ML18016A973

Changes,Tests & Experiments, for Harris Nuclear Plant.Rept Provides Brief Description of Changes to Facility & Summary & of SE for Each Item That Was Implemented Under 10CFR50.59 Between 970608-981128.With 990527 Ltr

ML18016A973
Person / Time
Site:	Harris
Issue date:	11/28/1998
From:	Alexander D CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-99-086, HNP-99-86, NUDOCS 9906040056
Download: ML18016A973 (360)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9906040056 DOC.DATE: 99/05/27 NOTARIZED NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina DOCKET ¹ 05000400 AUTH. NAME AUTHOR AFFILIATION ALEXANDER,D.B. Carolina Power &. Light Co.

RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Con rol Desk)

SUBJECT:

"Changes, Tests & Experiments," for Harris Nuclear Plant. Rept provides brief description of changes to facility & summary

& of SE for each item that was implemented under 10CFR50.59 between 970608-981128. A DZSTRZBUTZON CODE: ZE47D CORTES RECEZVED:LTR TITLE: 50.59 Annual Report of Changes, Tests L ENCL i SZZE:

or Experiments Made DO W/out Approv E

NOTES:Application for permit renewal filed. 05000400 G

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LPD2-2 PD 1 0 LAUFER,R. 1 1 R INTERNAL: ACRS 1 1 LE CE 1 1 RGN2 II FILE 01 1 .1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRZBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATIONi CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 7 ENCL 6

Carolina Power & Ugbt Company Harris Nuclear Plant P.O. Box 165 New Hill NC 27562 SERIAL: HNP-99-086 MAY 27 1999 10 CFR 50.59(b)(2)

United States Nuclear Regulatory Commission ATTENTION:Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REPORT OF CHANGES PURSUANT TO 10 CFR 50.59

Dear Sir or Madam:

'n accordance with 10 CFR 50.59(b)(2), Carolina Power & Light Company hereby submits the report of "Changes, Tests and Experiments," for the Harris Nuclear Plant. The report provides a brief description of changes to the facility and a summary of the safety evaluation for each item that was implemented under 10 CFR 50.59 between June 8, 1997 and November 28, 1998 (end of RFO 8). Additionally, some changes implemented after November 28, 1998 are also included in this rcport.

Questions regarding this matter may be referred to Mr. J. H. Eads at (919) 362-2646.

Sincerely, D. B. Alexander Manager, Regulatory Affairs Harris Nuclear Plant

/

MGW Enclosure c: Mr. J. B. Brady (NRC Senior Resident Inspector, HNP)

Mr. Rich Laufer (NRR Project Manager, HNP)

Mr. L. A. Reyes (NRC Regional Administrator, Region II) 9906040056 990527 PDR ADQCK 05000400 R PDR 5413 Shearon Harris Road New Hill NC

PCR-6966 RAF 0 2549 Title: Blanket-Type Thermal Insulation For Use In Containment

~Descri tion; This FSAR change revises sections 5.2.4.2.7 and 6.2.2.2.2.2 to indicate that metallic reflective insulation inside containment may be replaced on a one-for-one basis with fiberglass blanket insulation.

Safet Summar PCR-6966, Revision I, evaluates the acceptability of using blanket-type insulation within the Containment Building. Use of fiberglass blanket insulation cannot initiate an accident. The insulation will not block sump screens. Attachment of the insulation will be seismically qualified. The original function of the metallic reflective insulation is maintained when replaced with fiberglass blanket insulation. The type of insulation used inside containment does not impact the ability of safety related systems or components to perform their safety functions. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SEJM N/A RAF 2471 Title: ESR 94-00220, EDBS Update for Refueling Machine

~Descri tion:

This ESR evaluates the quality classification of the reactor cavity manipulator crane (refueling machine). The components of the manipulator crane are listed as Q-Class A, B, and E in the Harris Plant Engineering Data Base System (EDBS). CAR-2165-A-OOl, Classification of Structures, Systems,'nd Components (Q-List), indicates the manipulator crane as safety class NNS and Quality Class E. Section 9.4.1 of the FSAR states that the manipulator crane will not collapse, become derailed, or allow disengagement of a fuel assembly as a result of the safe shutdown earthquake (SSE). The dropping of a spent fuel assembly in the containment building is a credible accident and is evaluated in FSAR section 15.7.4. Several modifications have been made to the manipulator crane since original installation to improve the safety and reliability of fuel handling operations. Based on review of information from the crane manufacturer, supplier, and the applicable design back-up documents, the Q-list and FSAR Table 3.2.1-1 are being updated to reflect that the manipulator crane as Quality Class B.

~Sh S Based on the review performed, the refueling cavity manipulator crane is non safety related seismically designed. Revising the Q-List and FSAR Table 3.2.1-1 to indicate the manipulator crane as Quality Class B will provide consistency between these documents and other design information. This activity does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

ESR 94-00290 RAF 2484 Title: ESR 9400290, Emergency Service Water System (ESWS) Flow Diagram Revision

~Descri tion:

ESR 9400290 provides the basis for changing the position of the Charging and Safety Injection Pump (CSIP) cooling water inlet and outlet isolation valves. The previous valve alignment created a cross-connection of the ESWS "A" and "B" trains which could result in loss of both trains due to "A" train ESW return valve to the auxiliary reservoir (1SW-

. 270) failing to automatically open during an ESW actuation. The present alignment will prevent this scenario by closing the opposite train inlet and outlet isolation valves to the CSIP coolers. The flow diagrams and active valve list are revised accordingly.

I~If ~

The ESWS is not an accident initiating or mitigating system. The changes made in the valve alignments will prevent cross-connection of ESWS trains and violation of single failure criterion. By preventing cross-connection of trains "A" and "B", failure of 1SW-270 will not result in a loss of CSIPs. This change in valve alignment does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus,

~ no unreviewed safety question exists.

ESR 9400528 RAF 2485 Title: Removal of Valve 3SW-V369SN From Active Valve List

~Descri tion:

The subject of this evaluation is a correction to FSAR Table 3.9.3-14 "Non-NSSS Supplied Class 1, 2, and 3 Active Valves." Active valves are defined as those valves requiring mechanical motion in performing a safety function. Service Water System Check Valve 3SW-V369SN is removed from the list of active valves since this valve functions as a back-up isolation valve upon start of a Emergency Service Water Pump and is not credited as a containment isolation valve in the analysis.

S~S Valve 3SW-V369SN is not tested and is not credited as an isolation valve.

3SW-V369SN functions as back-up isolation for motor-operated valve 3SW-BSSA (3SW-B6SA) Failure of the 3SW-V369SN valve coincident with a single failure of 3SW-BSSA (3SW-B6SA) will only disable one train of the Emergency Service Water System. Removing this valve from the active valve list does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

0 ESR 95-00818 RAF 2483 Title: ESR 9500818, Screen Wash Pump Check Valve Elimination

~Descri tion:

ESR 9500818 removed the disk and hinge from Emergency Service Water (ESW) Screen Wash Pump Discharge Check Valves 3SC-V33SB and 3SC-V28SA. These valves were experiencing premature wearout of the hinge bearing area believed to be related to general corrosion and low flow rate conditions. These valves have no backflow function.

As such, these valves are being, removed from FSAR Table 3.9.3-14 "Non-NSSS Supplied Class 1, 2, and 3 Active Valves."

s~s In the case of Valves 3SC-V33SB and 3SC-V28SA, there is not a normal source of back flow pressure since there is no parallel pump or other source of high pressure downstream of the check valve that is safety-related. Adequate suction pressure is available during all operating conditions to keep the ESW Screen Wash Pump filled and primed. Elimination of the check valve function will not affect or degrade the safe operation of the system or any equipment important to safety. Removal of the internals of these two check valves does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

RAF ¹ 2504 Title: ESR 95-00173, Boron Recycle System Reclassification

~Descri sion:

ESR 95-00173 reclassifies the Boron Recycle System (BRS) including the recycle evaporator feed pumps from Safety Class 3 to non-nuclear safety (NNS). The original code classification is ASME Section III, Class 3 and the new classification is ANSI B31.1. Some portions of the system will remain seismic supported since the downgraded piping are connected to safety class piping. The Component Cooling Water (CCW)

System piping which ties into the recycle evaporator feed package remains safety class to maintain CCW safety system capability.

S~fS

~I The function, operation, and failure mechanisms of the BRS are not being changed. The BRS is not required for any operational mode and is not an accident mitigating system nor is it considered an initiating system. The BRS serves to recover boric acid from the Reactor Coolant System letdown. Plant procedures are in place to control the quality of the boric acid that may be transferred to the Boric Acid Storage Tank from BRS following evaporation of a batch. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 96-098 Rev. 1 RAF 2499 Title: ESR 94-00543 Rev. 2, Waste Processing Computer

~Descri tion:

The Waste Processing Computer System will be replaced per ESR 94-00543. This will be a direct replacement of the existing computer system.

Safet Summar The Waste Processing Computer performs monitoring and display functions. It does not perform any control functions, and does not interact with any safety related system. The computer replacement will not impact the performance of systems or components assumed in the FSAR Chapter I I analysis that demonstrates compliance with IO CFR 50, Appendix I. Disabling various field inputs during the modification will not have an adverse impact on the plant's waste processing capabilities. The installation of the new Waste Processing Computer will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 8 96-191 RAF 2187 Title: ESR 96-00204, Rev. 0, Setpoint Change for TS-01A V-6596

~Descri tion:

This FSAR change revises Section 9.4.5.2.2 to correctly identify room A297 rather than A296 as the room cooled by ACC-I/FCC-I.

S~fS The SE for this FSAR change is associated with an ESR for changing the operating setpoints for ACC-I/FCC-1. These changes affect the low setpoint in such a manner as to increase its reliability. Furthermore, ACC-I/FCC-I is a non-safety related system having no impact on accident mitigation capabilities. The actual FSAR change is editorial in nature and is consistent with the pant Technical Specifications. Therefore, the described change to the FSAR does not introduce an unreviewed safety question.

SE 0 96-269 Rev. 1 RAF 2588 Title: ESR 96-00025, Replacement of Emergency Service Water Pumps

~Descri tion:

ESR 96-00025 replaces the two existing Emergency Service Water {ESW) pumps with higher capacity pumps. The higher capacity is achieved through the use of a two stage pump rather than the single impeller original design. The higher capacity results in the usage of approximately 50 additional horse power {HP). ESR 96-00025 also installs vibration monitoring equipment.

Appropriate changes are made to FSAR Sections 9.2.1, 3.9.3, and 3.9B to reflect the new pump model and design characteristics.

S~fS The new ESW pumps are equal to or better in form, flit, and function when compared to the replaced pumps. The new pumps will continue to operate under the same controls as the previous pumps, but with a higher capacity. The increase in HP usage has a negligible impact on the electrical distribution system. The start-up time for the pumps is not impacted. Two independent trains of ESW will continue to be available. Changes to the pumps and lower seismic supports were evaluated in the seismic reconciliation report. Materials of construction are equal to or better than the replaced pumps for the application. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.,

SE ¹97-071 RAF 2445 Title: ESR 9500278 Installation of BWR Spent Fuel Racks

~Dmcri tion:

This change to FSAR Table 9.1.2-1 and Figures 1.2.2-55 and 9.1.1-2 modifies the number of BWR Spent Fuel Racks and the location of the inspection area in Spent Fuel Pool (SFP) "B". ESR 9500278 installs seven additional 11x11 BWR spent fuel racks in SFP "B". Additional storage capacity is required in order for the HNP to accept and store spent fuel from BNP.

SSf SS The spent fuel racks are designed to maintain the stored spent fuel in a subcritical condition. This change will be in accordance with design criteria previously established in fuel accident analysis. This change will not alter or modify fuel handling equipment. This change was evaluated for impact on adjacent racks, spent fuel cooling, TS compliance and Fuel Handling Building ventilation. As a result of this evaluation, this change was determined to be acceptable. Therefore, this change does not increase the probability or consequences of an accident or equipment malfunction. It cannot create a new or different type of accident or equipment malfunction, and it does not impact the margin of safety as defined in the bases of any technical specification. Thus, no unreviewed safety question exists.

SE ¹97-075 Rev. I RAF ¹ 2512 Title: ESR 97-00148 Rev. 3, Temporary Air Compressor

~Descri tion:

The activity evaluated is the addition of a permanent isolation valve in the Compressed Air System and the use of a temporary air compressor as a back up to the plant's installed air compressors. The compressor will be tied into the non-safety Compressed Air System at a flanged connection designed for a temporary air compressor.

Safet Summar The Compressed Air System is a non-safety system and is not required for safe shutdown of the plant. The installation of the isolation valve and the use of a temporary air compressor will not change the operation or function of the'Compressed Air System. The reliability of the system is enhanced and is protected from a temporary air compressor failure by a check valve at the system connection. This activity does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 97-167 Rev. l RAF 2556 Title: ESR 97-00237 Rev.l "Permanent Removal of Power from Dampe'rs AC-DSSB-1 and AC-D3SA-1

~Deseri non:

This ESR will permanently remove power from dampers AC-D5SB-1 and AC-D3SA-1 to ensure that the Control Room is capable of being pressurized to the Technical

~~

Specification required 1/8 inch water gauge positive pressure.

~S~S The proposed activity involves revising the FSAR to reflect the permanent removal of power from dampers AC-DSSB-1 and AC-D3SA-1 to ensure that the Control Room is capable of being pressurized to the Technical Specification required 1/8 inch water gauge positive pressure. This FSAR revision will not prevent any safety-related structures, systems or components from performing there intended safety function and will have.no adverse impact on safe plant operation (dampers are failed closed). This revision does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹97-236 RAF ¹ 2384 Title: ESR 9600424, Installation of Test Fittings in the Chemical and Volume Control System (CVCS)

~Descri tion:

ESR 9600424 installs test fittings, replacing the existing pipe caps, on non-nuclear safety drain lines and valves in the CVCS system. During performance of surveillance testing have been encountered with the NPT connections (pipe caps) used for test 'eaks equipment. To stop the leakage excessive force had to be utilized on the threaded connections which had the potential to damage the threaded connections and piping. The new test connections will minimize the leakage of potentially contaminated fluids and eliminate the potential of damaging pipe threads.

Safet Summar The replacement of the pipe caps with new test connections will minimize the leakage of potentially contaminated fluids and eliminate the potential of damaging pipe threads. The pipe caps on the non-nuclear safety drain lines and valves do not function as a pressure boundary. The materials used in the installation of the new test connections have been evaluated and are acceptable for the associated temperatures and pressures. The piping systems and supports have been evaluated for additional weight and stresses and were found to be acceptable per code requirements. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the. Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 97-238 RAF 2477 Title: ESR 96-00376, Relocation of Flow Elements in RAB Emergency Exhaust System

~Descri tion:

ESR 96-00376 relocates flow elements to the suction side of the Reactor Auxiliary Building (RAB) emergency exhaust fans E-6A and E-6B. The new locations are more suitable for the flow elements and the bleed flow will be eliminated from the total flow.

FE-4842A will be relocated to just upstream, of the filtration unit inlet isolation valve, 3AV-B1SA-1. FE-4842B will be relocated to upstream of the filtration unit inlet isolation valve, 3AV-B4SB-1.

~ SfS The new locations for the flow elements on the suction side of the RAB emergency exhaust fans E-6A and E-6B will provide more accurate flow indications and will eliminate the bleed flow from the total flow. These changes to the RAB Emergency Exhaust System will not effect or adversely impact the safety function to limit post-accident radiological releases from selected potentially contaminated portions of the RAB if required. Therefore, this modification does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹97-244 RAF 2580 RAF 2581 RAF 2582 Title: ESR 95-01000, AH-86 Cooling Coil Abandonment

~Descri tion:

ESR 95-01000 will permanently isolate the Emergency Service Water (ESW) System and the Cooling Tower (CT) Make-up System piping from the ESW Intake Structure Electrical Equipment Room Air Handling Units (AHUs). ESR 96-00284 provided the evaluation and document changes to isolate the ESW and CT Make-up flow to the ESW Intake Structure Electrical Equipment Room AHUs with locked closed manual valves.

