed nor the system it is connected to are discussed in the Technical Specifications or their Basis.

Tracking No. SE-99-021 Activity No. QCIPM 0200-03 Rev. 2 DESCRIPTION:

The core technical change to this procedure was a change in how the Upper 400 inch Reactor Water Level instrument reference leg is established during Outage Periods (with the Reactor head removed). Previously, this was done by connecting a water filled plastic hose to the reference leg and routing the hose to the refuel floor via the Reactor Building center stairway. The change eliminates this hose and replaces it with an air over water pressure source connected to the reference leg.

This procedure has also been improved by a nu...ber of administrative and format enhancements.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malftmetion of equipmem important to safety previously evaluated in the safety analysis report is not increased becaus: the proposed change has no interaction with any analyzed accidents or transients; therefore, neither probability nor consequences can be affected.

This system provides indication only; it does not cause any automatic actions and therefore, cannot initiate a malfunction of equipment important to safety. While the changed system does'not introduce any new failure modes, it does have some physical failure mechanisms that are subtly different fiom the existing system. Thus, new failure mechanisms are created while at the same time, failure mechanism from the old system, that are more probable, are eliminated. The net effect is there is no discernable change in the probability of malfunction of equipment important to safety. Consequences are unaffected because the changed system has no credible means for affecting source term or the probability of release.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the new method oflevel measurement does not create any new system interactions nor does it have any failure modes that are different in character from the existing system.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the proposed activity does not affect the bases for Technical Specifications Sections 3/4.10.G, K and L, because the system merely indicates water level. It does not impair in any way the ability to perform the plant surveillances necessary to ensure the margin of safety is maintained. Thus, the margin of safety is not reduced.

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Attachment A, SVP-99-102, Page 27 of 57 j

Tracking No. SE-99-023 Activity No. QCOP 1000-42, UFSAR-97-R5-126; GE Vendor Procedures DESCRIPTION:

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Noble Metal Injection Procedures and changes to the UFSAR to add discussion of the Noble Metal Injection Process. j SAFETY EVALUATION

SUMMARY

.l. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because noble metal chemical addition (NobleChem) prevents the start ofIGSCC and stops the growth of existing IGSCC within the reactor coolant pressure boundary.

NobleChem does not adversely affect any contacted equipment. The mitigation ofIGSCC helps prevent the occurrence of a LOCA inside containment. The main steamline is not affected, and thus, the possibility of a Main Steamline Break (MSLB) is not changed.

NobleChem should reduce the amounts of corrosion products within the reactor vessel, which would reduce the possibility of a stuck control rod. The CRD equipment will function as designed, and thus, the possibility of a Control Rod Drop Accident (CRDA) is decreased or not changed. As the noble metal chemical injection occurs at an "all-rods-in" hot shutdown condition, no fuel movement is possible, and thus, an FHA is not possible.

Because NobleChem does not adversely affect fuel bundle structural integrity, the probability of a postulated FHA occurring in the future is not changed by NobleChem. The use of NobleChem has no affect on normal plant operations, except for maintaining the hot  ;

shutdown condition during the noble metal injection process. All operations will remain l within Technical Specifications limits and allowables. Therefore, the probability of occurrence or consequences of an accident previously evaluated in the UFSAR will not be affected.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because NobleChem does not change a plant operating condition or plant operations. No new equipment will be permanently added to the plant. No new equipment interaction, accident scenario, or sequence of events will be created by NobleChem. Thus, NobleChem does not allow for a new fission product

. release path, result in a new fission product barrier failure mode, or create a new sequence of events that results in fuel cladding failures. Therefore, NobleChem can not create the possibility of a new type of accident than any previously evaluated in the UFSAR.

3. ' The margin of safety, as defined in the basis for any Technical Specification, is not reduced because all operations will remain within Technical Specifications limits and allowables, and thus, equipment availability will not change. Plant equipment will continue to be operated within design operating ranges. NobleChem prevents the start ofIGSCC and stops the growth of existing IGSCC within the reactor coolant pressure boundary. NobleChem does not adversely affect any contacted equipment. The mitigation ofIGSCC helps prevent Attachment A, SVP-99-102. Page 28 of 57 r

the occurrence of reactor vessel internals degradation and of a LOCA inside containment.

The safety analyses in the FSAR, which provide the bases for numerous Technical Specifications, are not affected by Noble Chem. Therefore, no margin of safety as defined in the basis for any Technical Specification will be affected.

Tracking No. SE-99-025 Activity No. DCP 9900046 DESCRIPTION:

This DCP installs a positive locking mechanism (clamp) around jet pump ' a 8 (JP 7/8) riser and the existing support brace in Unit 1. The clamp is required as the existing weld between the riser and brace has degraded. A similar clamp was installed on JP 5/6 riser for Unit I and subsequent inspections have confirmed clamp integrity. The shroud repair hardware near JP 7/8 will be removed to facilitate clamp installation. The installation can only occur when the unit is in Mode 5 or defueled since the components are located within the reactor vessel.

SAFETY EVALUATION

SUMMARY

)

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the clamp is a passive device that does not interface or interact with any I other plant system or component. The clamp is designed to resist all of the same forces as the original weld between the riser brace and pipe riser. The clamp will be subjected to the same periodic inspections as thejet pumps and will not interfere withjet pump flow.

Removal of the shroud repair hardware near JP 7/8 is acceptable, as maintaining core geometry is not a concern since the control rods will be inserted if fuel is in the vessel (a !

requirement of Mode 5). Therefore, no adverse changes to any existing accident or transient scenario will result and the probability or consequences of a malfunction of equipment important to safety will not increase.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because flow induced vibrations are not adversely affected as the clamp fits securely around the riser pipe (simulating the original welded arrangement). The clamp utilizes threaded fasteners with locked keepers to ,

prevent loosening over time. Periodic inspection of the clamp will occur since it is part of the assembly for JP 7/8. Subsequent inspections on the JP 5/6 clamp have not revealed any deficiencies. Thus, no new accident or transient scenarios will be created.

Attachment A, SVP-99-102, Page 29 of 57

3.' The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the clamp will not interfere with flow through the riser or the jet pumps.

Monitoring capabilities associated with JP 7/8 are not compromised. Core geometry is not adversely affected by withdrawal / insertion of a single control rod (allowed in Mode 5) with the core shroud repair hardware near JP 7/8 removed during clamp installation. Therefore, margin ofsafety is not reduced.

Tracking No. SE-99-033 Activity No. UFSAR-97-R5-127 DESCRIPTION:

The Containment Inservice Program (CISI) Program was developed in accordance with the requirements of the 1992 Edition with the 1992 Addenda of the ASME Boiler and Pressure Vessel

- Code,Section XI, Division 1, Subsections IWE and IWL, as modified by NRC final rulemaking to 10 CFR 50.55a published in the Federal Register on August 8,1996. The Program details the requirements for the examination and testing of ASME Class MC pressure retaining components at Quad Cities Station Unit 1 & 2 for the first ten-year inspection interval. This Program Plan is effective from 9-30-1998 to 9-9-2008 +/- one year Interval extension as allowed by paragraph (d) ofIWA-2430. This is the first ten- year Inspection Interval for the IWE/IWL Program. The UFSAR is being revised to reflect this new program implementation.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not ,

increased because the IWE Program inspections to be performed are non-intrusive visual

-inspections and have no effect on the probability of occurrence of an accident or, malfunction of equipment important to safety previously evaluated in the safety analysis report.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the IWE Program inspections to be performed are non-intrusive visual inspections and have no effect on the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced

because the IWE Program inspections to be performed are non-intrusive visual inspections and will not reduce the margin of safety as described in the basis for any Technical Specification.