ESR-01000 removes the piping and components that supplied the cooling water that ESR 96-00284 valved out of service.

~Sf S ESR 95-01000 makes no changes to the function of the AH-86 air handlers not already in place from ESR 96-00284. The pipe closure devices (flanges and welded fittings with plugs on the 30" diameter ESW headers) are manufactured and will be installed to the same codes and standards as the rest of the ESW System. This modification will meet the design, material and construction requirements for Safety Class 3 piping where required.

The physical integrity of the ESW pressure boundary is not adversely impacted. The deletion and/or sparing of the associated electrical control circuitry will have no adverse impact. This modification does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹ 97-'754 Title: ESR 95-00433, Safe Shutdown Analysis Calculation Revisions

~Descri tion:

The activity evaluated is ESR 95-00433 which revises the HNP Safe Shutdown Analysis (SSA) to incorporate the resolution of various open items to ensure that adequate separation has been maintained between shutdown divisions. An extensive review of the HNP SSA was performed and this safety evaluation analyzes the resulting documentation changes. The resolutions to the open items are addressed by the following methods:

1. Revision to SSA calculations and flow diagrams to address the required separation and shutdown methodology consistent with HNP safe shutdown licensing commitments.

2. Revision to procedures to identify new operator actions and provide clarity in the procedure consistent with safe shutdown methodology.

3. Identification of a new modification to install fire protective wrap on two conduits to ensure adequate separation of safe shutdown components.

The resolutions are in compliance with the existing plant licensing basis.

The revision to the SSA and operational procedures utilizes current safe shutdown criteria and methodology for the open item resolutions. The safe shutdown capability and the required separation of safe shutdown components have not been impacted due to this analysis. The equipment that was analyzed and added to the SSA provides the required safe shutdown capability for a fire scenario in given fire area/zone. The routing of cables and raceways was analyzed to ensure that the components meet the separation requirements of BTP CMEB 9.5-1.

The selected equipment and methodology required to maintain safe shutdown capability will not increase predicted radiation levels as evaluated in the SAR. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-259 Title: PEP-400, Supplemental Procedure, Revision 3

~Descri tion:

The activity evaluated is Revision 3 to PEP-400, "Supplemental Procedure" for emergency preparedness. This procedure addresses emergency preparedness reviews, record keeping and documentation, logkeeping, and maintaining readiness of emergency facilities. This revision makes editorial changes and also provides clarification that an emergency preparedness modification review may be performed within the criteria of an Engineering Service Request (ESR) impact review.

~Sf S The activity evaluated is an enhancement to engineering review of emergency preparedness related systems. No changes to the facility are being made. Conservatism is introduced to the ESR process by evaluating for emergency preparedness impact. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

0 SE 0 97-262 Title: PEP-440, Public Notification and Alerting System, Revision I

~Descri tion:

The activity evaluated is Revision l to PEP-440, "Public Notification and Alerting System."

This procedure provides instructions for: (I) maintaining the tone alert radio receiver program, and (2) scheduling, testing, documenting, and reporting on the performance of the Harris siren system. This revision made editorial changes, added training requirements, and added the siren program.

8~IS The addition of the Harris siren program to the procedure is a program enhancement. The sirens and their mode of activation are off-site. The purpose of the sirens is for public notification in the case of an emergency. No facility changes are being made, and no tests or experiments are involved. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no

'nreviewed safety question exists.

SE ¹97-263 Title: PEP-340, Radiological Assessment, Revision 4

~Descri tion:

The activity evaluated is Revision 4 to PEP-340, "Radiological Assessment." This procedure provides instructions for calculating projected off-site doses due to actual or potential radiological releases and for calculating the extent of damage to the reactor fuel. This revision includes editorial changes and clarification or additional guidance for the following:

streamlining control room use, radiation monitor information, sources of weather information, and dose projection viewing.

S~S This activity is an enhancement to the dose assessment process. No facility changes are being made, and no tests or experiments are involved. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE N 97-264 Title: PEP-240, Activation and Operation of the Technical Support Center, Revision 2

~Descri tion:

PEP-240 provides guidance to the various Emergency Response Organization (ERO) positions located in the Technical Support Center (TSC) during a declared emergency.

Revision 2 of this procedure adds checklists for the TSC ERO, TSC ERFIS Operator, EC-NRC and TSC Log Keeper. This revision also has reformatted the presentation of the checklists to minimize duplication of instructions and enhance the organization of reference material.

Safet Summar The additional guidance provided in PEP-240, Revision 2 should decrease the probability of a communication error during an emergency situation. No plant equipment is modified or added by this procedure revision. The changes to PEP-240 have been determined to have no impact on the probability or consequences of an accident or equipment malfunction. Safety related equipment is not directly addressed in this procedure. The personnel impacted by the procedure revision have no direct control of, nor are specifically instructed to interact with, any safety related equipment. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-265 Title: PEP-260, Activation and Operation of the Operations Support Center, Revision 2

~Descri tion; The activity evaluated is Revision 2 to PEP-260, "Activation and Operation of the Operations Support Center." This procedure specifies the actions to be taken by emergency response organization personnel who report to the Operations Support Center (OSC). This revision provides additional guidance for personnel working in the OSC. Specifically, the changes in this revision include: (1) upgraded checklists to minimize duplication of instructions, enhance organization of reference materials, and provide additional guidance and (2) added checklists for positions in the OSC that did not previously have guidance.

S~S This procedure specifies the function and responsibilities of the OSC as described in the safety analysis report. The OSC function is to mitigate the consequences of a declared emergency.

This revision enhances facility response and further clarifies roles and responsibilities. Facility location and equipment does not change as a result of this procedure revision. No tests or experiments are involved. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-268 Title:, PLP-201, Emergency Plan, Revision 31

~Desert tion; The activity evaluated is Revision 31 to PLP-201, "Emergency Plan." This revision reflects numerous changes and improvements made to the emergency preparedness program.

Specifically, the changes include: various editorial changes, minimizing the description of responsibilities for the majority of the emergency response organization (ERO) positions, a rewrite of the recovery section, modifying general information related to agreements with external organizations, and changes to more accurately reflect the guidance provided in EPA-400. Programmatic and procedural changes have been made to improve the ability of the ERO to determine protective action recommendations during emergency events.

~S ~

The facility as described in the safety analysis report is not effected. This revision to the Emergency Plan does not incorporate any additions, deletions, or modifications of plant equipment. The changes do not expand, delete or reassign responsibilities for any ERO position and will result in an overall improvement in the ability of the ERO to effectively determine and issue protective action recommendations and transition from an emergency into recovery. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-271 Title: PEP-270, Activation and Operation of the Emergency Operations Facility, Revision 3

~Desert tien:

The activity evaluated is Revision 3 to PEP-270, "Activation and Operation of the Emergency Operations Facility." This procedure specifies the actions to be taken by emergency response organization (ERO) personnel who report to the Emergency Operations Facility (EOF). This revision provides additional guidance for personnel working in the EOF. Specifically, the changes in this revision include: (1) upgraded checklists to minimize duplication of instructions and enhance organization of reference materials, (2) additional checklists for positions in the EOF that did not previously have guidance, (3) guidance for the emergency response manager position addressing control of overtime in emergencies and the use of the event information worksheet.

S~S This procedure revision provides additional guidance and reorganizes the EOF checklists. There is no impact on the facility as described in the safety analysis report. EOF personnel do not control plant systems, equipment or provide direction to the plant staff responding to a declared emergency. This procedure does not address tests or experiments. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-272 Title: DBD-301, Reactor Control and Protection System, Revision 1 II ~

~Descri tion:

The activity evaluated is Revision I to DBD-301, "Reactor Control and Protection System."

Revision 1 to this design basis document includes: changes to ensure consistency with the FSAR, Technical Specifications, and vendor manuals; inclusion of a modification concerning reactor temperature control; revision of exceptions for minimum cable separation in certain areas; and updates to documents and references.

~Sf S The cable separation condition of the reactor trip switchgear and solid state protection system logic cabinets and the other changes to system descriptions included in this activity are consistent with the FSAR. Updates to the control and protection system setpoint documentation include documents that have been previously evaluated per 10 CFR 50.59. No tests or experiments are involved. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-273 Title: ESR 95-00278, Additional Four BWR Racks for Pool B, Revision 2

~Descri tinn:

The activity evaluated is Revision 2 to ESR 95-00278 which provides structural details for temporary access platforms attached to the spent fuel bridge. crane to support fuel rack installations. The temporary platforms will allow riggers to be positioned on the north side of the bridge crane and over the racks when the racks are lowered and positioned in the spent fuel pool.

After the racks are installed, the temporary platforms are removed. The installation and removal of the temporary platforms are controlled by procedure.

s~f'n ESR95-00278 Rev. 2 does not make changes to any fuel handling equipment nor to any equipment used for accident mitigation. The temporary access platforms do not adversely impact the seismic qualification or function of the spent fuel bridge crane. The platforms are designed so that they will not fail during a seismic event resulting in components falling into the spent fuel pool and on to spent fuel. The loading on the spent fuel bridge crane due to th'e temporary access platforms is less than the rated load for the crane. Fuel handling tools and spent fuel assemblies are not suspended from the access platforms, and when the platforms are installed, no loads may be suspended by the spent fuel bridge crane hoist. The temporary access platforms have no impact on the function of the spent fuel pool cooling or spent fuel storage systems. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-275 Title: PEP-250, Activation and Operation of the Joint Information Center, Revision 6

~Descri tion:

The activity evaluated is Revision 6 to PEP-250, "Activation and Operation of the Joint Information Center". This procedure specifies actions to be taken by emergency response organization personnel who report to the Joint Information Center (JIC). This revision to PEP-250 includes: (I) added guidance for news media briefing protocol, (2) added guidance for telephone response to the media and public, (3) relocation of the technical specialist guidance to another procedure, and (4) format changes.

s~s The function of the JIC is to provide information to the media and public during a declared emergency at HNP. The JIC personnel have no influence over plant systems, equipment or onsite staff response to a declared emergency. This revision does not make changes to the facility as described in the safety analysis report, and it does not involve tests or experiments.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-277 Title: PEP-500, Recovery, Revision 8

~Descri iion:

The activity evaluated is Revision 8 to plant emergency procedure PEP-500, "Recovery'. The purpose of this procedure is to provide guidance for the transition into, conduct of operations while in, and termination of the recovery phase of a classified emergency event involving implementation of the HNP Emergency Plan. Revision 8 modified the procedure to provide additional guidance for key decision makers in the emergency response organization.

Specifically, this revision includes: (I) separation of recovery actions for events classified as unusual events from those for the more elevated classifications, (2) more specific guidance on making the transition from the emergency phase of the event to the recovery phase, (3) enhanced guidance for the emergency response organization to use in development of a recovery plan.

Safety Summary:

The activity evaluated does not incorporate any additions, deletions, or modifications to plant equipment. The procedure does not provide direction to emergency response personnel regarding the control of plant systems or equipment, and does not involve tests or experiments. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-282 Title: PEP-110 Revision 3, Emergency Classification and Protective Action Recommendations D~escri tion:

The activity evaluated is Revision 3 to PEP-110, Emergency Classification and Protective Action Recommendations, which upgrades the Protective Action Recommendation process by adding an "Event Information Worksheet" attachment and provides clear linkage between PEP-110 and PEP-500 "Recovery" action steps. Specifically, this change revises the Protective Action Recommendation process to be compatible with the guidance of NUREG-0654, Supplement 3 to address determining plant based Protective Action Recommendations out to 10 miles. This revision also added guidance for developing recommendations when protective Action Guideline thresholds are exceeded beyond 10 miles. This revision incorporates an "Event Information Worksheet" to be used by all facilities for turnover and briefing purposes and added guidance and instructions for the process of terminating from an, emergency and transitioning into a recovery phase.

S~hS Procedure PEP-110 provides guidance and instruction to the HNP ERO members for establishing the proper emergency classification level and Protective Action recommendations to be issued to the State of North Carolina and the four EPZ counties during an actual declared emergency at HNP. As such, the affected procedure does not direct HNP ERO personnel in the control of plant systems, equipment or provide direction to the plant staff responding to a declared emergency.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-283 Title: PEP-330 Revision 2, Radiological Consequences

~Descri tion:

The activity evaluated is Revision 2 to PEP-330, Radiological Consequences, which removes guidance to the Environmental Monitoring Teams for encoding the old obsolete radios. The radios have been upgraded with new Motorola radios which have been appropriately evaluated for site use.

S~PS The upgrade of the radios used in communicating during an emergency is considered to be an enhancement in the area of communications. Removal of obsolete information from PEP-330 will decrease the probability of a communication error. The radios are not safety related equipment. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction; The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-289 Title:, PEP-350 Revision 3, Protective Actions

~Descri tion:

The activity evaluated is Revision 3 to PEP-350, Protective Actions, which adds guidance to personnel performing accountability of the TSC, CR, and OSC during a declared emergency.

S~PS This change does not involve, either directly or indirectly, safety related equipment nor does it direct personnel in the operation of safety related equipment. This procedure enhancement should provide improved productivity of the TSC, CR and OSC organizations with more concise and clear instructions and will decrease the probability of a communication error. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ff 97-291 Title: PEP-230 Revision 1, Control Room Operations

~Descri tion:

The activity evaluated is Revision 1 to PEP-230, Control Room Operations. The changes being made provide consistency in procedure format and content with changes made to related emergency plan implementing procedures. Guidance is added for the SEC-CR in the use of the Event Information Worksheet in the conduct of turnover and briefings.

~Sf S This procedure directs actions not involving plant equipment, systems, or components, other than communications equipment which is non-safety related. As such, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-295 Title: EPT-250, A Train Emergency Service Water (ESW) Flow Verification/Balance, Revision 5

~Descri tion:

The activity evaluated is Revision 5 to EPT-250, "A Train ESW Flow Verification/Balance".

This procedure provides instructions for performing an ESW flow verification and balance for the entire A Train ESW system and/or individual A Train components. This procedure revision incorporates new acceptance criteria as defined by a revision to a calculation.

I~IS This change does not affect the design, function or method of performing a function as described in the FSAR. The revised acceptance criteria ensure an acceptable flowrate of cooling water is provided to associated safety related heat exchangers to ensure the required heat removal capabilities are maintained. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-296 Title: EPT-251, B Train ESW Flow Verification/Balance, Revision 5

~Descri tion:

EPT-251, "B Train ESW Flow Verification/Balance" is revised to change the acceptance criteria for proper ESW flow to the associated components served by ESW. The new acceptance criteria incorporates Revision 5 of calculation SW-0080, and eliminates the position check for the strainer backwash manual valve.

~Ht S The revised acceptance criteria in EPT-251 ensures an acceptable cooling water flow rate such that each associated heat exchanger is able to perform its respective mitigating function. The required heat removal capabilities of the ESW system are maintained by this change. EPT-251, Revision 5 ensures that margins are maintained by verification that the minimum required flow is provided to the associated components. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹97-297 SE¹97-324 RAF ¹ 2619 Title: ESR 97-00648 Rev. 0 and Rev. 2, Safe Shutdown Cable Protection

~DeSCri tioSS:

Engineering review determined that two cables required for safe shutdown of the plant did not have adequate protection from an area fire as required by HNP commitments to NUREG-0800. These fire protection discrepancies have been identified in the HNP corrective action program. ESR 97-00648 installs a new 3-hour fire door and penetration seals to create a new 3-hour fire rated wall along column line E north of column line 43 on the 261'eactor Auxiliary Building (RAB) to protect conduit/cable 14442V12550A-SB. Additionally, approximately 30 feet of 1-hour rated fire wrap and two penetration seals are being added on either side of 261 RAB wall 39/41 to protect conduit/cable 16257Y/12549E-SA.