Attachment A, SVP-99-102, Page 30 of 57 q I'

l i

l Tracking No. SE-99-044 l '

Activity No. QCOP 0280-03, Rev. 0 DESCRIPTION:

QCOP 0280-03, Rev. O, " Bypassing the Refuel Bridge Over the Core Rod Block". .

l SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of i equipment important to safety previously' evaluated in the safety analysis report is not l increased because the probability of an inadvertent criticality is not affected by this change J because core alterations are not allowed to occur during this evolution and the control rod motion control switch will be taken out-of-service. The consequences of the refueling accident and the inadvertent criticality accident are not affected by this change. The rod block from the refueling equipment does not mitigate any accident. The rod block is part of the circuitry to prevent accidents, not to mitigate them. Alternate protection to prevent an accident has been provided with the change. Additionally, this change does not affect the probability or consequences of a malfunction of equipment important to safety because the s accidents that the affected equipment is designed to prevent are averted by other administrative controls.

2. 4.ne possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because since alternate protection for the prevention of accidents has been provided, and since this is the only purpose of this circuitry, no new type of accidents or transients are postulated to occur.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced l because there is full compliance with the Technical Specifications. The TS requires this circuitry to be operable when core alterations are in progress; therefore, this evolution )

requires no core alterations to be performed and insures that none are performed. In addition, the rod block is put into place by taking the rod motion switch out-of-service, so that effectively there is a rod block already in place while this evolution is occurring.

- Attachment A, SVP-99-102, Page 31 of 57

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Tracking No. SS-H-98-0161 Activity No. DCP 9700373; SE-97-039 DESCRIPTION:

Install Relief Valve 1-1299-87 between the Primary Containment Isolation Valves on the Reactor Water Cleanup system.

S AFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the relief valve is set sufficiently high to prevent inadvertent discharge.

The valve was installed in accordance with ASME Section XI and Appendix J requirements. Installation of this relief valve will prevent oveyressurization during a DBA LOCA.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because inadvertent discharge of this

- relief valve is detectable by current Technical Specification leakage limits, and if this were to occur, the consequences are bounded by the HELB analysis.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the station Technical Specifications identify ASME Section XI as verification of structural integrity. The relief valve was designed and installed in accordance with ASME

-Section XI.

Tracking No. SS-H-99-0006 Activity No. DCP 9700348; SE-98-147 DESCRIPTION:

Modify the Turbine Trip Logic for the Main Shafl Bearing Oil Pump (MSOP) Low Discharge Pressure from a one-out-of-one logic to a two-out-of-two logic. A new pressure switch, isolation valves and calibration tees will be installed in the Pressure Switch Box located on the Unit 2 Turbine Oil Reservoir.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the scope of this design change is limited to the installation of a new Attachment A, SVP-99-102, Page 32 of 57

f pressure switch that will operate in conjunction with the existing pressure switch for MSOP low discharge pressure to enhance the existing Turbine Trip logic. This design change has not created new interfaces with other systems or components important to safety. As such, l the probability or consequences of a accident or a malfunction is not affected. The new pressure switch arrangement for monitoring MSOP low discharge pressure will be adequately tested to ensure the Turbine Trip logic will continue to function as intended.

QCIPM 5610-36 provides the instructions for functionally testing the MSOP low discharge pressure turbine trip.

The Turbine Trip logic is designed as a series of parallel fail safe inputs each individually and independent that can initiate the Turbine Trip; therefore, this change to the MSOP low discharge pressure contact logic has no effect on the other Turbine Trip input contacts.

l The installation of the two-out-of-two logic does marginally increase the probability of a malfunction of equipment. However, the reduction in the probability of a turbine trip due to MSOP low discharge pressure switch failure is significant enough that the overall

probability of a malfunction of equipment important to safety does not increase.

' 2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because Pressure Switch installation and control logic change initiated by this design change is all within the Turbine Trip logic.

Failure modes for these changes have been addressed and found to be within the boundaries

~

of the existing Turbine Trip components. Although adequate testing will be performed to ensure reliability, in the unlikely event that the new or existing pressure switches fail to function properly, a Turbine Trip is still expected to occur due to the Turbine Thrust Bearing Trip, which is an analyzed condition. Therefore, no new accidents are being introduced by this design change that have not been previously analyzed. j The failure modes of the pressure switches have been addressed and shown that there are no adverse impacts to the Turbine Trip logic because of the independence of the Turbine Trip logic signals and because of the reliability of the pressure switches.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based; therefore, there is no reduction in the margin of safety.

Tracking No. SS-H-99-0008 Activity No. DCR 990004; UFSAR-97-R5-109; SE-99-003 DESCRIPTION:

The purpose of this safety evaluation is to support the issuance of DCR 990004 and UFSAR R5-109. DCR 990004 was issued to revise drawing M-4A, Sheets 1 through 5 to Rev. B. UFSAR

- Section 3.11 was revised (UFSAR-97-R5-109) to update Figure 3.11-1, Sheets 1 through 10 with drawing M-4A, Sheets 1 through 5, Rev. B.

i Attachment A, SVP-99-102, Page 33 of 57 l

L_}

O The EQ parameter changes are based on the same source documents that were reviewed for their impact in safety evaluation SE-99-003 and is applicable to the proposed activities.

SAFETY EVALUATION SUMMA'RY:

1. The probability of occurrence or the consequences of an accident ca a malfunction of equipment important to safety previously evaluated in the safety analysis report is not i nereased because the EQ documentation demonstrates the qualification of the affected )

SSCs under the changed environmental conditions. The change does not affect the function of the components required to mitigate the accidents. Therefore, the change in EQ Zone

)

parameters or the UFS AR change does not impact the probability of occurrence of this accident or conscquences of the accident or a malfunction of equipment important to safety.

1

2. The possibility for an accident or malfunction of a different type than any evaluated l previously in the safety analysis report is not created. The changes in parameters calculated are the direct results of the postulated DBAs and do not affect any other accidents. This change does not affect normal plant operation or operation during any other DBA or l transient. No functional changes have been made to any SSC due to this proposed change.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because DCR 990004 and UFSAR-97-RS-109 do not impact the margin of safety as defined l in the basis for any Technical Specification. The source documents for the changed EQ parameters are the same as those originally reviewed for their impact in SE-99-003. The EQ parameters shown in M-4A were calculated for the plant design basis and do not impact the Technical Specifications. 4 Tracking No. SS-H-99-0010 Activity No. DCN 001529E-01 (DCP 9600384); DCN 001530E-01 (DCP 9700029); SE-98-091 DESCRIPTION: )

DCN 001529E-01 and DCN 001530E-01 replace existing Penn pressure switches with SOR pressure switches and unloading solenoid valves for both trains of the shared Emergency Diesel ,

Generator (EDG) air start system. New, separate solenoid valves are required since the existing l pressure switches also contained solenoid valves. These pressure switches function to control l volume (pressure) in the air receiver tanks by controlling the air compressors. It is the volume of air in the tanks that is used to start the EDG.  ;

SAFETY EVALUATION

SUMMARY

1. ' The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the new components perform the same function as the existing components and are considered more reliable. The replacement components are purchased Attachment A, SVP-99-102, Page 34 of 57 c

and installed safety-related to a.sure the pressure boundary of the air system is maintained.

The new pressure switches are tested to higher standt ds than the existing (original) ,

switches. Also, the existing copper tubing is being replaced by stainless steel tubing which 1 is considered an overall improvement due to increased strength. Thus, existing accident or 1 malfunction scenarios are n.x increased by this activity.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the replacement components perform the same function and are considered more reliable than the existing components. J No new system interfaces result from this activity. Therefore, new accident or malfunction scenarios are not created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because System parameters and technical specification parameters are not altered by the proposed component changes. The new components are considered more reliable than the existing components. Thus, margin of safety is not reduced by this activity.

Tracking No. SS-H-99-0022 Activity No QCAN 901(2)-7 C-5 Rev. 2; QOM 2-5650-01 Rev. 3; SE-98-100 DESCRIPTION:

This modification has a new gessure switch with new isolation valves. This addition will make the logic two-out-of-two trip logic instead of one-out-of-one, i.e., both switches must "see" the EHC fluid low pressure before the turbine will trip. In addition, this modification adds a 3-second time delay to the EHC low-pressure turbine trip logic.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the saiety analysis report is not increased because the additional components provide a monitoring function and have an insignificant affect on the failure of the EHC or turbine systems. The addition of the second pressure switch and the 3-second time delay relay will reduce the probability of a low '!HC pressure turbine trip due ta an invalid or spurious signal.

2. The possibility for an accident or malfunction of a different type than any evaluated j previously in the safety analysis report is not created because the new pressure switch being l installed is identical to the previous switch, and the failure modes are the same. The new

wiring installed with the time delay relay is consistent with the existing design and is being added only to mitigate a spurious signal.

3. The margin of safety, as defiried in the basis for any Technical Specification, is not reduced i

because this modification introduces additional active components that must function to provide a turbine trip. The addition of these components will decrease the probability of a Attachment A, SVP-99-102, Page 35 of 57 o

i spurious turbine trip from a low EHC pressure signal. The turbine will either trip or fail to '

trip due to EHC low pressure. If either event were to occur, the turbine would trip from other signals and the reactor would trip if power were above a certain value. The accidents have been previously analped. The margin of safety is not reduced with the addition of l these components.

Tracking No. SS-H-99-0029 Activity No. QOA 900-7 C-4 Rev. 3; QOA 5600-03 Rev. 6; SE-98-099 DESCRIPTION:

These procedure changes reflect the installation of DCP 9700367. This design change will bypass the automatic high temperature trip function of the LP turbine exhaust hood when operating at or above 30% power.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because of concern is the potential for damaging the turbine by overheating and causing harmful distortions or clearances of the last LP turbine buckets that could rub on the casing and cause turbine missiles. Sensors that signal the control room via remote alarms detect high temperature conditions. The turbine trip logic will be changed from 'always trip on high temperature' to 'only trip on high temperature below 30% power' This increases the probability that the automatic turbine trip will not be initiated on high temperature, although this failure mechanism is not new. The probability of this occurrence is small because the wiring and contact used meg the electrical design requirements of the turbine i trip system, and the new components will be adequately tested to ensure the turbine trip I function is operating properly. Also, the duration of time the turbine is in this mode is very short as compared to the time the turbine is operating above 30% power. Procedural guidance is given to protect the turbine by these procedures. Therefore, the probability or consequence of existing accidents are not changed.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because components being installed by this modification are all within the turbine trip logic. Failure modes for these changes have been addressed and have been found within the boundaries of the original turbine trip design. Therefbre, no new accidents ne malfunctions are being introduced by the modification.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the turbine trips from equipment failures are reduced by the modification. A reduction of the number of turbine trips will result in reduced cycles on the vessel. ,

l Attachment A, SVP-99-102, Page 36 of 57 l

p ,

l The reactor coolant pressure safety limits are not impacted by the elimination of unnecessary turbine trip transients and reactor scrams. Therefore, the margin of safety is not reduced.

Tracking No. SS-H-99-0035 Activity No. QCOP 1200-15, Rev. 6; SE-98-024 DESCRIPTION:

Increase procedural administrative limit for use of the RWCU system in the decay heat removal mode in conjunction with Reactor vessel hydrostatic or inservice leak tests from < 225'F to

< 250"F.

SAFETY EVALUATION

SUMMARY

1.- The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the use of the RWCU system at higher temperatures during a Reactor vessel pressure test does not create any new system failure modes and the system is not adversely affected by operation within the new limit. If the system were to fail, the change in maximum operating temperature would not change the consequences of this malfunction.

The ability to perform mitigating actions has not been changed or adversely affected.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this procedure only is performed during shutdown conditions. The accidents and anticipated transients referenced, except for the LOOP, occur with the unit at power. The evaluation, though, has no impact on electrical equipment that might cause a LOOP. Performing a Reactor vessel hydrostatic test at a slightly higher temperature reduces the potential of a brittle fracture of the vessel and does not exceed any high temperature limits on the vessel or any affected system.

Ti> mfore, the decrease in heat removal by the Reactor coolant system transient / accident wgd not be made more severe.

The change does not cause any thermal limits to be exceeded on the utilized equipment;

' therefore, the change does not make a LOCA more likely. If a LOCA were to occur during hydro testing, the Reactor would quickly depressurize because of the limited fluid makeup capacity during the test. This does not prevent the use oflow pressure ECCS systems and therefore, has no adverse impact on the systems required to mitigate the LOCA.

~3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because if there is a loss of RWCU during the pressure test, this would not result in a

' violation of the Technical Specification pressure / temperature curve. Core cooling could be restored by depressurizing the vessel and initiating Shutdown cooling. This recovery mode would also not violate the pressure / temperature cu ve. The test is performed very close to Attachment A, SVP-99-102, Page 37 of 57

. g

n 7 Mode 4 conditions and therefore, low pressure ECCS' systems and Secondary Containment i are available in the event oflarge coolant leak during the test.

l L Tracking No. SS-H-99-0037 Activity No. UFSAR-97-RS-116; NFM:BSA:99-008 j DESCRIPTION:

The proposed activity is to change the Quad Cities Units 1 and 2 Rod Withdrawal Block Monitor (RBM) upscale instrumentation trip setpoints. The setpoints to be changed are determined from the following relationships:

From: < (0.65)Wd + 43%**, To: < (0.65)Wd + 55%**

For Single Loop Operation (SLO), the Rod Withdrawal Block Monitor Upscale Instrumentation Trip Setpoint is determined from the following relationship:

1 From: < (0.65)Wd +39%* *, To: < (0.65)Wd + 51%**

• • Clamped with an allowable value not to exceed the allowable value for recirculation loop drive flow (Wd) of100%.

Wd is the percent of drive flow required to produce a rated core flow of 98 million Ib/hr. Trip level  ;

setting is in percent of rated thermal power (2511 MWth).

The effect of changing the RBM setpoints to the proposed values allows the reactor core to be operated within its licensed power / flow map without unnecessary restrictions.