I~IS The addition of the fire barriers in accordance with this ESR will improve the ability of the plant to cope with a fire in these areas where the conduits/cables discussed above are located. The installions are consistent with the plant's regulatory committments for protection, of redundant safe shutdown division cables. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-298 Title: MMM-027, Troubleshooting Plan for "A" Recirculation Pump D~escri tion:

MMM-027, Revision 0 is the troubleshooting plan for the "A"Recirculation pump due to the slowly increasing level in the "A"Recirc. sump. A temporary system lineup change will result in a short term isolation of the RWST from the Containment Spray "A"train.

The Containment Spray valves will be stroked with the system under a Limiting Condition for Operation (LCO).

I~IS The Containment Spray system is a standby ESF system, and does not connect with systems involved with FSAR Chapter 15 accident analyses. The very short duration of the off-normal lineup will be controlled by the LCO and will ensure that the long-term availability is not degraded. The limited number of Containment Spray valve strokes will not cause wear or degradati'on. The LCO established prior to this activity maintains the availability of the "B" train of Containment Spray.. The activity will be conducted within the limits of Tech. Spec. LCO requirements and safety margins will not be affected. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-300 Title: ESR 95-00278, Additional Four BWR Racks for Pool B, Revision 3

~Descri tien:

The activity evaluated is Revision 3 to ESR 95-00278 which provides revised structural details for temporary access platforms attached to the spent fuel bridge crane to support fuel rack installations. The temporary platforms will allow riggers to be positioned on the north side of the bridge crane and over the racks when the racks are lowered and positioned in the spent fuel pool.

After the racks are installed, the temporary platforms are removed. The installation and removal of the temporary platforms are controlled by procedure. Revision 3 revises the value used for the temporary access platform weight to reflect the actual value obtained from weighing a platform assembly.

S~IS ESR95-00278 Rev. 3 does not make changes'o any fuel handling equipment nor to any equipment used for accident mitigation. The temporary access platforms do not adversely impact the seismic qualification or function of the spent fuel bridge crane. The platforms are designed so that they will not fail during a seismic event resulting in components falling into the spent fuel pool and on to spent fuel. The loading on the spent fuel bridge crane due to the temporary access platforms continues to be less than the rated load for the crane. Fuel handling tools and spent fuel assemblies are not suspended from the access platforms, and when the platforms are installed, no loads may be suspended by the spent fuel bridge crane hoist. The temporary access platforms have no impact on the function of the spent fuel pool cooling or spent fuel storage systems. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

0 SE 0 97-308 RAF 0 2438 Title: ESR 97-00007 Rev. 1, Abandonment of Chlorine System Heat Trace

~Descri tion:

ESR 97-00007 Rev. 1 makes changes associated with the elimination of heat trace at the abandoned Chlorine Storage Facility. Two Normal Service Water lines and one Potable Water line will be isolated from the Chlorine Storage Facility to enable elimination of the associated heat trace.

Safet Summa The Plant Heat Trace System, Potable Water System, and Normal Service Water are non-safety related. This ESR reduces unnecessary equipment associated with existing abandoned facilities. No new equipment or functional components are introduced by this ESR. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor does it introduce a'different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

0 SE 0 97-310 Title: AOP-027, Response to Acts Against Plant Equipment V

~Descri tion:

The activity evaluated is Revision 9 to AOP-027. AOP-027 provides guidance to Operations and Security regarding acts directed against plant equipment. It details plant equipment and systems to be inspected by Operations, emergency action level entry, and security event declarations.

Revision 9 provides additional information concerning Security and Operations response to acts of tampering and sabotage to counter threats, investigate incidents, inspect equipment, enter emergency action levels, and perform reporting.

~ss The revision to AOP-027 enhances guidance for operations and security actions related to acts of tampering/sabotage of plant equipment. The procedure revision addresses corrective and mitigating actions by Security and Operations, makes no change to the facility as described in the SAR, and does not address tests or experiments. This change does not increase the probability or consequences of analyzed accidents, nor introduce.a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-314 RAF ¹ 2461 Title: FSAR Figure 9.3.2-1

~Descri tion:

This change revises FSAR Figure 9.3.2-1, "Flow Diagram - Sampling System (Nuclear)"

to indicate that valve 4SP-V381-1 is an air-operated valve rather than a solenoid-operated valve. The change of valve type is described in ESR 97-00669.

Safet Summar The FSAR change is required to accurately reflect that valve 4SP-V381-1 is an air-operated valve. ESR 97-00669 describes changing this valve from a solenoid-operated valve to an air-operated valve. Changing the valve from solenoid- to air-operated is intended to prevent possible overpressurization of sample panel components. Valve 4SP-V381-1 is downstream from the containment isolation valves. It functions as an isolation valve to the Post Accident Sampling System (PASS) panel and does not perform any safety function. Since the valve does not have a safety function, and it will continue to be used in the same manner, the change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-317 Title: ESR 97-00719, Temporary Mod for Water Treatment Building Acid Transfer Pump B

~Descri tion:

The activity evaluated is ESR 97-00719 which removes valve 3CA-5 and installs a temporary blind flange to allow continued operation of the acid transfer system. Water Treatment Building (WTB) Acid Transfer Pump B has been removed for maintenance. Continued system operation was allowed by isolation of pump suction and discharge valves 3CA-5 and 3CA-6. An acid leak occurred at valve 3CA-5 which required isolation of the acid storage tank outlet valve, preventing further use of the acid transfer system. Therefore a blind flange is being used in place of valve 3CA-5 as an acceptable means of isolation of the removed B acid transfer pump until the valve can be repaired or replaced.

~SS The WTB acid/caustic system is a non-safety system that is not an accident initiating system and is not relied upon for accident mitigation or safe shutdown of the plant. This temporary mod provides adequate isolation from the B acid transfer pump which has been removed from service to allow continued operation of the acid transfer system. The removal of an isolation valve and installation of a blind flange does not create an unanticipated failure mechanism. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-319 Title: ESR 97-00708 D~escri tion:

ESR 97-00708 will change the mode of operation of the Computer/Communication Room Complex (CCRC) HVAC System. A permanent modification, which will replace a temporary modification, will ensure that the computer room HVAC system does not operated in a pressurized mode. The current design causes the room to pressurize on receipt of a control room isolation signal to 1/8" water gauge positive pressure with respect to the PIC room.

Safet Summar The dampers that are being re-positioned for this modification are non-safety related and non-seismic. The CCRC ventilation system is not an accident initiating system. The change in damper position will not affect the probability of occurrence of a malfunction or equipment important to safety. The elimination of the ability to introduce outside air will not adversely affect equipment contained in the CCRC. The change will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹97-297 SE¹97-324 RAF ¹ 2619 Title: ESR 97-00648 Rev. 0 and Rev. 2, Safe Shutdown Cable Protection

~Descri tion:

Engineering review determined that two cables required for safe shutdown of the plant did not have adequate protection from an area fire as required by HNP commitments to NUREG-0800. These fire protection discrepancies have been identified in the HNP corrective action program. ESR 97-00648 installs a new 3-hour fire door and penetration seals to create a new 3-hour fire rated wall along column line E north of column line 43 on the 261'eactor Auxiliary Building (RAB) to protect conduit/cable 14442L/12550A-SB. Additionally, approximately 30 feet of 1-hour rated fire wrap and two penetration seals are being added on either side of 261 RAB wall 39/41 to protect conduit/cable 16257Y/12549E-SA.

ssss The addition of the fire barriers in accordance with this ESR will improve the ability of the plant to cope with a fire in these areas where the conduits/cables discussed above are located. The installions are consistent with the plant's regulatory committments for protection of redundant safe shutdown division cables. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

¹ SE 97-326 ESR 97-00248 C

Title: ESR 97-00248 "Turbine Building Drains Radiation Monitor Re-Design"

~Descri tion:

This ESR changes the design of the Turbine Building Drains Radiation Monitor from an "off-line" sampling monitor to an "adjacent-to-line" radiation monitor. This change will improve the reliability of the monitor by resolving problems associated with maintaining radiation monitor sample flow. This ESR results in a changes to FSAR section 11.5.2. by adding a description of this type of adjacent-to-line radiation monitor and to the associated FSAR tables and figures.

S~fS This ESR changes the design of the Turbine Building Drains Radiation Monitor from an "off-line"sampling monitor to an "adjacent-to-line" radiation monitor. This change will improve the reliability of the monitor by resolving problems associated with maintaining radiation monitor sample flow. The change in radiation monitor types will improve overall radiation monitoring system reliability. The design change affects the RMS and Turbine Building Drains Systems, but neither are considered accident initiating systems.

No additional failure mechanisms are introduced by this new design . The change does not affect an accident or malfunction of equipment previously evaluated in the SAR.

There are no new accident scenarios or equipment malfunctions created by this change.

Margin of Safety as defined in the TS bases will not be reduced. Thus, no unreviewed safety question exists.

SE ¹97-331 Title: ESR 97-00730, Future Operability Determination of Fuel Handling Building Emergency Exhaust System, Revision 0

~Descri tion:

The activity evaluated is ESR 97-00730, "Future Operability Determination of Fuel Handling Building Emergency Exhaust System." A separate ESR contained an operability determination for past and current conditions of the FHB emergency exhaust system. The critical issue was the acceptability of the small bleed flow that could bypass the filter beds during certain conditions.

The purpose of this ESR is to evaluate future operability for a normal system lineup until the long term design basis is reestablished. Compensatory actions have been identified as ensuring fuel offload does not occur until at least 258 hours0.00299 days <br />0.0717 hours <br />4.265873e-4 weeks <br />9.8169e-5 months <br /> after shutdown and placing a procedure on administrative hold.

~Sf S This ESR and the compensatory actions established ensure the consequences of a fuel handling accident are not increased. This ESR demonstrates operability in accordance with NRC guidance. A delay in moving spent fuel would require the residual heat removal system and the containment ventilation system to operate slightly longer after shutdown, but this is well within their design basis. With the compensatory action in place, the offsite dose from a fuel handling accident would be within the licensing basis value. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

0 0

SE ¹97-337 Title: ESR 97-00725, Turbine Driven Auxiliary Feedwater Pump Test Technical Specification Change, Revision 0

~Descri tion:

The activity evaluated is ESR 97-00725, Turbine Driven Auxiliary Feedwater (TDAFW) Pump Test Technical Specification Change. The TDAFW pump is tested at approximately 4100 rpm on recirculation which limits the pump flow to approximately 90 gpm. This test condition produces higher vibration readings due to hydraulic instabilities that are present at the high speed and low flow conditions. These test conditions are undesirable since they can lead to early pump degradation. This ESR provides the basis for changing the surveillance parameters specified in the Technical Specifications (TS) from 4100 rpm to 3700 rpm.

Ssf SS This ESR only affects the surveillance test criteria for the TDAFW pump. No other equipment important to safety is affected. The new criteria will demonstrate acceptable pump performance.

The change to the speed of the TDAFW pump does not change the indication of degradation.

The test will detect pump degradation at 3700 rpm just as degradation was detected at the previously specified TS criteria. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

NOTE: This safety evaluation was written to support Tech Spec change amendment 87. No unreviewed safety question exists.

SE ¹97-340 Title: OPT-1518, Emergency Service Water Stagnant Area Flushing, Revision 4

~Descri tion:

The activity evaluated is Rev. 4 to OPT-1518. This procedure provides direction to periodically flush stagnant/low flow piping in the Emergency Service Water (ESW) header that is not cooling the safety train in service. The purpose of this flushing is to control/eliminate macroscopic fouling and biological fouling organisms. Revision 4 of the procedure added a flush of the standby WC-2 chiller condenser and the ESW pump seal supply lines.

S~IS The ESW system is not an initiating system for any accident evaluated in the SAR. The portion of the system addressed with this evaluation isolates a non-safety portion (Chemical and Volume Control System chillers), which is not used for the mitigation of any accident in the SAR, from the safety-related portion. The change places the isolation valves in their required post-accident positions, and this decreases the potential for them to fail open. The ESW system would still be operated as assumed. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 97-341 RAF 2435 Title: FSAR section 10.4.8 Steam Generator Blowdown (SGBD) System

~Descri tion:

This change allows use of a temporary modification to "fail open" the pressure control valve in the nozzle 11 flow path to sustain blowdown flow from a steam generator when the isolation valve in nozzle 6 is inoperable. The steam generator blowdown system has two parallel

, connections to the steam generator via nozzles 6 and 11. Ifthe air-operated isolation valve in nozzle 6 were to become inoperable and shut, then the normal means of blowdown would become unavailable. This temporary modification and FSAR change would allow using nozzle 11 as the sole conpection from which blowdown could be taken from. If blowdown was isolated to a steam generator a plant shutdown would be required due to chemistry requirements.

~Sf S The pressure control valve in the blowdown line from nozzle 11 does not perform a safety function other than being a pressure boundary for the closed system in which it is installed. This change will not affect the pressure boundary of the valve only the non-safety feature of pressure control. SGBD is not an accident initiating system. Since its safety related function is not being altered, the probability and consequences of an accident will not increase. SGBD is part of the pressure boundary of the secondary of the steam generators. The only failure that could result from failure of the SGBD system is a faulted steam generator which has been previously evaluated in chapter 15 of the FSAR. Therefore. the possibility of a new or different type of accident will not be created. The change being made only affects the non-safety portion of the SGBD system and will not affect the system's ability to isolate on safety injection or AF%V actuation. Therefore, the probability or consequences of equipment malfunction will not increase.

Since the system will still be operated-within the same pressure, temperature, and flow limitations, then a new type of equipment malfunction will not be created. Thus, no unreviewed safety question exists.

SE 4 97-343 RAF 2466 Title: FSAR section 9.4.0 and 9.4.9 Computer Room Ventilation

~Descri tion:

This change incorporates ESR 97-00708 into the FSAR. This change eliminates the pressurization mode for post-accident operation of Computer Room ventilation. This was necessary to maintain Control Room Ventilation operable during an accident. Technical Specifications require the Control Room to be capable of being pressurized to 1/8" greater than adjacent areas. The Computer Room is an adjacent area, therefore to maintain the Control Room Ventilation system operable, the Computer Room cannot be allowed to be pressurized.

I 888$

Preventing the Computer Room from being pressurized during an accident, maintains Control Room Ventilation operability. Removing the capability to pressurize the Computer Room does not affect habitability of the area. The change being mad. only affects the non-safety portion of the plant ventilation system and ensures the plant is operated within the parameters defined by Technical Specifications. The plant computer is not credited to mitigate the consequences of an accident. There are no control functions operated by the plant computer. Therefore, the possibility of a new or different type of accident will not be created. The probability and consequences of an accident will not increase. The probability or consequences of equipment malfunction will not increase. Since the system will still be operated within the pressure, temperature, and humidity limitations. then a new type of equipment malfunction will not be created. Thus, no unreviewed safety question exists.

SE ¹97-348 Title: Cancellation of EPT-170, Containment Fan Cooler Cooling Coil Capacity Test,

. Revision 3

~Descri tion:

The activity evaluated is cancellation of procedure EPT-170, "Containment Fan Cooler Cooling Coil Capacity Test." EPT-170 determines the cooling coil capacity of the Containment Fan Coolers. The data is used to determine the possible fouling of the water side of the coils. EPT-170 is a Generic Letter 89-13 required test and was written for data taking only. It does not directly affect operability of the Containment Fan Coolers. The procedure requirements of EPT-170 are being fulfilled by two other procedures, EPT-058 and EPT- 163.