~S AFETY EVALUATION

SUMMARY

1. - The probability of occurrence or consequences of an accident or a malfunction of equipment important to safety previously evaluated is .he safety analysis report is not

increased because raising the RBM setpoints to credit the conservatively analyzed unblocked Rod Withdrawal Error event for QlC16/Q2C15 and updating the setpoints in the COLR accordingly will not affect the probability of the Rod Withdrawal Error (RWE)

. event. These changes do not increase the probability that the incorrect control rod would be selected for withdrawal. The RBM system itselfis not affected by this change; therefore,

' the system that is designed to eventually inhibit withdrawal of the control rod and terminate

' th; transient is assumed to function the same with revised setpoints as before these changes.

Therefore, the probability of the RWE event will not be increased.

The OLMCPR ensures that the MCPR Safety Limit is not violated. The off-site dose is not

- increased from the RWE event due to the change to raise the PBM setpoints since fuel failure is not expected to occur. This is true since violation of the MCPR Safety Limit,1%

Attachment A, SVP-99-102, Page 38 of 57

)

plastic strain, and fuel centerline melt are prevented by the MCPR and LHGR limits.

Therefore, consequence of the RWE event are not increased due to these changes.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the change to raise the RBM

.setpoints to credit the conservatively analyzed unblocked Rod Withdrawal Error event for QlC16/Q2C15 and updating the setpoints in the COLR accordingly will not adversely affect systems or plant equipment in a way that would create another type of accident or malfunction different than that evaluated in the UFSAR. The change to raise the RBM setpoints does not prevent any plant systems from adequately performing its functions, nor does it create the possibility of an accident different than those r.lready evaluated in the UFSAR.

Since operating limits have been established to protect the conservatively increased Safety Limit MCPR using previously approved methods and the results meet the basis for the thermal limits, there is no possibility to create an accident or malfunction of a type different from those evaluated in the SAR.

3. The margin of safety, as dermed in the basis for any Technical Specification, is not reduced l because the proposed activity to criange the RBM setpoints is within the currently analyzed and approved safety analysis. The MCPR Safety Limits were confirmed to be bounding for Q1C16 and Q2C15. Operating Limit MCPRs that apply to GE9/10 fuel and ATRIUM-98 fuel are provided in the COLR to protect the MCPR safety limit. Therefore, there is no reduction in the margin of safety for MCPR, as appropriate operating limits for QlC16 and Q2C15 will be applied.

Tracking No. SS-H-99-0038 Activity No. COLR Revision Q2C15 Rev 1; NFM:BSS:99-025 DESCRIPTION:

This safety evaluation addresses changes to the Q2C15 Rev. I reload licensing reports and Core Operating Limits Report (COLR). The changes to the COLR include increasing the MCPR Safety Limit from 1.10 to 1.11, changes to the MCPR Operating Limits, changes to the Rod Block Setpoint limits, and attaching the revised Plant Transient Analysis and Reload Analysis reports for Q2C15. The increase in the MCPR Safety L'imit is being implemented to make the MCPR Safety Limits consistent between Quad Cities Unit I and Unit 2 in preparation for implementation of a Technical Specification submittal. The transient and reload analyses were re-performed to incorporate the updated fuel gap conductance inputs using a 1.11 MCPR Safety Limit and to relax the input values for the margin to unpiped safety valve analysis for SCRAM timing, relief valve setpoints, turbine stop valve and turbine control valve timing. This re-analysis resulted in new MCPR Operating Limits for Q2C15 and positive unpiped safety valve margin. The rod block setpoint change is being addressed by another safety evaluation. .

l Attachment A, SVP-99-102, Page 39 of 57

In addition, select references in the COLR were updated to match revisions to documentation.

These updates are administrative in nature and wi!! not be addressed again in this evaluation.

SAFETY EVALOATION S&a mWL

'l. The probability of occutTence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this conservative increase of the MCPR Safety Limit, revision of the Q2C15revi inpat parameters and the resultant COLR changes (including revised operating limits) will not affect the probability of the malfunction of equipment important to safety.

This change does not physically alter any plant components, systems or structures. The fuel integrity will continue to be protected by the thermal limits provided in the COLR.

Therefore, the probability of the malfunction of equipment important to safety does not

. increase.

This revision of the Q2C15 Rev.1 COLR with changed MCPR Safety and Operating Limits will not affect the consequences of a malfunctions of equipment important to safety. These changes to the Q2C15revi COLR are due to a conservative increase in the MCPR Safety Limit, changes in inputs to the transient analyses and changes to the transient analyses reports, not a physical change to any plant systems, structures, or components. No plant support equipment designed t mitigate consequences of accidents or malfunction is physically altered by these changes. The consequences do not increase as the MCPR Operating Limits protect the MCPR Safety Limit which precludes fuel failure. Therefore, the ccnsequences of a malfunction of equipment important to safety will not be increased.

2. The possibility for an accident or malfunction of a different type than any evaluated

- previously in the safety analysis report is not created because the increase in the MCPR Safety Limit and the chuges to the transient analysis inputs to incorporate the new GE fuel characteristics and assumed reactor conditions resulting in the changes to the Q2C15 Rev.1 COLR will not adversely affect systems or plant equipment in a way that would create another type of accident or malfunction different than that previously evaluated. These changes were mcde to more accurately model GE co-resident fuel and the Q2C15 Rev. I core design and operation, and to conservatively increase the MCPR Safety Limit. This revision to the analyses does not physically change any plant systems or functions. The proposed operating limits have been prepared using the results of the revised analyses,

' including the unblocked RWE analysis supporting the rod block setpoint changes, and ensure protection of the associated revised safety limit. Therefore, no new accidents or malfunctions of a type different than those evaluated are expected.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced 1 because the increase in the MCPR Safety Limit and the changes to the transient analysis inputs to incorporate the new GE fuel characteristics and assumed reactor conditions resulting in the changes to the Q2C15 Rev.1 COLR will not reduce the margin of safety as j defined in the basis for any Technical Specification. No Safety Limit as defined in i l

1 I

l Attachment A, SVP-99-102, Page 40 of 57 l

Technical Specifications is being challenged as a result of these changes. Therefore, the  !

margin of safety is not reduced as a result of these changes. 1

(

)

Tracking No. SS-H-99-0044  !

Activity No. DCR 990064; SE-98-099 DESCRIPTION:

DCR 990064 to revise drawing 4E-6820H, Rev. F for error made during DCP 9700366 issuance.

SAFETY EVALUATION

SUMMARY

- 1. The probability ofoccurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not

. increased because this DCR will correct drawing 4E-6820H, Rev. F to show the proper ,

voltage comparator type designation for comparator VC2A15. This typographical error was ]

introduced during the issuance of DCP 9700366 which shows the comparator as type A on page 4, but also shows it on page 5 as a type B comparator. Investigation revealed that page 5 is correct and the comparator should be shown as a type B on page 4 as well. Changing page 4 to show the intended comparator designation will have no effect on 50.59 safety evaluation SE-98-099 which was prepared for DCP 9700366. The probability of occurrence or consequences of an accident or malfunction of equipment important to safety remains the same.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the r fety a

am,Iysis report is not created because as stated in the previous step,

it was the intent ou {P 9700366 to show the comparator as a B type. Safety Evaluation SE-98-099 was prepared with this in mind. Correcting the error on 4E-6820H, Rev. F will allow this drawing to be in conformance with DCP 9700366 and it's safety evaluation. The possibility for an accident or malfunction of a different type than evaluated in the SAR is ,

not created. j 3.- The margin of safety, as defined in the basis for any Technical Specification, is not reduced because changing the designation of this comparator will have no affect on the Technical Specifications. l Attachment A, SVP-99-102, Page 41 of 57 Na

Tracking No. SS-H-99-0045 Activity No. UFSAR 97-RS-118; SE-99-016 DESCRIPTION:

Revise UFSA.R section 5.3.2.2 to include a discussion on performing pressure testing of non-welded Class 1 repairs / replacements with the core critical provided the Class 1 periodic pressure test required by ASME Section XI Category E-I'is completed prior to criticality at the end of each refueling outage and the replacement activities are controlled.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety was analyzed in Safety Evaluation SE-99-016 and concluded there was no increase. SS-H-99-0045 was used as a validation of the  ;

previously performed Safety Evaluation (SE-99-016) to permit a revision to UFSAR section 5.3.2.2.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the possibility for an accident or malfunction of a different type than any evaluated previously was analyzed in Safety Evaluation SE-99-016 and concluded it was not created. SS-H-99-0045 was used as a validation of the previously performed Safety Evaluation (SE-99-016) to permit a revision l to UFSAR section 5.3.2.'2.

i

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the margin of safety, as defined in the basis for any Technical Specification was not l reduced as documented in Safety Evaluation SE-99-016. SS-H-99-0045 was used as a j validation of the previously performed Safety Evaluation (SE-99-016) to permit a revision to UFSAR section 5.3.2.2.

Tracking No. SS-H-99-0047 Activity No. QCAN 901-8 C-8 Rev. 3; QCAN 901(2)-8 H-1 Rev. 4; SE-98-098 DESCPIPTION:

1 i

Delete reference to a Unit 1/ Unit 2 fuel oil pump selector switch at Panel 2251-37. j SAFETY EVALUATION

SUMMARY

l. The probability of occurrence or the consequences of an accident or a malfunction of 1 equipment important to safety previously evaluated in the safety analysis report is not

. Attachment A, SVP-99-102, Page 42 of 57

]

1

)

1

~

increased because the only action altered is the deletion of guidance for movement of a i selector switch that is no longer in place, and therefore, the action cannot be performed. In j addition, this does not alter the supply of fuel oil to the Emergency Diesel Generators and I therefore, does not affect any equipment that is assumed to operate during an accident. )

2. The po.ssibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the referenced selecto: switch is no longer in place, and therefore, the previously stated action cannot be performed. No new actions are being added and no in-place actions are being altered. Therefore, no I accidents or malfunctions are impacted.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Specifications are based. i i

Tracking No. SS-H-99-0049 Activity No. QCAN 901(2)-4 G-22 Rev. 3; SE-99-005 DESCRIPTION:

Indicate that the puinp low discharge pressure alarm for the 1 A Fuel Pool Pump requires the pump breaker to be closed.

SAFETY EVALUATION

SUMMARY

1 1

1. The probability of occurrence or the consequences of an accident or a malfunction of 1 equipment important to safety previously evaluated in the safety analysis report is not increased because the only change is to indicate which actions are required due to an j abnormal condition. The actions to address the abnormal condition have not been altered. j I

2. The possibility for an accident or malfunction of a different type than any evaluated j previously in the safety analysis report is not created because the only change is to indicate j which actions are required due to an abnormal condition. The actions to address the abnormal condition have not been altered.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the change does not affect any parameters upon which Technical Speci6 cations are based.

i Attachment A, SVP-99-102, Page 43 of 57

( ]

Tracking No. SS-H-99-0054 Activity No. UFSAR-97-R5-123; SE-98-091 DESCRIPTION:

. DCN 0014511-01 replaces and relocates the existing Penn pressure switch with a Static O-Ring (SOR) pressure switch and unloading solenoid valve for the 2-4609B air compressor of the Emergency Diesel Generator (EDG) air start system. A new, separate solenoid valve is required since the existing pressure switch contained a solenoid valve and this ccmbination is now obsolete.

The pressure switch functions to control volume (pressure) in the air ret eiver tanks by controlling the air compressors. It is the volume of air in the tanks that is used to 51 art the EDG.

This Safety Evaluation was also used for DCP 9600453 which was not Op authorized during this report period. The summary will be included when the DCP becomes Op authorized.

l

. UFSAR Figure 9.5-3 will be simplified as a result of this UFSAR submittal. This design change relocates a pressure switch that has had a history of vibration related failures and replaces an obsolete unloader-solenoid, combination valve with two components. In previous design changes (DCP 9600377, DCP 9600383, DCP 9600384, DCP 9700028 and DCP 9700029) there has been an attempt to identify each of these changes on UFSAR Figure 9.5-3 as they were installed.

l However, the purpose of the single-line drawing in the UFSAR is to provide a functional ]

description of the Diesel Generator Air Start System. Although the location and physical mounting

. of the pressure switch is changing, the pressure switch will continue to sense pressure from the same volume and provide the same signa's to the Diesel Generator Air Start Compressor. The obsolete combination valve does not operate any differently than the two replacement components and is still, functionally, a part of the compressor operation. Therefore, Figure 9.5-3 has been simplified to reflect the function of the Diesel Generator Air Start system and bound the changes  ;

being made as a result of this design change. i SAFETY EVALUATION

SUMMARY

l

1. The probability ofoccurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the new components perform the scme function as the existing components and are considered more reliable. The replacement components associated with the safety-related pressure boundary and/or safety-related function are purchased and installed safety-related to ensure the pressure boundsry of the air system is maintained. The solenoid valve is isolated from the pressure boundary and is therefore, non-safety-related.

The new pressure switch is tested to higher standards than the existing (original) switch.

Also, the existin; copper tubing is being replaced by stainless steel tubing which is considered an overall improvement due to increased strength. Thus, existing accident or malfunction scenarios are not increased by this activity.

Attachment A, SVP-99-102, Page 44 of 57

l

2. The possibility for an accident or malfunction of a different type than any evaluated j previously in the safety analysis report is not created because the replacement components perform the same function and are considered more reliable than the existing components.

No new system interfaces result from this activity. Therefore, new accident or malfunction scenarios are not created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because system parameters and Technical Specification parameters are not altered by the proposed component changes. The new components are considered more reliable than the existing components. Thus, margin of safety is not reduced by this activity.

Tracking No. SS-H-99-0056 Activity No. FPR CRN 98-08; SE-98-098 DESCRIPTION:

Update the Fire Protection Report (FPR), Volume 2 Safe Shutdown Analysis (SSA) to reflect the changes implemented by Design Change Package (DCP) 9800235. The DCP changed the fuel oil piping for the 1/2A and 1/2B fire pump day tanks, changed the control circuits for the Unit I and Unit 2 Diesel Fuel Oil Transfer Pumps, added a new selector switch to panels 2252-37 and 2251-37, and connected bypass valves in parallel with somnoid valves SO 1/2-5202 and SO 1/2-5203.

Table 3.3-1, Table 3.3-2, section 4.20, section 7.0, and Appendix B drawings were changed as a result of the DCP. Changes to Appendix B are documented in NDIT QDC-98-045-04.