I~If S This procedure cancellation does not change the operation of the plant, nor does it alter any equipment installed in the plant. No licensing, technical specifications, or design basis requirements are changed or affected. This procedure does not affect any accidents analyzed in the safety analysis report. Current analyses in the safety analysis report continue to bound the operation of the plant with this procedure cancellation. The procedure requirements are fulfilled by other procedures. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE ¹97-353 Title: PEP-430, Routine Maintenance and Testing of the Dialogic System

~Descri tion:

The activity evaluated is Revision l to PEP-430, Routine Maintenance and Testing of the Dialogic System. The Dialogic System is a computerized emergency response personnel call out computer that is available to notify the CP&L emergency response organization personnel and NRC resident inspector of emergency declarations at the plant.'evision 1 to PEP-430 adds to the procedure a general description of the Dialogic system and a caution statement to not place the Dialogic system in an inoperable condition without first notifying the Control Room.

~Sh S This procedure change provides a caution to notify the Control Room when Dialogic is placed in an inoperable condition. The enhancement re-enforces the need for good communication with the Control Room for a tool they would use in an emergency. The addition of this procedural guidance should decrease the probability of a communication error that could potentially aggravate an emergency situation. Safety related equipment is not directly addressed in PEP-430. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-355 Title: PEP-420, Emergency Equipment Inventory

~Desert tien:

The activity evaluated is Revision 3 to PEP-420, Emergency Equipment Inventory. This procedure provides a detailed list of supplies for the emergency facilities, including instructions for the performance of inventories and the associated checklists. Changes to the inventories being made by this procedure revision fall into several categories:

1. Title and name changes,

2. Typo corrections,

3. Dosimetry inventory reduction due to issuance of thermoluminescent dosimeters (TLDs) to the necessary emergency response organization members,

4. Equipment removal due to technology upgrades,

5. Name tag removal due to sign-in board, and

6. Procedure forms moved from inventoried cabinets to controlled forms towers.

s~ps The inventory changes described above serve to provide updated, current information and equipment. The nature of this change should enhance the performance of the emergency facilities. Safety related equipment is not directly addressed in PEP-420. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The pro'posed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-356 Title: ESR 97-00768, Accelerated Flow Rates in the Waste Processing Building Filtered Exhaust System

~Descri tion:

The activity evaluated is ESR 97-00768 which provides an operability determination for the operation of the Waste Processing Building Filtered Exhaust System (WPBFES) at accelerated flow rates. The accelerated flow rates eliminate severe vibration in the duct work. The vibration is caused by the throttling of the vortex damper, resulting in turbulence downstream of the vortex damper. The accelerated flows allow the vortex damper to fully open; thereby reducing the turbulence and duct work vibration. The evaluation performed by this ESR allows the fans in the WPBFES to operate at accelerated flow rates with three fans in service in lieu of four fans.

SSSS The ESR evaluated and approved the. operation of the WPBFES fans at accelerated flows based on technical information and test results which show that the filtration at the accelerated flow rates provides the necessary filtering. The WPBFES is not an accident initiating or mitigating system, and does not affect safety systems or safety equipment. The WPBFES is a non-safety system. Operating the fans at the accelerated flow rates prevents fan and duct work vibration; and hence reduces the probability of equipment malfunction. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-358 RAF ¹ 2462 Title: ASTM Methods for Testing EDG Fuel Oil for Sulfur

~Descri tion:

This change modifies FSAR Section 9.5.4.1 to reflect that the emergency diesel fuel oil storage and transfer system analysis for sulfur may be performed in accordance with ASTM-D1552-79 or ASTM -D2622-82. This change will make the FSAR description match what is currently stated in Technical Specification Surveillance Requirement 4.8.1.1.2 for diesel generator fuel oil testing.

Safet Summar No actual plant modifications are involved with this FSAR change. The description of the emergency diesel fuel oil storage and transfer system is modified to accurately reflect the ASTM methods that may be used for fuel oil sulfur analysis. The FSAR change does not result in any changes to system or component operation, procedures or testing requirements. The change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 97-359 RAF 0 2464 Title: Rod Deviation Alarm

~Desert tion:

This activity changes the FSAR, section 7.7.1.3.4, to state that the Digital Rod Position Indication (DRPI) system detects and alarms when a shutdown rod is at or below 210 steps. The purpose and operation of the alarm has not changed. The rods full out "park" position changed, which changed the reference point with respect to the deviation alarm.

Originally, HNP shutdown banks were maintained at 228 steps. The Rod Deviation alarm for shutdown banks is set for 210 steps. The FSAR states that the deviation alarm for shutdown banks is set at 18 steps below the full out position. Since the full out position will vary from cycle to cycle, then the FSAR is being changed to state the deviation alarm for shutdown banks is set at 210 steps.

Safet Summar Changing the park position of control rods has been previously evaluated. This evaluation examines the effect of changing the park position indication and alarm. The'DRPI system and the shutdown rod alarm are non-nuclear safety. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ft 97-360 RAF 0 2467 Title: Fuel Densification

~Descri tion:

This FSAR change updates FSAR Section 1.8 to indicate that HNP complies with Reg.

Guide 1.126 by means of utilizing the Siemens fuel densification model. This corrects an administrative oversight that failed to update the FSAR when Siemens fuel was introduced in Cycle 6.

Safet Summar This FSAR change is editorial in nature. No actual plant modifications are involved with this change. The Siemens fuel densification model has been approved by the NRC. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 97-361 Title: REG-NGGC-002, 10 CFR 50.59 and Other Regulatory Evaluations

~Dosori tion:

The activity evaluated is Revision 0 to REG-NGGC-002, "10 CFR 50.59 and Other Regulatory Evaluations." This new Nuclear Generation Group common (NGGC) procedure will replace in its entirety the site specific procedure for safety evaluations. This procedure provides instructions and personnel training and qualification requirements for performing evaluations pursuant to 10 CFR 50.54, 10 CFR 50.59 and other regulatory requirements for proposed activities at CP&L's nuclear plants. The purpose of the evaluations is to determine if a proposed activity requires NRC approval or notification prior to implementation. This procedure provides directions for performing evaluations of proposed permanent or temporary changes involving various requirements in 10 CFR 50 and other site specific requirements.

S~S REG-NGGC-002, Revision 0, represents an administrative change and enhancement to the 10 CFR 50.59 evaluation process and the evaluation of other regulatory changes which currently exist at the plant. This is a new NGGC administrative procedure which does not alter any design bases, codes and standards, or normal or operating procedures. This procedure does not involve any tests or experiments, and does not have any direct impact on systems, structures, or components important to safety, either through modification or design bases changes. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 8 97-362 RAF 2465 Title; FSAR Revision to correct the "Turbine Trip From Low Hydraulic Pressure" range specified in FSAR Table 7.2.1-3.

~Descri tion:

This RAF revises FSAR Table 7.2.1-3 to correct the "Turbine Trip From Low Hydraulic Pressure" range and provide consistency with the Instrument List range of 200 to 3000 psig. This FSAR discrepancy was identified during the Surveillance Procedure Review Project.

SSf SS The proposed activity involves revising FSAR Table 7.2.1-3 to correct the "Turbine Trip From Low Hydraulic Pressure" range and provide consistency with the Instrument List.

The correct range should be designated as 200 to 3000 psig as listed in the Instrument List. This FSAR correction will not alter any safety-related structures, systems or components and will have no adverse impact on safe plant operation. This revision does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹97-363 RAF 2468 Title: FSAR editorial corrections and clarifications

~Descri tion:

This evaluation was performed on changes to the FSAR to correct misspellings and typographical errors. No changes have been made to the operation of the plant or to any plant equipment under this evaluation I~If S The editorial changes made to the FSAR do not modify plant SSCs important to safety, or change design bases, codes and standards, or normal/emergency operating procedures.

This activity does not increase the probability of occurrence of a malfunction of equipment important to safety. The change does not make any changes to structures, systems, components, or equipment. There is no increase in the probability or consequences of analyzed accidents, nor is an accident of a different type than previously evaluated presented. This activity does not reduce the margin of safety. The change is not a test or experiments. Based on this, no unreviewed safety question exists.

SE ¹97-364 RAF ¹ 2473 Title: Demineralized Water

~Descri tion:

This FSAR change revises Section ~).2.3.2.3 to more accurately describe the safety function of the Demineralized Water System (DWS). The Section currently states that the DWS serves no safety function. Valve 1DW-65 within the DWS performs a safety function as a containment isolation valve. The FSAR revision will state that the supply of .

DWS serves no safety function, but that components within the DWS are relied on for containment isolation.

~S<<S No actual plant modifications are involved with this FSAR change. Containment isolation valve 1DW-65 is designed and tested to ensure it will perform its safety function to open/shut. No new control systems, system configurations or equipment are being introduced by this change. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-365 RAF 0 2525 Title: E&RC Organization Change

~Descri tion:

The activity evaluated is. an organization change within the Environmental &, Radiation Control Unit at the Harris Plant. The Spent Fuel Management responsibility is being moved from the Superintendent - Radiation Protection to a new subunit led by the Supervisor - Spent Fuel Management which will report directly to the Manager-Environmental & Radiation Control.

S~f ~

This is an administrative change which provides for realignment of the E&RC organization. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹97-366 RAF ¹ 2469 Title: Auxiliary Dam Length and Height

~Descri tion:

This change modifies FSAR Sections 2.5.6.1.3.2, 2.5.6.4.1.2 and 2.5D.2.3 to provide the correct Auxiliary Dam length of approximately 3903 feet, and structural height of approximately 72 feet.

Safet Summar No actual plant modifications are involved with this FSAR change. The description of the Auxiliary Dam is currently incorrect with respect to the dam length and structural height. This FSAR change is editorial in nature. The change does not physically impact the Auxiliary Dam, does not change how the dam performs its function and does not affect the probability or consequences of dam failure. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹97-367 RAF ¹ 2487 Title: ESR 9700S84, Isolation of PRT Nitrogen

~Descri tinn:

ESR 9700584 changes the normal operating position of containment isolation valves 1RC-141 and 1RC-144 from open to close, and changes the normal operating setpoint of the nitrogen regulator 1NI-241 from 3 psig to 0 psig (i.e., closes the valve). The current design of the Pressurizer Relief Tank (PRT) nitrogen supply is to maintain a constant 3 psig cover gas through these isolation valves by regulating valve 1NI-241. Due to chronic seat leakage past the regulator, the containment isolation valves are to be closed to prevent increases in nitrogen pressure on the PRT. The isolation valves will be opened and the regulator realigned whenever PRT pressure control is required, such as when the PRT is to be vented, purged, drained, cooled down or pressurized when placed in service.

The purpose of the 3 psig cover gas is to preclude oxygen from the PRT so that if hydrogen gas accumulates in the tank (due to inleakage from the RCS), no explosive hydrogen-oxygen mixture will result. To provide additional assurance of maintaining minimum PRT pressure with the nitrogen supply isolated, a low pressure annunciator is added using the plant computer point for PRT pressure. The alarm setpoint is based on assuring a positive pressure in the PRT, consistent with the calibration accuracy of the transmitter.

Safety Summary:

The safety-related function of the PRT nitrogen supply isolation valves is to isolate containment penetration M77B on a phase A containment isolation signal. There are no other safety-related functions of the isolation. The valves are therefore changed to be normally in their correct position to accomplish their safety-related function. In the event of an accident requiring phase A containment isolation, these valves would no longer rely upon their actuation signal to close. This in effect improves the reliability of the valves to accomplish the isolation function. With the valves open during PRT venting, purging, or draining, the containment isolation signal would close the valves, consistent with the current design. Operation of the plant with the PRT nitrogen supply isolated does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ~ 97-36S RAF 2548 Title: Evaluation of the addition of 1 inch makeup water line connection from the Primary Makeup System to the Spent Fuel Cooling and Cleanup System.

~Descri tion:

This RAF adds text to FSAR Section 9.1.3, and modifies FSAR Figures 9.L3-4 and 9.2.3-2 to address the addition of 1 inch piping routed from the Primary Makeup System (water supply from the RMWST) to the Spent Fuel Cooling and Cleanup System to provide another way to add water to the fuel pools.

S~fS This proposed activity evaluates the addition of a connection between the Primary Makeup Water System and the Spent Fuel Pool Cooling and Cleanup System, and provides the routing and installation instructions for the 1 inch connection between these two systems. The use of tritiated water for makeup to the spent fuel pools is evaluated in accordance with the Harris Nuclear Plant goal to further reduce tritium releases to Harris Lake. The proposed plant modification will not create adverse interactions with safety related equipment, change the operating environment or conditions associated with safety related equipment, or affect the performance of either the Primary Makeup or Spent Fuel Cooling and Cleanup Systems as described and evaluated in the FSAR. As a result. this

'evision does not increase the probability or consequences of analyzed accidents. nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR. nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus. no unreviewed safety question exists.

SE N 97-360 RAF 2470 Title: Editorial Change Concerning Main Reservoir Level

~Descri tion:

The activity evaluated is a change to FSAR Section 2.4.11, "Loiv Water Considerations". This is an editorial change to a previously approved FSAR change concerning the main reservoir level.

Specifically, the change involves removal of a reference to Technical Specifications.

S~IS This is an editorial change to the FSAR and it does not impact accidents or equipment malfunctions. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE ¹97-371 RAF ¹ 2472 Title: RHR and CT NPSH

~Descri tion:

This FSAR change revises net positive suction head (NPSH) values given in FSAR Section 6.2.2.3.2.1, Table 6.2.2-8 and Table 6.3.2-1. Specifically, the NPSH available, for containment spray pumps is changed from 27.2 ft. to 25 ft, the NPSH available for RHR pumps is changed from 20 ft. to 22 ft., and the NPSH required for RHR pumps is changed from 18 ft. to 19 ft. These changes reflect the most recent engineering evaluations, as documented in ESR 95-00344, Rev. 3.

Safet Summar No actual plant modifications are involved with this FSAR change. The description of the NPSH values for containment spray and RHR pumps is being revised to accurately reflect current engineering evaluations. The NPSH available to the pumps is greater than required. This FSAR change will not impact the ability of the containment spray pumps or RHR pumps from performing their safety functions. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 6 97-372 RAF 0 2513 Title: Steam Tunnel Thermocouple Relocation and Setpoint Change

~Desert tinn.

This FSAR change revises the setpoints at which the Steam Tunnel Ventilation Fans start with relation to outside ambient temperatures and incorporates the relocation of the temperature thermocouples to improve system operation. The revision also describes operation of the fans manually via the control switches in the Main Control Room. These changes reflect the most recent engineering evaluations, as documented in ESRs 97-00157 and 97-00785.

Safet Summar The Steam Tunnel Ventilation Fan setpoint changes and thermocouple relocation will allow the system to operate in a more efficient manner. This modification will help to prevent low outside ambient air temperatures from affecting the operability of the Main Feedwater Isolation Valve (MFIV) actuators. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment.

and does not reduce any margin of safety. Theret'ore. the change does not involve an unreviewed safety question.

SE ¹97-373 RAF ¹ 2478 Title: ALARAAnalyst's Duties

~Descri tion:

This change revises the description provided in FSAR Section 12.5. I of the ALARA Analyst/Engineer's duties. Specifically, the ALARAAnalyst/Engineer is no longer a position that is removed from the line function of day to day health physics (HP) activities. As the work planning process at HNP has evolved, the position of ALARA Analyst has changed from that of an independent individual contributor to that of a technical staff member involved in the routine planning of site HP activities.

Safet Summar This FSAR change is administrative in nature. No plant equipment is affected by this change. There are no requirements that the ALARAAnalyst be completely independent of routine HP activities as long as the responsibilities of the position regarding maintaining doses ALARAare not compromised. Based on dose trends at HNP, the increased involvement of the ALARAAnalyst in routine HP activities has not been detrimental. The duties and organizational relationships of the ALARAAnalyst do not impact any accident initiators or mitigators or any equipment important to safety. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment,,and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 97-374 RAF 0 2501 Title: Radiation Work Permit (RWP) Office Name Change

~Descri iion:

The subject of this evaluation is a change in the name of the Radiation Work Permit (RWP) Office located in the Waste Processing Building 261'levation office area. The designation for this office is being changed to the Radiological Control Center.