SAFETY EVALUATION

SUMMARY

1

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because information in the Fire Protection Report documents the plant design and its response during a fire scenario. The Safety Evaluation previously completed documents j the probability of occurrence or consequences of an accident or malfunction. Therefore, the I documentation of the change within the Fire Protection Report does not change the probability of an accident or malfunction beyond those previously analyzed.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because information in the Fire Protection Report documents the plant design and its response during a fire scenario. The Safety Evaluation previously completed documents the possibility for an accident or malfunction. Therefore, the documentation of the change within the Fire Protection Report does not change the possibility hi an accident or malfunction beyond those previously analyzed.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because information in the Fire Protection Report documents the plant design and its j

- response during a fire scenario. The Safety Evaluation previously completed documents )

l 1

Attachment A, SVP-99-102, Page 45 of 57

. l 1

e that the change does not affect any parameters upon which Technical Specifications are based. Therefore, the documentation of the change within the Fire Protection Report does not change the any margin of safety.

Tracking No. SS-H-99-0059 I Activity No. QCOP 3300-08 Rev. 4; SE-98-057 j I

DESCRIPTION: l Revise minimum indicated CCST level R>c HPCI and RCIC operability to be 10.5'.

. SAFETY EVALUATION

SUMMARY

l

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not l increased because the only change is to abstract a value listed within the referenced safety l evaluation that ensures the minimum quantity of water available is maintained and provides 1 a correlation between indicated level versus actual level. This does not alter the stated quantity of water that is required to be maintained.

1

2. The possibility for an accident or malfunction of a different type than any evalucted )

previously in the safety analysis report is not created because as stated in item 1. above, this i does not alter the stated quantity of water that is required to be maintained.

3. The margin of safety, as defined in the basis for any Technical SpeciGeation, is not reduced because as stated in item 1. above, this does net alter the stated quantity of water that is required to be maintained.

Tracking No. SS-H-99-0060 Activity No. QCOS 1400-11 Rev.1; SE-98-142 DESCRIPTION:

RevEe testing of.several circuits so that relays that are actuated by contacts in parallel paths can be ver .ed to be actuated by operation of the contacts independent of each other. This provides a

n. ore concise testing of contacts to assure proper operation of circuits.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because components are bypassed or actuated using accepted maintenance practices. These activities are performed on subsystems that are inoperable and within an allowable outage time. Circuit breakers for the Core Spray pumps ard EDGs are racked Attachment A, SVP-99-102, Page 46 of 57 o

c I

into test to allow verification of the logic without actually closing the breaker, Inspections '

are performed to ensure that equipment is returned to its design condition before the subsystem is required to be operable.

i

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because loss of off-site power and various LOCA's have already been evaluated in the SAR. This change impacts systems and components that are described in the evaluation of these accidents. This change does not produce any fundamental difference in how these systems and components interact with the ]

rest of the plant.

3. The margin of safety, as defined in the basis for any Technical Specification. is not reduced because the change does not affect any parameters upon which Technical Specifications are

)

based.

]

Tracking No. SS-H-99-0063 Activity No. QOS 6500-03, Rev.13; SE-98-112 DESCRIPTION: j Include in the procedure a condition that results in a Unit 1 RWCU isolation and actions needed to a return components to the normal status.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the &asequences of an accident or a malfunction of equipment important to safety previously evaluated in' the safety analysis report is not increased because this provides information and ensures the system is retumed to the proper configuration. As such, it has no adverse impact on system operation and can not result in a change in probability of occurrence or a change in the consequences of an event.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this provides information and ensures the system is retumed to the proper configuration. As such, it has no adverse impact on system operation and can not result in the possibility of creating a different type of accident'or malfunction.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this provides information and ensures the system is returned to the proper configura6n. As such,it has no adverse impact on system operation and can not result in a

- change to the ' margin of safety.

Attachment A, SVP-99-102, Page 47 of 57

Tracking No. SS-H-99-0065 Activity No. QOS 6500-01 Rev. 31; SE-98-112 DESCRIPTION:

Include in the procedure a condition that results in a Unit 1 RWCU isolation and actions needed to return components to the normal status.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because this provides information and ensures the system is returned to the proper configuration. As such, it has no adverse impact on system operation and can not result in a change in probability of occurrence or a change in the consequences of an event.

2. - - The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this provides information and ensures the system is returned to the proper configuration. As such, it has no adverse impact on system operation and can not result in the possibility of creating a different type of accident or malfunction.

I

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced J because this provides information and ensures the system is returned to the proper ]

configuration. As such, it has no adverse impact on system operation and can not result m a  ;

change to the margin of safety.

Tracking No. SS-H-99-0066 Activity No. QOA 900-7 C-13 Rev. 2; QCAN 901-7 C-13 Rev. 0; QOA 900-7 E-13 Rev. 2; QCAN 901-7 E-13 Rev. 0; QCAN 901(2)-7 G-13 Rev.1 (delete);

QCAN 901-7 G-13 Rev. 0; QCAN 902-7 G-13 Rev. 0; SE-99-017 DESCRIPTION:' l Delete Unit 1 alarms for Off Gas High Flow, SJAE Liquid Drain A High Level, and A SJAE Loop

. Seal Drain Low Level. This resulted in the alarm tiles becoming Unit specific with Unit I alarm tiles now identified as ' spares' and the Unit 2 alarm tiles now only referencing Unit 2 with no change in action.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not Attachment A, SVP-99-102, Page 48 of 57 on__

increased because the chrnges te the reference procedures are alarm indications only.

These alarms annunciate as result of abr.ormal conditions and do not cause the condition.

The changes do not result in, prevent, or alter actuation of any components. As such, the changes can not increase the probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because for the same reasons stated in item 1, the changes do not cause any abnormal conditions or result in, prevent, or alter actuation of any components. As such, the changes can not create the possibility for an accident or malfunction of a different type that any evaluated previously in the safety analysis report.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the referenced Unit I annunciator tiles will no longer be active; therefore, the changes only reflect that the alarms will no longer occur. As such, these changes have no adverse impact on system operation and can not result in a change to the margin of safety.

Tracking No. SS-H-99-0067 Activity No. QOM l-5400-01 Rev. 7; QOM 1-5400-02 Rev. 6; SE-99-017 DESCRIPTION:

Revise valve checklists to reflect the change in position of one valve and the deletion of several other valves.

SAFETY EVALUATION SUMM ARY:

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the referenced procedures are valve checklists that reflect actual plant configuration. These procedures do not direct any actions to be performed and do not result in, prevent, or alter actuation of any components. As such, the changes can not increase the probability of occurrence or the conrequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report.

2. - The possibility for an accident or malfunction of a different type than at:y evaluated previously in the safety analysis report is not created because for the same reasons stated in item 1, the changes do not cause any abnormal conditions or result in, prevent, or alter  ;

actuation of any components. As such, the changes can not create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.

Attachment A, SVP-99-102, Page 49 of 57

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the procedures only reflect changes implement:d by DCP 9900035, DCN l 001784M, DCN 001785M and DCN 001788I. They do not add, alter or delete any actions.

As such, these changes have no adverse impact on system operation and can not result in a L change to the margin of safety.  ;

l Tracking No. SS-H-99-0078 Activity No. QCIS 1000-06; Rev. 9; SE-97-158 DESCRIPTION:

The procedure change to QCIS 1000-06 Rev. 9 -HIGH DRYWELL PRESSURE AUTO BLOWDOWN /HPCI INITIATION FUNCTIONAL TEST, verified the proper operation of the j' 1-2330-162 relay during the functional testing of PS 1-1001-89D and clarified the test setup for

, PS 1 1001-89D.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the testing process was not changed in this revision. The addition to verify actuation of relay 1-2330-162 was visual and thus did not increase the probability or consequences of an accident / malfunction of equipment important to safety.

The procedure was applicable in ALL MODES; therefore, adding NO MODE was acceptable because this clarifies a distinctly defined situation per Technical Specifications.

4 Removing the Shift Manger final review also had no impact on the probability or consequences of an accident / malfunction of equipment important to safety, j l

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the only changes to the procedure were passive in nature (e g. visual verification of relay actuation) and thus did not

create the possibility for a new accident ar malfunction of a different type previously ,

evaluated.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the functional test was not changed by this reviwon. The same control and trip functions are tested in the same manner as previously evaluated.

i i

Attachment A, SVP-99-102, Page 50 of 57 i

Tracking No. SS-H-99-0079 Activity No. QCOS 0005-05, Rev. 6; QCOP 0201-13; Rev. 3; SE-99-021 DESCRIPTION:

Changes to the following procedures:

QCOS 0005-05, Rev. 6, INCREASED MONITORING SURVEILLANCE

, QCOP 0201-13, Rev. 3, REACTOR LEVEL UPPER 400 REFERENCE LEG EXTENSION USE AND CONTROL SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the new system eliminates the more probable failure mechanism (physical damage to the tygon tube) by using stainless steel tubing and a pressure gage.

Therefore, the probability of an accident decreases while the consequences remain the same.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because this new system for obtaining reactor leven will only be used when the Reactor is in cold shutdown and vented to the Reactor Building atmosphere. The fault pathways are the same as the previous method of obtaining Reactor level using the upper 400 level indication, j

{,

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the proposed activity does not reduce the margin of safety because this system only provides indication oflevel. This instrument does not provide any automatic safety

^

injection or other ECCS function. It does not impair the ability to perform any plant surveillance or other operating procedure.

Tracking No. SS-H-9940080 Activity No. QCCP 0200-03; UFSAR-97-R5-126; SE-99-023 DESCRIPTION:

Adds Chemistry limits for Noble metals to QCCP 0200-03 Reactor Water Chemistry.

l SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because noble metal chemical addition (NobleChem) prevents IGSCC and stops the growth of existing IGSCC within the reactor coolant pressure boundary. NobleChem i Attachment A, SVP-99-102, Page 51 of 57

o

, does not adversely affect any contacted equipment. The use of NobleChem has no affect on normal plant operations, except for maintaining the hot shutdown conditions during the noble metal injection process. All operations will remain within Technical Specifications limits and allowables. Therefore, the probability of occurrence or consequences of an accident previously evaluated in the UFSAR will not be affected.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because NobleChem does not change a plant operating condition or plant operations. No new equipment will be permanently added to the plant. No new equipment interaction accident scenario, or sequence of events will be created by NobleChem. Thus, NobleChem does not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that results in fuel cladding failures. Therefore, NobleChem can not create the possibility of a new type of accident than any previously evaluated in the UFSAR.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because all operations will remain within Technical Specifications limits and allowables, and thus equipment availability will not change. Plant equipment will continue to be j operated within operating ranges. NobleChem prevents the start ofIGSCC and stops the i growth of existing IGSCC within the reactor coolant pressure boundary. NobleChem does not adversely affect any contacted equipment. The mitigation ofIGSCC helps prevent the occurrence of reactor vessels internals degradation and of a LOCA inside containment. The safety analysis in the FSAR, which provide the bases for numerous Technical Specifications, are not affected by NobleChem. Therefore, no margin of safety as dermed l

in the basis for any Technical Specification will be affected.

Tracking No. SS-H-99-0084 Activity No. GE Procedures; Specifications for DCP 9900046, Repair Jet Pump 7/8 Riser, Unit 1; SE-99-025 DESCRIPTION:

Authorize onsite use oflisted General Electric Specifications and Procedures during the accomplishment of Design Change Package (DCP) 9900046 to repair Jet Pump Riser 7/8 at Quad  !

Cities Station, Unit 1. The DCP involves installation of a passive restraint clamp device on the riser for Jet Pump 7/8. The clamp will functionally take the place of the weld between the riser and riser brace. The installation of the jet pump riser clamp device will require the temporary removal of the core shroud repair hardware adjacent to jet pump 7/8.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the capability of reflooding the core to two-thirds core height following a Attachment A, SVP-99-102, Page 52 of 57

1

, I I

LOCA is dependent upon the stmetural integrity of the jet pumps (JP). Failure of thejet l pump riser will not cause a breach in the reactor coolant pressure boundary. Therefore, the I probability of a LOCA is not increased. The function associated with JP 7/8 and its riser is )

unchanged by the installation of the clamp and therefore, consequences of a LOCA are not increased. The clamp is a passive restraint device designed to replace the weld between the riser for JP 7/8 and the riser support brace. It is designed to handle all or the forces normally resisted by the weld. Therefore, the probability of malfunction of equipment important to safety has not increased. Since the clamp is specifically designed to accommodate all of the same forces as the riser to riser brace weld, any consequences associated with equipment malfunction have not increased.

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the clamp will not interact or interface with any other plant system or component. Therefore, no new failure modes will be introduced. The clamp is designed to " replace" the degraded weld between the riser and riser support brace, should this weld eventually fail. A similar clamp has been installed at  !

the same location on JP 5/6 riser with no observed deficiencies. The clamp utilizes threaded fasteners with tack welded keepers to pievent loosening over time. The clamp will be i subject to the same periodic inspections associated with the jet pump assemblies. The  ;

temporary removal of core shroud repair hardware adjacent to JP 7/8 can only be done in plant Mode 5 or defueled and the shroud will not be subjected to a differential pressure.

Therefore, a different type of equipment malfunction or new accident / transient will not be created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because the jet pump riser clamp will not interfere with flow through the riser orjet pumps.

Monitoring capabilities associated with JP 7/8 are not comprised. Core geometry is not adversely affected by withdrawal / insertion of a single control rod with the core shroud repair hardware in the vicinity of JP 7/8 removed during clamp installation. Therefore, margin of safety is not reduced.

Tracking No. SS-H-99-0085 Activity No. QCMMS 1500-01 Rev.15 DESCR1~PTION; Revision to QCMMS 1500-1 Revision 15, " IST RELIEF VALVE SET POINT TESTING" to include the 1-1299-87 Relief Valve and revise the cold set point on the 2-1299-87 relief valve.

SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because the inclusion of relief valve in the IST surveillance program does not Attachment A, SVP-99-102, Page 53 of 57

• 1

/'  !

increase the probability of an accident or malfunction. The testing program is performed in the shop with the relief valve removed from the system. j

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the relief valve testing is performed offline. This does not create any new type of accident that has not previously been evaluated.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because no margin of safety is affected since the testing is performed offline.