Safet Sum mar No changes to equipment or equipment operation are being introduced. This is a title'hange of an office area only. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor does it introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 97-376 Rev. 1 RAF 0 2474 Title: Changes to FSAR Tables (3.2.1-1 and 9.5.5-1)

~Descri tion:

There are two changes to the FSAR being evaluated. The first change is updating the Q-class table'(Table 3.2.1-1). Plant Change Request (PCR) 5731 made changes to both the Q-class design drawing 2165-A-0001 and FSAR Table 3.2.1-1. However, the PCR inadvertently deleted the quality classification for the control room exhaust fans and dampers on Table 3.2.1-1. 2165-A-0001 was revised, and included the quality classification for the control room exhaust fans and dampers. This change updates the FSAR table to bring it in agreement with the approved design document. The second change is to FSAR Table 9.5.5-1. Changes were previously made to this FSAR table to bring the table into agreement with design calculation SW-0049, Revision 2. However, the two jacket water cooler exit temperatures were inadvertently not revised. This change updates the FSAR table to bring it in agreement with the approved design document.

I Safet Summar The change to Table 3.2.1-1 is an administrative activity which does not physically affect any equipment or system. Adding the quality class of the control room exhaust fans and dampers corrects the inadvertent deletion from a prior change. No physical changes in quality classification are made as a result of this evaluation. The EDG jacket water heat exchanger shell-side design temperature is 200'F, which is well above the revised value of 157'F. Likewise, the tube-side design temperature is 160'F, which is greater than the revised value of 130'F. Thus, the increases in outlet temperatures as made by this change described in FSAR Table 9.5.5-1 is acceptable. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

SE 0 97-377 RAF 2475 Title: FHBEES low - flow bleed air

~Descri tion:

This activity changes FSAR Section 6.5.1 and figures in FSAR chapter 9 to indicate the modification of the FHBEES that isolated the bleed path between E-12 and E-13 fans. The NRC issued License Amendment 82 which removed the surveillance requirement to verify the valve in the filter cooling bypass line (bleed line) was locked in the balanced position; HNP is modifying the FHBEES to isolate the filter cooling bypass line therefore, all references to the filter cooling bypass line are being revised in the FSAR.

s~s Calculation HNP-M/FFIB-1002 determined that the bleed path was not required for the FHBEES.

The temperature increase in the charcoal resulting from a fuel handling accident is below the auto-ignition and the iodine desorption temperature of the charcoal. Therefore, the bleed path is not required. HNP is modifying the FHBEES by isolating the bleed path. The method of isolation chosen does not affect the safety or seismic qualification of the FHBEES. Additionally, the efficiency of the charcoal is not affected by this modific"tion. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased

SE 0 97-378

~ Title: ESR 97-00535, HVAC Control Room Area Habitability

~Descri tion:

The activity evaluated is the impact on the habitability of the Control Room by increasing the maximum allowable air makeup rate above the current limit of 315 CFM. This evaluation has determined that based on the probability associated with the occurrence of an off site chlorine release, coupled with the removal of the chlorine tank car from the site, the 315 CFM limit is no longer applicable. This limit can be raised to a new value of 400 CFM based on radiological considerations.

S~f' The change being made by this ESR does not change the design or function of the control room HVAC system nor does it change the basis for any radiological calculations associated with dose to control room personnel. This change to the allowable flow rate does not have any impact on Systems, Structures or Components ability to perform it's safety related function. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹97-379 RAF 2475 Title: Control Room Emergency Exhaust Filtration System low - flow bleed air system

~Descri tion:

This activity changes FSAR Section 6.5.1 to indicate that the Control Room Emergency Exhaust Filtration System does not need a low-flow bleed air system. The existing design basis (Calculation 9-SAC-2C) has previously evaluated that an air bleed system is not needed for the R-2 units. The description of the control room ventilation and filtration system in FSAR Sect 9.4 already reflects this. This change to the FSAR simply corrects an omission that has been previously considered in another section of the accident analysis (FSAR Sect. 9.4).

I~I<<S Calculation 9-SAC-2C provides the basis for not needing a low-flow bleed system for the R-2 units and the existing accident analysis already takes this into account. The calculation shows that there is not sufficient heat produced in the units charcoal beds to require a low-flow bleed system. This change to the FSAR provides consistency regarding this description within the FSAR. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased

0 SE ¹97-380 RAF 2516 Title: Installation and Use of Replacement Steam Generator Storage Facility

~Descri iion:

This activity changes FSAR Figures 1.2.2-1, 1.2.2-2, 3.4.1-1, and 9.4.0-2 to show the addition of

.

the Replacement Steam Generator Storage Facility (RSGSF) to the plant site plan. The RSGSF is a prefabricated structure (Butler Building) erected to provide a temporary storage location and weather protection for the three replacement steam generators (RSGs).

SsfsS The RSGSF is a non-safety related, non-seismic structure designed to provide temporary storage and weather protection for the RSGs. The RSGSF is a stand alone facility and will have no interface with permanent plant structures or systems. The activities associated with the installation and use of the RSGSF will be performed, in their entirety, outside of the site protected area. The RSGSF is located greater than 200 feet to the west of the protected area security fence. As a result of this distance, plant security will not be adversely affected by the location of the RSGSF. The design and location of the structure and work activities ensures that no safety-related or important to safety structures, systems, or components are impacted. The activities associated with the installation and use of the RSGSF will not increase the probability of occurrence or consequences of accidents or malfunctions of equipment important to safety previously evaluated in the FSAR. Likewise, this activity does not create the possibility of an accident or a malfunction of equipment important to safety of a different type than previously evaluated in the FSAR, and there is no reduction in the margin of safety as defined in the bases of any technical specification. Therefore, this activity does not involve a potential unreviewed safety question.

SE ¹97-381 Title: ESR 97-00943, Level Indicator, Upflow Filter Clearwell Tank D~escri tion:

The activity evaluated is the addition of a temporary level indicating gage for the Upflow Filter S~

Clearwell Tank which is a component of the plant's Potable Water System.

~

The Potable Water System/Water Treatment at HNP is a non-safety related system. No safety related equipment or other systems are affected by this change. Therefore, the addition of a temporary level indicating gage on the Upflow Filter Clearwell Tank does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 97-382 RAF 0 2488 Title: Deletion of Local Pressurizer Level Indication D~escri tion:

The activity evaluated is the removal of the reference to two local pressurizer water level indicators, LI-0459B and LI-0459C from FSAR Table 7.4.1-1, Monitoring Instruments For Safe Shutdown. These local indicators do not exist in the plant. Based on reviews performed, the two local level indicators are judged to be part of a generic Westinghouse design for remote shutdown control stations for charging and auxiliary feedwater (AFW).

This earlier design was superseded at the Harris Nuclear Plant (HNP) during the design/construction phase by the auxiliary control panel (ACP), which provided for control of the charging flow and AFW flow at a single panel in lieu of multiple panels.

~MS The two indicators are mentioned only in the referenced table in the HNP FSAR, and a review of the corresponding SER sections did not reveal that the existence of local indicators was a consideration in concluding that the HNP design for safe shutdown was acceptable. The deletion of the reference to the level indicators from the FSAR is considered acceptable and consistent with the design and licensing basis of the HNP.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 97-383 Title: ESR 97-00891, Evaluation of LS-435 Being Degraded and Non-Nuclear Safety Piping Downstream of I MS-336 and I MS-354

~Descri tion:

The activity evaluated is ESR 97-00891, which provides the background and safety evaluation for LS-435 in a degraded condition and for the non-nuclear safety (NNS) piping and supports downstream of valves IMS-336 and IMS-354 as being equivalent to ASME Safety Class (SC) 3.

This evaluation is necessary due to the relatively long time between initial discovery of the conditions and expected resolution. This ESR concludes that the turbine driven auxiliary feedwater pump (TDAFWP) will perform its necessary design basis requirements.

S~fS LS-435 and the NNS piping downstream of IMS-336 and IMS-354 impact the TDAFWP only.

AFW is not an accident initiator, but it is an accident mitigator. The AFW system continues to function as designed. Failing LCV0435 in either the open or closed, direction will not impact the operability of the TDAFWP. The condensate removal system is providing adequate condensate removal for the TDAFWP with LS-435 in its degraded condition, therefore the TDAFWP will perform its necessary design basis requirements. The NNS piping and supports downstream of valves IMS-336 and IMS-354 are designed and build essentially the same as ASME SC-3, therefore there is no increase probability of piping failure. The evaluations of LS-435 in its degraded condition and the NNS piping downstream of valves IMS-336 and IMS-354 concluded the TDAFWP is capable of performing its design basis accident mitigating and safe shutdown functions including single failure. Credible failure modes of the components have previously been evaluated and remain unchanged. This activity does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. This activity does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE < 97-384 ESR 97-00946, Revision 0

'itle:

~Descri tion:

ESR 97-00946 evaluates the impact of calculation revisions which increased the minimum level in the Condensate Storage Tank (CST) by six inches to 27.5 t'eet. This was done to account for pump suction vortex suppression.

Safetv Summar ESR 97-00946 concludes that the CST will perform its necessary design-basis functions provided a steam generator narrow range level of 50% is maintained. A level of 50% is adequate because Technical Specifications require only a 10% narrow range level for the steam generators to be operable, and the Auxiliary Feedwater (AFW) auto start setpoint is at 38.5% level. Re-filling the steam generators to a narrow range level of 50% at the end of the cooldown period provides no additional burden on the operators. Procedures already require operators to maintain the necessary steam generator levels. This change will not affect the CST's ability to perform its safety function of supplying the minimum volume of water to the AFW pumps. A steam generator narrow range level of 50% at the end of the cooldown assures systems ivill still meet design and single failure criteria.

This change does not increase the probability or consequences ot accidents or malfunctions of equipment previously evaluated. does not introduce a different type nf accident or malfunction of equipment. and does not reduce any m;irgin nf salety.

Therefore. the change does not involve an unreviea ed safety question.

SE ¹ 97-3S5 RAF 2481 Title: Removal of Valves 2SI-V537SA- l. 2SI-V536SB-I, 2SI-V535SA-I, 2SP-V21SA-I, and 2SP-V22SB-I From the Active Valve List

~Descri tion:

The subject of this evaluation is a correction to FSAR Table 3.9.3-13 "VASSS Supplied Active Class I, 2, and 3 Valves" and FSAR Table 3.9.3-14 "Non-NSSS Supplied Class I, 2, and 3 Active Valves." Active valves are defined as those valves requiring mechanical motion in performing a safety function.

Valves 2SI-V537SA-I, 2SI-V536SB-I, and 2SI-V535SA-I provide isolation between the Cold Leg Accumulators and the Reactor Coolant System (RCS). These valves are not required to move under normal or post-accident conditions and are kept open and de-energized during normal plant operation. Therefore, these three valves are being removed from FSAR Table 3.9.3-13.

Valves 2SP-V2ISA-I and 2SP-V22SB-I provide isolation between Post Accident Sampling Skid ¹I and RCS Hot Legs 3 and 2, respectively. The Post Accident Sampling System (PASS) itself is non-safety related and serves no safety function since it is not required to achieve safe shutdown or mitigate the consequences of an accident. Each PASS sample line that penetrates the reactor containment contains two automatic isolation valves to ensure the post-accident integiity of the containment and prevent radioactive release. Ho'wever. neither 2SP-V21SA-I nor 2SP-V22SB-I are containment isolation valves. Therefore. these two valves are being removed from FSAR Table 3.9.3-14.

Safety Summary:

Valves 2SI-V537SA-I, 2SI-V536SB-l. and 2SI-V535SA-I are not required to function during normal or post-accident operations and are normally kept open and de-energized.

Therefore, their failure to operate will have no effect on the Cold Leg Accumulators.

Valves 2SP-V21SA-1 and 2SP-V22SB-1 are p;irt ot the PASS. which serves no safety-related function. Therefore, failure ot these tvo valves will not affect safe plant shutdown. Valves 2SI-V537SA-1. 2SI-V536SB-1. 2SI-V535SA-l. 2SP-V21SA- l. and 2SP-V22SB-I are not containment isolation valves. Removing these five valves from the active valve lists does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE N 97-386 RAF N 2495 Title: RHR NPSH

~Descri tion:

This FSAR change revises net positive suction head (NPSH) values given in FSAR Table 6.3.2-1. Specifically, the NPSH available for the RHR pumps is changed from 20 ft. to 22.2 ft., and the NPSH required for RHR pumps is changed from 18 ft. to 19 ft.. These changes reflect the most recent engineering evaluation, as documented in ESR 95-00344, Rev. 5.

S~fS No actual plant modifications are involved with this FSAR change. The description of the NPSH values for RHR pumps is being revised to accurately reflect the current engineering evaluation. The NPSH available to the pumps is greater than required. This FSAR change will not impact the ability of the RHR pumps to perform their safety function. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SEC 97-387 RAF 0 2479 Title: Environmental Zone Maps

~Descri tion:

1 The activity evaluated are corrections made to FSAR Section 3.118 Environmental Zone Maps. These zone maps depict the environmental conditions in the plant and are used for the qualification of EQ equipment. The changes made are either editorial in nature or they correct inconsistencies between the environmental zone maps. The environmental zone maps are based on engineering calculations which have been reviewed to verify the corrected information.

~Sh S The changes made to the environmental zone maps are corrections and do not affect any temperature data used for the qualification of plant equipment or alter any temperature data established by the calculations that form the design basis for the zone maps. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

SE 5 97-388 RAF 2489 Title: Change to FSAR Table 7.3.1-12 "ESF and Supporting System Actuation Instrumentation."

~Descri tion:

'This RAF revises FSAR Table 7.3.1-12 to correct the "Steam Line Differential Pressure'nd "Feedwater Flow instrumentation ranges. Steam Line Differential Pressure range is currently listed in FSAR Table 7.3.1-12 as "0 to 1200 psig" and Feedwater Flow range is listed as "0 to 120%." These values are being corrected to indicate "0 to 1300 psig" and "0 to 120%" respectively.

~Ill S This change to the FSAR incorporates the applicable device specific ranges for the Steam Line Differential pressure and Main Feedwater Flow instruments. The increase in the specified ranges were evaluated as if the change were implemented by a modification even though the device specific ranges being evaluated have been in place since plant start up. This activity does not change the separation, redundancy, quality, function, or setpoints of the instrumentation systems. This change does not increase the probability or consequences of analyzed accidents or analyzed equipment malfunctions, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the bases of Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹97-389 RAP 2480 Title: Removal of Valves 3SW-V652SB-I and 3SW-V649SA-I From Active Valve List D~escri tion:

The subject of this evaluation is a correction to FSAR Table 3.9.3-14 "Non-NSSS Supplied Class I, 2, and 3 Active Valves." Active valves are defined as those valves requiring mechanical motion in performing a safety function. Service Water System Valves 3SW-V652SB-I and 3SW-V649SA-I are removed from the list of active valves since these valves are isolated by the locked-closed position of valves both upstream and downstream I~la S Service Water flow through Valves 3SW-V652SB-I and 3SW-V649SA-I has been permanently isolated. Mechanical motion is not required to maintain Fan Cooler AH-85 operable. Removing these two valves from the active valve list does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ff 97-390 Title: ESR 97-00528, Revision 0

~Descri iion:

ESR 97-00528, Revision 0 evaluates replacement valve positioners for the Bailey AP2 series pneumatic positioner since this model, along with many of the primary parts required for normal positioner maintenance, are no longer available. The Bailey AV1 series is evaluated to determine its suitability.

Safet Summar Multiple plant systems utilize the obsolete valve positioners that will be replaced.

Neither the functional design nor the principle of operation of the replacement model positioner is changed. The major difference is the mounting configuration, which has been found to be acceptable. There is no EQ impact associated with the replacements.