I Tracking No. SS-H-99-0086 i Activity No. Various QCOP and QCOS 1300 Block Procedures; SE-98-078 DESCRIPTION:

Have revised the following procedures to address the pump discharge valve position being reversed from normal lineup on Unit 2 to accommodate back-leakage through 2-1301-49 and 2-1301-50:

QCOP 1300-01, REV,11 QCOP 1300-02, REV.14 QCOP 1300-09, REV.10 QCOS 1300-01, REV 22 I QCOS 1300-05, REV. 21 QCOS 1300-07, REV.12 l QCOS 1300-10, REV. 6 QCOS 1300-11, REV. 6 QCOS 1300-13, REV.10 QCOS 1300-22, REV. 3 SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because RCIC is designed to li:ait the results of accidents by providing cooling water to the reactor and to aid in pressure control during an event. The automatic functions of the pump discharge and system isolation valves will not be affected. During an initiation, both discharge valves receive an open signal. During manual startup, the operator ,

is directed to open both discharge valves. I

2. The possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because the function of RCIC is to mitigate accidents by providing cooling to the reactor and to assist in pressure control during an event. These procedure changes will not affect the RCIC ability to perform that i function; therefore, these changes will not create any new accident or a malfunction of a different type than any previously evaluated accident.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because there is no reduction in the margin of safety because the RCIC will still perform its designed function. All surveillance requirements pertaining to pump flows and pressures Attachment A, SVP-99102, Page 54 of 57

,4 will still be met. The ventirig process will be slightly altered to not only verify flow will be j verified from the high point vent but also a pressure will be monitored to verify the I discharge piping is full of water.

)

Tracking No. SS-H-99-0090 Activity No. DCP 9900078; TMOD 99 2-0088; SE-98-086 DESCRIPTION:

Change the Unit 2 RCIC line-up such that MO 2-1301-48 is normally closed and MO 2-1301-49 is normally open until MO 2-1301-49 and MO 2-1301-50 are repaired.

S AFETY EVALUATION SLMMARY:

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not j increased because the change does not affect the ability of the RCIC system to mitigate the consequences of an accident within the design time requirements; therefore, this design change will not increase the probability of occurrence or consequences of an accident  ;

previously evaluated. 1

2. The possibility for an accident or malfunction of a different type than any evaluated ,

previously in the safety analysis report is not created because the change to the RCIC j System stand-by line-up has no impact on the system design functions. The 2-1301-48 valve has been verified to be an acceptable isolation (injection) valve for the system and the system integrity is maintained. There are no components added or removed so no new ,

failure modes have been created.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because this change to the RCIC System stand-by line-up has no impact on the system design functions. Technical Specification 3/4.D, Reactor Core Isolation Cooling System and 3/4.2.D, Reactor Core Isolation Cooling Actuation are not affected by this DCP.

Tracking No. SS-H-99-0091 Activity No. QCOS 5750-05 Rev. 5; SE-98-074

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DESCRIPTION-Revise direction to allow for 1(2)-3999-570, HPCI ROOM COOLER SERVICE WATER SUPPLY HEADER UPSTREAM STOP VALVE, to be left in either the open or closed position.

Attachment A, SVP-99-102, Page 55 of 57

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SAFETY EVALUATION

SUMMARY

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1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because Service Water is not relied upon to function during an accident. If the referenced valve is closed, flow from the EDG Cooling Water system to Service Water can not occur. If the referenced valve is open, an unanalyzed flow path can not occur due to a check valve installed as a result of DCP 9800181 (9800182), the safety function of which is to close. This prevents a flow path from the EDG Cooling Water system to Service Water.

2. The possibility fc r an accident or malfunction of a different type than any evaluated previously in the safety analysis report is not created because as stated in item 1, whether j the referenced valve is open or closed, a flow path from the safety-related EDG Coohng  ;

Water system to the non-safety-related Service Water system will not occur. i l

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because all changes to the parameters or conditions used to establish the Technical Specification requirements are in a conservative direction.

Tracking No. SS-H-99-0113 Activity No. DCP 9600434; UFSAR-97-R5-100; SE-98-112; SS-H-98-0233 DESCRIPTION:

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This validation is being issued to validate the subject evaluations (SE-98-112 and SS-H-98-0233) without a future licensing amendment. The revision does not affect the safety question responses, but removes the stipulation for a future licensing amendment. SE-98-112 safety evaluation identified an issue concerning the inclusion of new Reactor Water Cleanup (RWCU) Primary Containment Isolation (PCIS) instrumentation with that of similarly licensed PCIS instrumentation currently in the Technical Specidcations. The new instruments made the plant more conservative; therefore, a chrage to the Technical Specifications was not mandatory for installation or Operation Authorization. Following installation, Regulatory Assurance issued a position paper on why a licensing amendment was not required under letter CCP-98-017. Design Engineering letter Q-ECDS-98-0452 for DCP 9600434 stated that a Technical Specification change was not required per Regulatory Assurance. The Administrative Technical Requirements contained in QCOS 1600-i

. 06 provide adequate controls for this instrumentation. The method chosen for operability cotrol of this PCIS-related instrumentation is included in the UFSAR per UFSAR-97-RS-100 tracking I numberi SAFETY EVALUATION

SUMMARY

1. The probability of occurrence or the consequences of an accident or a malfunction of equipment important to safety previously evaluated in the safety analysis report is not increased because operation of high temperature automatic isSation components and Attachment A, SVP-99-102, Page 56 of 57 c

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hardware does not have any impact on the integrity of the RWCU piping system. The high j area temperature automatic isolation trip system will allow rapid detection and isolation of I the RWCU system and subsequently, reduce the consequences of a RWCU HELB outside of primary containment. The design of modification (DCP 9600434) provides for isolation of RWCU within the time constraints of the existing analysis.

The plant design change has inte faces with existing PCIS ' logic for Group 1 and Group 3 )

valves. Logic circuits have been designed to fail safe assuring that malfunction of new components would not prevent safe operation of equipment important to safety. Interfaces <

l are with existing relays' circuits which does not introduce additional failure modes of the PCIS relays.

The high temperature automatic isolation logic will function to increase the reliability of l equipment important to safety and minimize the reliance on manual operator action. the l design change provides greater assurance that under a RWCU HELB condition that l environmental qual 'ication conditions for equipment important to safety will be j maintained. This validation does not affect the response to these questions. l

. 2. The possibility for an accident or malfunction of a different type than any evaluated j previously in the safety analysis report is not created because installation of high  !

temperature automatic isolation circuitry is intended to reduce reliance on operator action in l the event of a RWCU HELB. The new system has been designed and qualified as a Class 1 1E installation. The new system is single failure proof, fail safe, and functions I independently from other plant controls and instrumentation. As a result, no new plant accidents are introduced by this plant design change. There are no new types of activities or new functions than that identified in the previously evaluated activities (DCP 9600434, QCOS 1600-06 procedure revision, and UFSAR change 97-R5-100). The difference is that SE-98-112 and SS-H-98-0233 were indicating a licensing amendment was in the future.

The SS-H-98-0233 activity addresses the Administrative Technical Requirements required to ensure the new instrumentation is maintained in a condition that is considered operable when the plant conditions require it to be. This validation states that these controls are adequate, and a licensing amendment is not required.

3. The margin of safety, as defined in the basis for any Technical Specification, is not reduced because Technical Specification Section 3/4.2.A, Isolation Actuation, requires isolation of RWCU in the event'of an 8" RPV water level signal. This protection is not altered by the installation of high temperature automatic isolation circuitry. The protection is enhanced by providing automatic isolation of RWCU on high temperature in areas containing RWCU High Energy piping.

Attachment A, SVP-99-102, Page 57 of 57

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