Minor differences in the manner of connecting instrument tubing can be accommodated with appropriate angle tube fittings, and no more than minor tubing adjustments. The replacement positioners were determined to be functionally equal to or better than the original positioner. They will perform the same func'.ion, in an equal to or better than manner, as the obsolete positioners. The fail-safe function of the valves is not changed or adversely affected, and the positioner replacement introduces no new failure mechanisms.

This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment. and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 8 98-002 RAF 0 2490 Title: Update of Active Valve List (FSAR Table 3.9.3-14)

~Descri tion:

FSAR Table 3.9.3-14, Non-NSSS Supplied Class 1, 2 and 3 Active Valves, is being revised to remove Containment Spray Valve 3CT-V95SN-1 (1CT-60) which is a manually operated gate valve, which is used to provide the second isolation valve in the containment spray "Emergency NaOH Addition" path. This path allows NaOH to be added to either the "A" train or the "B" train of the containment spray, in case the containment spray additive tank is unavailable. The line ends with a hose fitting to allow for the addition of NAOH solution. 1CT-60 is normally locked closed, and is not used in normal operation, nor in the normal response path to Chapter 15 Accidents. Immediately downstream of this valve, between 1CT-60 and the rest of the Containment Spray system are two other locked'closed valves. Valve 1CT-61 (3CT-V92SA-1) separates the additive line from the "A" train, and valve 1CT-64 (3CT-V93SB-1) separates the additive line from the "B" train. Neither of these two locked closed valves is listed in the FSAR table.

Safet Summar FSAR Section 3.9.3 defines active valves as those components that require a mechanical motion in performing a safety function. Safety-related equipment is defined as equipment whose failure could prevent satisfactory performance of one or more of the following functions: emergency reactor shutdown, containment isolation, reactor core cooling, containment and reactor heat removal, and prevent significant radioactivity release.

Valve ICT-60 is not required for safe shutdown. or for mitigating an accident. Removing this valve from the FSAR table will eliminate the inconsistency of having an "active" valve which depends on inactive valves for functionality. Original design requirements are not changed, so the valve or any replacement will still meet the applicable ASiVIE code requirements, and this valve or a replacement. will still perform its functions as assumed/intended in the original design of the system. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

SE ¹98-003 RAF ¹ 2500 Title: Core Thermal Power

~Descri tion:

This change is a clarification to FSAR Tables 5.1.0-1 and 15.6.3-6 regarding the actual licensed core thermal power output of the plant as 2775 megawatts thermal (MWt), the total unit thermal output as 2787,MWt including 12 MWt from the reactor coolant pumps.

Safet Summar These changes to FSAR Tables 5.1.0-1 and 15.6.3-'6 are being made so that the FSAR will be consistent with the Operating License and the Technical Specifications. Changing the reactor power has been evaluated in previous safety analyses. The change increases the load on certain components, but was addressed in previous safety evaluations and determined not to increase the probability or consequences of equipment malfunction.

The radiological source term for dose in FSAR Chapter 15 is based on a core power that conservatively bounds the licensed rated value of 2775 MWt. This activity changes FSAR Tables 5.1.0-1 and 15.6.3-6 to accurately reflect the accident analysis basis. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus. no unreviewed safety question exists.

SE ¹98-004 RAF 2494 Title: AFW Isolation Slave Relay Test Frequency

~Descri tion:

The activity evaluated is a change to FSAR Section 7.1.2, "Identification of Safety Criteria," and 7.3.2.2, "Compliance with Standards and Design Criteria". The change is being made to explain why testing auxiliary feedwater (AFW) isolation valves and flow control valves is not conducted at power. Specifically, these valves are not tested at power to prevent isolation of AFW flow to the respective steam generators. This isolation could adversely affect plant response to a loss of feedwater or a loss of off-site power event requiring AFW actuation.

S~S The probability of occurrence of an accident is not affected by the periodicity of AFW isolation testing. The AFW flow control and isolation valves are routinely tested during refueling outages.

Reliability of slave relays has been demonstrated to be acceptable with testing performed every 18 months. The testing periodicity is consistent with Harris Nuclear Plant (HNP) Technical Specifications (TS). The consequences of an accident or equipment malfunction may be decreased by eliminating AFW isolation during shutdown since AFW actuation would not be inhibited at power. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-005

, Title: REG-NGGC-0004, Assessment Process, Revision 0

~Descri tion:

The activity evaluated is Revision 0 to REG-NGGC-0004, "Assessment Process." This procedure establishes the assessment process and provides direction on planning,'reparation, performance, reporting and follow-up for performance-based assessments by the Performance Evaluation Support Unit (PES). It also includes programmatic commitments from Section 17.3, Quality Assurance Program Description, of each site's Final Safety Analysis Report.

S~hS REG-NGGC-0004, Revision 0, represents an administrative change and enhancement 'to the assessment process for PES personnel. This change does not have any direct impact on systems, structures, or components important to safety, either, through modification or design basis changes. Codes, standards, design bases, and normal. or emergency operating procedures are not being changed by the new procedure. REG-NGGC-004 is an administrative procedure that in and of itself cannot make changes to the facility and procedures as described in the SAR, or authorize new tests or experiments. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-006 Title: REG-NGGC-0005, Performance Evaluation Assessment Personnel Training and Development, Qualification, and Certification Program, Revision 0

~Descri tion:

The activity evaluated is Revision 0 to REG-NGGC-005, "Performance Evaluation Assessment Personnel Training and Development, Qualification, and Certification Program." This procedure provides direction to ensure Performance Evaluation Support (PES) personnel become informed about assessment work practices, acquire the basic knowledge, skills, and attitudes needed to meet job requirements, provide specific qualification and certification requirements, and provide for future career development.

S~fS REG-NGGC-0005, Revision 0, represents an administrative change and enhancement to the assessment training process for PES personnel. This procedure in and of itself cannot effect changes to the facility and procedures as described in the SAR, or authorize new tests or experiments. Codes, standards, design bases, and normal or emergency operating procedures are not being changed by the new procedure. This change does not have any direct impact on systems, structures, or components important to safety, either through modification or design bases changes. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-007 Title: ESR 98-00008, Revision 0

~Descri tion:

ESR 98-00008 evaluates the impact of increasing reactor power and increasing T, for a turbine synchronization process that is "bumpless" (i.e., synchronization would have minimal impact on plant parameters and a minimum number of actions for the operator).

This process requires that reactor power and subsequently steam flow through the condenser dump valves would have to be increased substantially prior to turbine synchronization in order to reduce post turbine synchronization impact. This will be accomplished by increasing reactor power, increasing T,s and simultaneously lowering the steam dump setpoint.

Safet Summar The proposed change does not introduce new components or processes into turbine synchronization; it simply increases pre-synchronization reactor power and T,~ to a level that more closely matches the post turbine synchronization conditions instead of causing a transient by closing the output breaker. Existing accident analyses bound the proposed increase in initial reactor power level and T,~. No new accident scenarios are created as the result of this change. Accident mitigating equipment, specifically components required to remove decay heat, are not challenged to remove more heat when compared to the existing analyses. When compared to the low power analyses, the proposed turbine synchronization conditions provide additional safety injection response time, due to core power, before re-criticality when compared to the current accident analyses. The change described in ESR 98-00008 will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE ¹98-008 RAF 2491 Title: Removal of Valves 2CS-V589SA, 2CS-V590SB, 2CS-V587SA, and 2CS-V588SB From Active Valve List

~Descri tion:

The subject of this evaluation is a correction to FSAR Table 3.9.3-13 "NSSS Supplied Active Class 1, 2, and 3 Valves." Active valves are defined as those valves requiring mechanical motion in performing a safety function. Valves 2CS-V589SA, 2CS-V590SB, 2CS-V587SA, and 2CS-V588SB are suction cross-connect valves separating the three Charging and Safety Injection Pumps (CSIPs). The valves were originally installed to make the system single failure proof, by allowing the pumps to take common suction from the Residual Heat Removal System (RHR) pumps or the Refueling Water Storage Tank (RWST) during injection, and then split into two independent trains during the recirculation phase. Westinghouse identified a safety problem with this arrangement in that failure of one RHR pump would cause complete loss of that train, while using a common suction header allowed either RHR pump to supply any of the three CSIPs. The operating procedures in the switchover sequence were revised, per Westinghouse letter CWS-CQL-3224, dated September 27, 1985. However, the suction isolation valves were left in FSAR Table 3.9.3-13, even though they were no longer included in procedures for safe shutdown, and no longer met the definition of "active" valves. Check valves were added to the RHR pump discharge flow paths to prevent "loop" flow, from the discharge of one RHR pump back through the common suction header to the other RHR pump, which could have occurred in the event that one RHR pump failed.

Additionally, Valve 3CX-RSSB-1 was incorrectly listed on FSAR Table 3.9.3-14 as 3CX-BSSB-1. This typographical error was corrected.

Safety Summary:

The current analyzed condition of the systems do not include the four suction cross connect valves. Removing these four valves from the active valve list does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-009 RAF 0 2492 Title: Update of Active Valve List (FSAR Table 3.9.3-14)

~Descri tion:

FSAR Table 3.9.3-14, Non-NSSS Supplied Class 1, 2 and 3 Active. Valves, is being revised to remove chilled water (CW) supply valves 3CX-W16SA (1CH-299) and 3CX-22SB (1CH-660) from the active valve list. Air Handler AH-12 supplies cooling capacity to RAB Switch Gear Room A. The AH is supplied with two independent trains of cooling water from the ESCW system. The CW supply is controlled in the A train via ICH-279 and in the B train via ICH-660. The AH also has two fans (IA-SA and 1B-SA) both of which are powered by the A electrical bus. AH-13 supplies cooling capacity to RAB Switch Gear Room B. The AH is supplied with two independent trains of cooling water from the ESCW system. The CW supply is controlled in the A train via 1CH-299 and in the B train via 1CH-680. The AH also has two fans (1A-SB and 1B-SB) both of which are powered by the B electrical bus.

S~III FSAR Section 3.9.3 defines active valves as those components that require a mechanical motion in performing a safety function. Safety-related equipment is defined as equipment whose failure could prevent satisfactory performance of one or more of the following functions: emergency reactor shutdown, containment isolation, reactor core cooling, containment and reactor heat removal, and prevent significant radioactivity release.

Failure of the valves being removed from the active valve list would not prevent operation of the associated air handling unit (AH-12 or AH-13) as these valves supply opposite train cooling. Normal maintenance and testing will continue to be performed to ensure that area temperatures are maintained. CW is not considered an accident initiating system. Therefore any changes to the operation of that system could not introduce the occurrence of an accident. However, as these valves are not tested as part of the IST, they can not be credited in single failure analysis. Therefore, assuming failure of the alternate CW control valve to the corresponding AH (3CX-W15SA for AH-12 and 3CX-W23SB for AH-13) could result in loss of area cooling in the SWGR room A or B and potentially the components located in that area. However, the opposite train cooling coil is not relied upon. In the event of a single active failure either SWGR room A or SWGR room B will be maintained at an acceptable temperature. As only one bus is required for safe shutdown, this is acceptable. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

SE 0 98-010 RAF 0 2496 Title: Inservice Testing of Pumps and Valves

~Descri tion; This FSAR change revises FSAR Section 3.9.6 and Appendix 3.9D. The revisions are editorial in nature to consolidate and clarify descriptive information regarding the Inservice Testing (IST) Program. Information which is no longer applicable or accurate is removed, and reference to the controlling IST Program Plan, HNP-IST-002, is added.

S~fS No actual plant modifications are involved with this FSAR change. The IST Program is conducted in accordance with the ASME Code as required by 10 CFR 50.55a. Revising the FSAR information describing the IST Program does not impact the required testing of pumps and valves in the plant. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-011 RAF 0 2493 Title: Spent Fuel Cask Drop Accident

~Descri tion:

This FSAR change revises FSAR Section 15.0.1. This change incorporates License Amendment 73 with respect to the Spent Fuel Cask Drop. This change is being made to match the analysis of the Spent Fuel Cask Drop accident currently presented in Section 15.7.5 of the FSAR.

Safet Summar No actual plant modifications are involved with this FSAR change. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-012

. Title: OP-127, Steam Generator Blowdown, Revision 15 Temporary Change 00002

~Descri tion:

The activity evaluated is a temporary change to OP-127 which takes manual control of the containment isolation valve (1BD-49) for "C" steam generator (S/G) blowdown (BD) header.

The valve is opened in manual for a short time to ensure the C S/G BD header is filled prior to placing the header in service as described in the FSAR. The valve is throttled open with an operator standing by until the air bubbles are swept out of the line. The procedure change recognizes that the isolation valve is inoperable and returns it to the shut position as rapidly as possible and back to the automatic control mode. This change is written to avoid water hammer events.

S~fS This change does not impact the operation of the backup containment isolation valves inside containment, nor does it impact the other headers. 1BD-49 is being placed in the manual mode and opened a small fraction; it has not failed. The valve can be shut by manual operation if necessary and the closed system is still isolating the reactor coolant system from the public. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE¹98-013 RAF ¹ 2508 Title: Editorial Correction to Chemical and Volume Control System Flow Diagrams

~Descri tion:

This activity corrects the safety class designation on two flow diagrams (2165-G-0804 &

2165-G-0805). Flow diagram 2165-G-0805 correctly showed valve 3BR-D2SN-1 (1BR-

9) and the piping downstream of the valve as Class 3 from Revision 0 to Revision 20, During the Cad Conversion in Revision 21 the Class break was mistakenly reversed which created this error.

Additionally, Flow diagram 2165-G-0804 and Piping Drawing 2165-G-0145 required revision to correct a wrong Class break. The Class break goes from Safety Class 3 to Non-Safety Class 6. This is incorrect. It should show the class break going from Safety Class 2 to Non-Safety Class 6 which is correctly shown in a different location on the drawings.

Safet Summar These changes correct the safety designations on flow diagrams to make them consistent with other approved design documents and the actual plant conditions. No changes are being made to any plant equipment. This change does not increase the probability or consequences of accidents or malfunct!ons of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce

, any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-014 Title: ESR 98-00016

~Deseri tinn:

ESR 98-00016 involves manual operation of steam tunnel fans and local Main Feedwater Isolation Valve (MFIV) actuator temperature measurements to ensure operability of the MFIVs. The compensatory actions in this ESR are a result of identifying a new design input to the MFIVs. Temperature monitoring data has indicated that a low temperature starting point of 30F may reduce MFIV actuator temperatures to less than 60F. In order to ensure operability of the MFIVs, operators will manually secure the operating steam tunnel fan(s) when outside ambient temperature drops to 40F or less. This is a temporary compensatory action.

Safet Summar There are no physical changes being made to the plant as a result of this ESR. Increasing the frequency of actuator temperature monitoring will provide increased assurance of operability of the MFIVs. Manually securing the steam tunnel fans when outside ambient temperature drops to 40F will ensure the MFIV actuators remain above 60F and do not become inoperable due to cold weather. The MFIVs will still be able to perform their isolation function within the maximum 10 second time limit for containment isolation.

The temporary compensatory actions evaluated in ESR 98-00016 will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-015 RAF ¹ 2497 Title: ESR 9600433, Charcoal Canister Permanent Installation

~Descri tion:

ESR 9600433 provides a hose connection to the drain line, between the two drain valves, from the "A" Laundry and Hot Shower Tank. The connection allows use of a cam-lock fitting to allow quick attachment of a hose for portable waste treatment equipment.

Safet Summar The hose connection being added is constructed to the same standards as the drain line which it is being installed. The hose connection is in a drain line, close to the floor drain into which the drain line is routed. Thus any spill from the connection would go on to the floor, then into the drain system. The Laundry and Hot Shower System is a non-nuclear safety system. Addition of this hose connection does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-016 RAF ¹ 2498 Title: LOCA Analysis Acceptance Criteria

~Descri tion:

This change to FSAR Section 6.3.3 and 15.6.5 clarifies the LOCA Acceptance criterion to agree with wording in 10 CFR 50.46. The previous acceptance criterion in the FSAR stated that th'e total amount of fuel element cladding that reacts chemically with water or steam does not exceed 1 percent of the total amount of Zircaloy in the reactor. The change made excludes the cladding surrounding the plenum volume. The previous acceptance criterion was less conservative in that a limit of <1% of all Zircaloy in the core represents a less restrictive limit than <1% of the Zircaloy in the cladding immediately surrounding the fuel pellet stack.

S~fS The scope of this change is limited to the LOCA analysis acceptance criteria. The LOCA acceptance criteria is not related to accident initiation as described in the FSAR. This change has no affect on the failure modes effects analysis presented in the FSAR. This change is limited to the LOCA analysis acceptance criteria and does not affect plant design or operation. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SEC 98-017 RAF 0 1918 Title: ESR 9500078, Abandonment of Waste Processing Building Filter Backwash Pumps A & B Suction Pressure Instruments.

~Descri tion:

This activity (ESR 9500078) abandons the Waste Processing Building Filter Backwash Storage Tank Pump A & B suction pressure lo instruments PS-":1WL-6314A and PS-

• 1WL-6314B. In addition, the annunciator windows for the respective pump will be changed accordingly. The normal position of the associated instrument root isolation valves have been revised to Normally Closed to exclude the process pressure boundary from the abandoned tubing and related instruments in the unlikely event a leak would develop or the tubing is accidentally damaged.

Safet Summar Abandonment of these non-safety Quality Class "E" instruments will not affect waste processing operations ability to safely drain down the Filter Backwash Storage Tank. No safety related equipment or electrical system is affected by the instrument abandonment.

The instrument root valves are left in the Normally Closed position for added assurance that the downstream abandoned pressure switch/tubing configurations will not be subjected to process boundary pressures in the unlikely event it is damaged or is inadvertently opened. Seal water pressure instrumentation remains intact, which helps ensure that process boundaries are maintained on the storage tank pumps. The tank level instrumentation is not affected by this change. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE¹98-018 RAF ¹ 2529 Title: Installation of time delay relay for QPTR alarm

~Descri tion:

The proposed activity is to correct spurious Quadrant Power Tilt Ratio (QPTR) alarms.

This will be achieved by the installation of a time delay no greater than 1.5 minutes for actuation of the Upper Flux Deviation & Auto Defeat and Lower Flux Deviation & Auto Defeat alarms on the main control board.

Safet Summar The QPTR alarm is described in TS 3/4 4.2.4. The addition of a time delay of up to 1.5 minutes for the QPTR alarm does not require a change to Technical Specifications. The QPTR alarm is not an accident initiating system as described in the FSAR. This circuit does not perform any automatic accident mitigating functions. The circuitry being changed only affects the non-safety related main control board annunciators for the QPTR alarms. Therefore, this change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of eouipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-019 Title: ESR 98-00032, Calculations for Pressurizer Heater Power Output

~Descri ttnn:

ESR 98-00032 was developed to determine "correction factors" for feeder cable voltage drop and degraded voltage to be used in the performance of MST-E0023 (calculation of Pressurizer Heater Backup Group IA & 1B KW output). No changes are made to the acceptance criteria (125 KW minimum heater output). These correction factors will allow for more accurate trending of heater output KW since variations in output KW due to supply voltage differences between tests will be eliminated.

S~S The changes being made do not make any physical changes to the Pressurizer Heaters, do not make changes to the way the heaters are operated, nor make changes in heater KW output or acceptance limits. The only change is in the methodology by which heater output KW is calculated in the quarterly verification of Pressurizer Heater output. The new methodology is more conservative which will help ensure that any heater degradation will be identified during testing such that corrective maintenance can be performed if necessary and to allow more accurate trending of data. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-022 Title: ESR 98-00054, Revision 0

~Descri tten:

ESR 98-00054, Revision 0 evaluates a Demineralized Water System pipe temporary repair.

Safet Summar The Demineralized Water System is a non-safety related system. There are no safety-related systems or equipment in the area of the leaking pipe. The leaking pipe does not constitute a new radioactive leak path. There are no new accident initiating scenarios created by this ESR, and no safety-related system functions or equipment will be impacted by the repair. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-023 RAF 0 2503 Title: Maintenance Reorganization

~Desert tton:

The activity evaluated is an organizational change within the plant Maintenance Unit.

FSAR Chapter 13.1.2 is being revised to reflect realignment of responsibilities and title changes among the superintendents that report to the Manager - Maintenance.

Safet Summar No organizational responsibilities are being deleted as a result of this change.

Organizational responsibilities are only being realigned within the plant Maintenance Unit. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor does it introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety; Therefore, the change does not involve an unreviewed safety question.

SE 0 98-024 Title: PLP-201, Emergency Plan, Revision 32

~Descri tion:

The activity evaluated is Revision 32 to PLP-201, Emergency Plan. The changes to PLP-201 in Revision 32 include an administrative change to correct repagination and a clarification to the discussion of "Drills". Specifically, an addition clarifies the use of an integrated drill to be conducted during the time interval between FEMANRC evaluated exercises and provides a better linkage to the regulatory basis for the HNP EP drill program.

S~fS This revision to PLP-201 does not impact the operation, engineering, or maintenance of equipment, systems or components important to the safety of the plant. The conduct of the drills provides an opportunity for plant staff to practice actions in response to an accident. The change serves to better ensure that training and opportunities for practicing plant staff actions in response to accidents are maintained current. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of acci'dent or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-025 RAF 2509 Title: Main Steamline Isolation Logic

~Descri tion:

This activity changes FSAR Section 15.1.5 to clarify an editorial error. The FSAR stated in item 4.b. on FSAR page 15.1.4-2 that Main Steamline Isolation actuated on 1/3 channels on any steam generator. This change corrects this error by modifying item 4.b. on FSAR page 15.1.4-2 to state 2/3 channel are required on any one steam generator to actuate a Main Steamline Isolation signal.

~st s This FSAR change is administrative in that the design and operation of the Harris Nuclear Plant is not being modified as a result of this change. The FSAR and Technical Specifications were in conflict with respect to how many Main Steamline Low pressure signals are required to actuate a Main Steamline Isolation signal. The FSAR is being changed to be consistent with Technical Specifications and actual plant design. As such, this change is administrative and will not affect operation of the Harris Nuclear Plant. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE 0 98-026 RAF 0 2506 Title: Control Rod Position

~Descri tion:

This FSAR change revises descriptions provided in FSAR Section 15A.3.3.1 related to the control rod deviation alarm and means of determining control rod position.

Specifically, the description of the deviation alarm is revised to note that the operator is alerted to rod-to-rod deviations within the same bank in excess of "12 steps," rather than "12.5 inches." This corrects an editorial error, and is consistent with descriptions elsewhere in the FSAR and in Technical Specifications. Also, a correction is made to the description of the indirect means of determining control rod position to be consistent with AOP-001 and Tech. Specs.

Safet Summar No actual plant modifications are involved with this FSAR change. Descriptions are being revised to correct erroneous statements. This FSAR change will not impact the function of the control rod deviation alarm or the means by which operators determine control rod position. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment. and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-027 RAF ¹ 2505 Title: Pressurizer Relief Tank Hydrogen Gas Accumulation

~Descri tion:

This change addresses administrative changes to section 5.4. l I of the FSAR S~hS The administrative changes made do not alter the physical or mechanical characteristics of the PRT. No actual plant modifications are involved with this FSAR change.

Descriptions are being revised to clarify information concerning the PRT. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-028 RAF 0 2519 Title: Essential Services Chilled Water Chillers. Flow Rates and Miscellaneous Details

~Descri tion:

This FSAR change revises FSAR Figure 9.2.8-2, Essential Services Chilled Water (ESCW) Chillers, Flow Rates and Miscellaneous Details to include Air Handler AH-24 which serves the Reactor Auxiliary Building Elevation 261', Electrical Penetration Area.

The values in Figure 9.2.8-2 are being revised to reflect information contained in the design calculation (9-ESCH-001) of record. This calculation evaluates the ESCW system will be capable of supplying the cooling load for mitigation of an accident.

Safet Summar No changes to equipment or equipment operation are being introduced. The inclusion of the AH-24 operating during Normal, Cooldown, and Post-LOCA modes are within the capability of the ESCW system as described in calculation 9-ESCH-001. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor does it introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-029 RAF 2590 Title: ESR 97-00594, Heater Drain Pump Discharge Piping Material Upgrade

~Descri tion:

The activity evaluated is the replacement of Heater Drain piping pressure boundary components suffering from Flow Accelerated Corrosion and/or severe service damage.

The components are being changed from carbon steel to stainless steel. The components affected are in Heater Drain Pump 1A and 1B-NNS discharge lines and consist of pipe, S~

pipe fittings and the pump discharge flow elements FE-1HD-1255A and FE-1HD-1255B.

~

The Heater Drain and Vents System is not an accident initiating or mitigating system.

The change in materials will increase the overall system reliability and help decrease the probability of a piping component failure. Flow elements FE-IHD-1255A and FE-1HD-1255B will be replaced with "like in kind" with only minor dimension differences which will not result in any actual operational or procedural changes. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications.

Thus, no unreviewed safety question exists.

SE 0 98-030 RAF N 2510 Title: Generic Letter 96-05, Reference in FSAR

~Descri tion:

The activity evaluated is the addition of wording to the FSAR (Section 6.3.2) acknowledging the Harris Plant's commitments to NRC Generic Letter (GL) 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. GL 96-05 requests the establishment of a program to verify on a periodic basis that safety-related Motor Operated Valves (MOVs) continue to be capable of performing their safety functions within the current licensing bases. The MOV program at the Harris Plant was revised to implement the requirements of the commitments to this Generic Letter.

~s<<s The GL 96-05 program is a testing program only. This testing provides a higher confidence that equipment will perform as designed. This change does not affect the design, function, or method of performing a function '.hat the NRC relied upon in concluding that the facility may operate without undue risk to the health and safety of the public. It does not change any analyzed accident, change the consequences of an analyzed accident. create a new accident or change the margins of safety previously analyzed. Thus. no unreviewed safety question exists.

SE 0 98-032 RAF 2511 Title: Detection of Reactor Coolant leakage into the Pressurizer Relief Tank

~Descri tion:

safety review addresses changes made to section 5.2.5.3.3 of the FSAR. A technical change II'his to this section adds Pressurizer Relief Tank (PRT) pressure increase as an indication of Reactor Coolant leakage. This pressure effect has been observed at the Harris Nuclear Plant concurrent with seat leakage through the Pressurizer Power Operated Relief Valves and Pressurizer Safety Valves. The FSAR had previously stated that PRT level and temperature would increase but was silent on pressure affects due to influent Reactor Coolant leakage. This change provides additional information about plant parameters. Other editorial and administrative changes are made to FSAR 5.2.5.3.3 are made as a result of this change.

S~fH The method of detecting Reactor Coolant leakage into the PRT is not a factor which contributes to the probability of primary or secondary piping failures, reactivity transients, changes in secondary heat removal, changes in primary coolant inventory or flow, or releases of radioactive material. This change to the FSAR is not a result of a modification of the PRT instrumentation.

Systems, structures, or components are not being modified as a result of this change. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE N 98-033 RAF 2534 Title: ESR 97-00666, Boric Acid Flow to Volume Control Tank Makeup Mixing Tee

~Descri tion:

The reactor makeup control system (RMCS) is designed to allow makeup water and boric acid solution to be blended together at predetermined flow rates to yield a total makeup flow of a desired boron concentration. The current design includes a non-adjustable "external" setting of 120 gpm for the total makeup flow when the RMCS is operated in the automatic mode. ESR 97-00666 will modify the system design to allow the total makeup flow to be set by the operator to values below 120 gpm while in the automatic mode. This will allow higher blended flow concentrations to be achieved at the current maximum boric acid flow rate.

S~S This change will replace the "external" non-adjustable setting for total makeup flow to an "internal" adjustable setting. The RMCS system operation is essentially the same with the exception that the operator will now be able to set the total makeup flow rate. The minimum total makeup flow will be limited to 50 gpm to ensure that the flow remains within the flow sensing capabilities of the instrumentation. Reducing the total makeup flow rate to less than 120 gpm as described in ESR 97-00666 does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-034 Title: PEP-410, Communication and Facility Performance Tests, Revision 2 D~escri tion:

The activity evaluated is Revision 2 to PEP-410, "Communication and Facility Performance Tests." This procedure describes the proper methods for conducting required tests of the selective signaling system, FTS-2000, Emergency Operations Facility and Technical Support Center emergency ventilation systems, and periodic communications tests. This revision reflects the consolidation of siren information into one procedure and corrects various consistency problems within the test procedures. Clarification statements and changes in titles have also been added as an enhancement to overall procedure usage.

S~S This procedure describes tests of equipment that support the Emergency Plan. The tests described in this procedure are routine tests that document system operability. No new equipment is utilized as a result of this procedure revision, and there is no impact on safety related equipment. The equipment continues to support the accidents evaluated in the safety analysis report. The effectiveness of implementing the Emergency Plan has not been reduced.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-035 Title: ESR 98-00056, POWERTRAX Update

~Descri tien:

The activity evaluated is ESR 98-00056 which: (I) provides an in-cycle update to POWERTRAX input and database files,'and (2) transfers the updated files from a testing directory to the production directory. POWERTRAX is an off-line computer code that provides predictions for various core related parameters including power peaking factors, power distributions, reactivity coefficients, estimated critical positions, and shutdown boron requirements. The database updates are small parameter corrections and user preference items.

The input file impacted is used for trending purposes.

s~fs The proposed activity constitutes a routine in-cycle code update that does not modify the POWERTRAX design and installation requirements. POWERTRAX does not provide input to the reactor protection system or to engineered safety features actuation system functions.

POWERTRAX is an off-line code which is completely segregated from core on-line processes; it does not interface with any design basis accident initiating or mitigating system. This ESR does not introduce any changes to the reactor operating requirements as stated in the Technical Specifications. In conclusion, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety. question exists.

SE 0 98-036 Title: PEP-440, Public Notification and Alerting System. Revision 2

~Descri tion:

The activity evaluated is Revision 2 to PEP-440, "Public Notification and Alerting System."

This procedure describes the programmatic criteria for the Public Notification and Alerting System (tone alert radios and sirens). This revision reflects the consolidation of siren information into this procedure. It also includes the correction of typographical errors, renumbering, and clarification of siren information.

Safety Summary:

This procedure describes the Public Notification and Alerting System. The changes described in this revision provided administrative clarifications and programmatic enhancements for the users and do not effect accident analysis or probability of occurrence. The procedure revision reflects the consolidation of siren information into the procedure. The addition of the Annual Operability criteria and Loss of Siren information allows a consolidation of information for the siren system.

This change has been determined to not increase the probability of occurrence of an accident as previously evaluated in the SAR. The sirens and tone alert radios are a means of notification of the public during an accident at the plant. This equipment is not used for assessment of an accident nor does not impact previous accident analysis. As such, the overall effect of this procedure revision is an enhancement to procedure usage. This change does not introduce a different type of accident or equipment malfunction. The change does not decrease the margin of safety as described in the Technical Specifications. Therefore. no unreviewed safety question exists.

SE 8 98-037 Title: ESR 98-00069, Revision 0

~Deeeri iion:

ESR 98-00069, Revision 0 changes the reed switch adjustment requirements for Post Accident Hydrogen Sampling System Containment Isolation Valves. Changing the reed switch "enrichment" used for Target Rock Model 79Q-018-1 valves should improve valve position indication reliability.

Safet Summar The change will reduce valve position indication malfunctions. The change will not change, degrade or prevent the response of the valves during accident conditions. The valves will continue to meet their design standards. The performance of the Containment Isolation and Post Accident Hydrogen Sampling Systems are not affected by ESR 98-00069. The valve setting modification will not impact any accidents associated with the Post Accident Hydrogen System Analyzer Cabinet Containment Isolation Valves. The environmental and seismic qualification ol'he valves is not impacted by this change.

This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. does not introduce a different type of accident or malfunction of equipment.;ind does not reduce any margin of safety.

Therefore. the change does not involve <<n unreviewed sat'ety question.

¹ SE 98-038 RAF¹ 2515 Rev. 1 Title: ESR 98-00092, Pressure Relief Valve 3FD-703 Removal

~Descri tice:

The activity evaluated is the removal of pressure relief valve 3FD-703 which is mounted on the inlet to the Modular Fluidized Transfer Demineralization System (MFTDS) skid.

Safet Summar The setpoint on valve 3FD-703 is 150 psig. The maximum pressure experienced by the inlet to the skid is 122 psi from the Waste Monitor Tank pump. The only ASME VIII code vessels within the skid are protected by other relief valves (3FD-720 and 3FD-728).

No other components within the MFTDS skid are required to be protected by relief valves and therefore it is acceptable to remove valve 3FD-703. The MFTDS will continue to function in the same manner and no changes to operating procedures are required. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

'

SE 0 98-041 RAF-2545 Title: ESR 96-00492 Rev.5, Digital Portable Telephone System

~Descri tion:

ESR 96-00492 Rev. 5 provides the design for the installation of a digital portable telephone system. An Ericsson DCT 1900 Wireless PBX system will be installed at HNP.

Safet Summar The Ericsson DCT 1900 Wireless PBX system has been evaluated as suitable for application at HNP. It has been determined that operation of the proposed equipment in accordance with the exclusion distances specified, will not exceed industry guidelines for plant equipment electromagnetic interference (EMI) or radio frequency interference (RFI). Communication cable installed exposed (not in conduit) for the phone base stations meets or exceeds IEEE 383. The combustible loads added have been evaluated as insignificant. Operation of the PBX system will have no adverse impact on any plant equipment. Thb installation and subsequent operation of the PBX equipment will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the modification does not involve an unreviewed safety question.

SE 0 98-042 RAF N 2518 Title: Calibration Source Radiation Measuring instruments

~Descri tion:

The activity evaluated is allowing the use of an electrometer or other equivalent instrument to determine the source-to-detector distances used for survey instrument calibration. The Harris FSAR describes the condenser R-meter as the instrument used to determine source-to-detector distances for survey instrument calibration. This same function can be performed with an equivalent instrument such as an electrometer, which is the type of instrument used for this purpose at other CP&L facilities. Allowing the use of an electrometer or other equivalent instrument at Harris will allow calibration standards to be shared among CP&L's nuclear facilities.

S~fS The use of an instrument other than the condenser R-meter changes both the HP equipment and source calibration procedure described in the FSAR. The substitution of an equivalent instrument does not, however, impact th ability to accurately determine the source-to-detector distances to be used for survey instrument calibration. Plant activities and equipment outside of the instrument calibration facility will not be affected. There is no impact on fission product barrier status or on the health and safety of personnel.

Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-043 RAF ¹ 2522 Title: General Layout of Containment Building Foundation Mat

~Descri tion:

FSAR Figure 3.8.5-4, General Layout of Containment Building Foundation Mat is being updated to reflect civil design detail changes approved and implemented during Containment construction. The added details include construction joint details and descriptions of materials utilized in the placement on concrete during Containment Building construction.

Safet Summar The design detail changes being incorporated into FSAR Figure 3.8.5-4 were appropriately reviewed and approved during the plant construction phase. The changes were in accordance the applicable seismic criteria and industry standards. The FSAR figure is being updated to reflect more accurate details regarding the construction of the Containment foundation mat. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

¹ SE 98-044 RAF ¹ 2521, 2624, 8c 2635 Title: Pipe Break Locations Reactor Coolant Piping

~Deseri finn:

FSAR Figures 3.6A-20-CALC, Containment Building Summary of Pipe Break Locations Reactor Coolant Piping Loop ¹1, Sheets through 3 are being deleted and Figures 3.6A-1 20-1 CALC, Containment Building Summary of Pipe Break Locations Reactor Coolant Piping Loop ¹I Sheets 2 and 3 are being revised. Figures 3.6A-20-CALC were superseded by Figures 3.6A-20-1 CALC, which eliminated arbitrary intermediate pipe breaks for Reactor Coolant piping in all 3 loops, issued by FSAR Amendment 27. The superseded Figures 3.6A-20-CALC were not removed from the FSAR as they should have been. Minor corrections are also being made to Figures 3.6A-20-1 CALC and 3.6A-20-PLOT-B based upon a comparison of the summary of calculation information details on the FSAR Figure with the existing associated Ebasco calculations.

Safety Summary:

These changes to the FSAR Figures represent a summary of design calculations previously approved through the design calculation process and by HNP's AE (Ebasco) prior to plant operations. The reduction in postulated line break locations has been analyzed as acceptable and documented in site calculations. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore. the changes do not involve an unreviewed safety question.

SE 0 98-045 Title: CRC-215, Primary Auxiliary Systems Chemical Control, Revision 16

~Descri tion:

The changes made to procedure CRC-215 address containment spray additive tank (CSAT) mixing by nitrogen sparging through the sample line, chemical additions, chemical addition calculations, and independent verification of valve manipulations. The changes are consistent with Technical Specifications and the FSAR which assume that the CSAT will be sampled and analyzed periodically and when necessary the caustic concentration will be adjusted to maintain the concentration in the allowable band.

~ss The proposed changes Ichemical addition and tank mixing] are expected to occur rarely and will be done under appropriate administrative controls within operability and time constraints. The

'proposed changes cause no adverse'impact on FSAR Chapter 15 initiating events such as loss of coolant or boron dilution. The operation and safety functions of the containment spray system will be reestablished upon completion of the tank mixing and chemical. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE N 98-046 Title: PEP-310, Revision 5

~Descri tion:

Revision 5 to PEP-310, Notifications and Communications, involves human factor improvements, improved legibility of forms and procedural guidance, and inclusion of guidance from EPL-001. Attachment 10 changed the containment pressure indications to the most limiting indications.

Safet Summar No plant or equipment modifications are involved with this change. This change makes improvements to an Emergency Preparedness procedure. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 6 98-047 Title: PEP-400 Revision 4, Supplemental Procedure

~Descri tion:

The activity evaluated is PEP-400 Revision 4, Supplemental Procedure. The changes being made clarify record retention responsibilities, the 50.54(q) process, the ERO Additions request forms, deletion of the NRC 4 requirement, and enhancements to the readability of the procedure.

~Sh S The changes being made to PEP-400 are basically administrative and process enhancements.

These changes do not alter the original design specifications or degrade the structure, system, or components. As such, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

0 SE Ã98-04S RAF-2552 Title: Drawing Correction, CAR-2165-G-0044 (FSAR Figure 10.1.0-3), Flow Diagram Feedwater System

~Descri iion:

The subject of this evaluation is the revision to plant design drawing CAR-2165-G-0044 (FSAR Figure 10.1.0-3), Flow Diagram Feedwater System, to correct valve number 2AF-V116SAB-1 to 2AF-VI16SA-l. A drafting error made on Revision 19 of the drawing caused the valve numbe'r safety train to be changed from SA to SAB. This revision corrects the error and brings the drawing into compliance with current plant design.

Safet Summar This is an administrative revision to correct a drawing valve number safety train designation to bring it into concurrence with the current plant design. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, nor does it reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-049 Title: PLP-608, Revision 5

~Desert tion:

PLP-608, "Q-List Development and Maintenance" is a program description that assigns responsibility for development, maintenance and use of the Q-List at HatTis. The Q-list identifies items to which the Quality Assurance Program applies. The list consists of an item identification and Quality Class. Revision 5 of PLP-608 is a complete revision that updates references and organizational changes and clarifies the basis for the Q-List. No new responsibilities or changes in responsibilities have been added.

S~S PLP-608 is not used to operate or maintain the plant. The changes made to PLP-608 are administrative in nature. PLP-608 does not impact accident initiation, accident mitigation, equipment operation or bases for Technical Specifications. The changes will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

SE ¹98-050 RAF ¹ 2557 Title: Main Steam Safety Valve Blind Flanges (ESR 98-00085)

~Desert tion:

This change revises FSAR Section 10.3.2 by stating that the Main Steam Safety Valves (MSSVs) may be removed and blind flanges temporarily installed to maintain containment closure while in Modes 5 or 6. This will facilitate maintenance on the MSSVs and maintain containment closure requirements.

Safet Summar The purpose for the change is to provide containment closure for the piping locations of the MSSVs when the valves are removed and/or cannot be re-installed when required for containment closure. The use of a blind flange as a closure device is limited to Modes 5 and 6. The closure device ensures containment closure is achieved when the associated valve is removed. The fuel assembly drop event analyzed in FSAR Section 15.7.4 is not affected by this change. The use of a blind flange does not create any new accident scenario or equipment failures important to safety. The blind flange is a passive component and does not interact with any other equipment while installed. It is secured sufficiently to provide containment closure, withstand a seismic event and is compatible

. with the mating flange. The blind flange will eliminate a release path from containment and will serve the same function in Modes 5 and 6 as a closed MSSV. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-051 RAF 2553 Title: ESR 96-00511, Upgrade of the Fire Detection Computer

~Descri tion:

ESR 98-00511 upgrades the Fire Detection System. The alarm processing system is being upgraded to obtain greater operational flexibility by replacing various obsolete components and associated interfaces. Similarly, the obsolete Main Fire Detection Information Center (MFDIC) Security Information Retrieval System (SIRS) Computer System is being replaced with a commodity-based, desk-top Personal Computer. Fire and trouble alarm status transmittal to the ERFIS Computer and the Main Control Room Annunciator remain functionally unchanged. Additionally, ESR 96-00511 will resolve "Year 2000" compliance problems with the existing system Central Control Unit (CCU) digital multiplexing system firmware and operation/application software for the MFDIC SIRS Computer. The upgraded system will also allow full field-programmability of the MFDIC data base, rather than relying on vendor controlled firmware changes to add, delete or modify an alarm point.

S~S The Fire Detection System upgrade addressed by this ESR does not have any adverse affect on the plant safe shutdown analysis. The SAR Fire Hazards Analysis (FSAR ~

Appendix 9.5A) remains unchanged. The CCU digital multiplexing system and associated interfaces, along with the MFDIC SIRS Computer System, which are impacted by this ESR, perform display and monitoring functions only, and do not have any direct control or accident mitigating capabi! ities. By replacing obsolete equipment components with known "Year 2000" compliance problems and through field programmable control of alarm points, a greater reliability in system display and monitoring functions will be achieved. A continuous fire watch will be maintained during equipment reconfiguration and will remain until completion of post modification testing activities. In this manner.

the effectiveness of the Fire Detection System will not be degraded during modification implementation. This modification does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-052 Title: PEP-230, Control Room Operations, Revision 2

~Descri iion: S The activity evaluated is a revision to procedure PEP-230, Control Room Operations which provides improved guidance associated with ensuring Control Room ventilation for habitability post accident. The changes provide more thorough and consistent application of emergency response protocol including PA announcement guidance and other human factors enhancements.

I~IS These enhancements are a result of drill feedback and human factor improvements. The overall effect of this revision is an enhancement to communications and procedure usage. The verification of control room HVAC does not provide for any operation other than what is currently described in existing procedure's, FSAR, and Technical Specifications. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-053 Title: PEP-340, Radiological Assessment, Revision 5

~Desert tion:

The activity evaluated is Revision 5 to PEP-340, "Radiological Assessment." This procedure provides instructions for calculating projected off-site doses due to actual or potential radiological releases and for calculating the extent of damage to the reactor fuel. This revision includes: (1) typographical and editorial corrections, and revised terminology, (2) updated computer usage guidance, (3) addition of Emergency Operating Procedure values for top and bottom of the core, and (4) enhancements to reflect the correct timing for drawing a sample and proper usage of certain graphs.

ssss:

This procedure provides input to decision making for plant mitigation and recovery during a declared emergency. No plant equipment is operated in this procedure. The procedure changes provide corrections, enhancements, and an easier to use format. There is no impact on safety related equipment. The overall effect of this procedure revision is expected to be an enhancement to communications and procedure usage. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-054 RAF 2550 Title: ESR 98-00020, Steam Generator Preheater Bypass Valves Modification

~Descri tion:

ESR 98-00020 modifies the steam generator (SG) feedwater preheater bypass valves.

The feedwater preheater bypass valves (1AF-64, IAF-102 and 1AF-81) are open during normal operations and close upon receipt of a main feedwater or containment isolation signal. The valves also automatically close if control air is lost, which is the motive force to the valve operator. This modification relocates the sensing points for the control air pressure switches PS-01IA-9790SA and PS-01IA-9791SB from the RAB on the instrument air header which supplies instrument air to additional equipment beyond the steam tunnel to a dedicated common supply header for the three S.G. preheater bypass valve actuators. This design change will ensure sensing of the air pressure (control air) which, if lost through a postulated "smart leak", could result in a slow bleed of the accumulator pressure on the operator and render the valves inoperable. A reduction of the regulated air pressure in the common header to 66 psig (+1 psi) will result in the simultaneous closure of AF-64, 1AF-102, and 1AF-81 by the action of pressure switches PS-01IA-9790SA and/or PS-01IA-9791SB.

Additionally, FSAR Table 6.2.4-1 (Containment Isolation System Data) is being revised to correctly identify the S.G. preheater bypass valve's primary actuation mode as automatic and the secondary actuation mode is remote manual. These were incorrectly shown as remote manual and manual in the table. FSAR Table 9.3.1-2 (Safety Class Valves with Accumulators) is being revised to add the S.G. preheater bypass valves as safety class valves with accumulators. These valves were not previously identified in the table. FSAR section 9.3.1.3.b is being revised to reflect the S.G. preheater bypass valves do have accumulators. FSAR section 10.4.9.1 is expanded to describe the operation of the S.G. preheater bypass valve actuator.

S~fS The instrument air redesign is to ensure the loss of air pressure does not result in the failure of the SG feedwater preheater bypass valves to close. This ensures containment isolation is available for the three valves as required. The "smart leak" method for air loss was not postulated in earlier system designs. This redesign addresses the "smart leak" method and prevents this failure mode. The reliability of equipment is enhanced by the installation of this modification. This modification does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-055 RAP-2460 Title: Q-List FSAR Table 3.2.1-1

~Descri tion:

This evaluation adds a Note (43) to FSAR Table 3.2.1-1 to clarify the bases for the Quality Classes of the Water Chillers and to ensure that the Quality Class breaks are clearly defined. This note should have been added as part of PCR 4987 but was overlooked. The actual Quality Classes are not changed under this evaluation.

SSSS:

The water chillers are part of the HVAC system. They are used to mitigate the consequences of an accident. Adding this note to the FSAR Table 3.2.1-1 does not change the way the equipment is to be operated and maintained, nor does it change any equipment that relies on the water chillers for operation. In fact, adding a note of clarification provides additional assurance that the equipment will be operated and maintained using the appropriate quality requirements. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE n 98-056 RAF N 2524 Title: Containment Fan Cooler > I 18' Mode of Operation

~Descri tion:

This FSAR change revises the description of normal operation for the Containment Heat Removal System provided in FSAR Section 6.2.2.2.1.2.2. Specifically, the description of the fan cooler units is revised to note that more than two coolers can be operated the "greater than 118' mode" at temperatures below 118' if additional cooling is desired.

This FSAR revision is consistent with OP-169, Revision 10, "Containment Cooling and.

V,entilation."

Safet Summar No actual plant modifications are involved with this FSAR change. This FSAR change will not impact the Containment Heat Removal System's ability to perform its safety function. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-057 RAF 0 2527 Title: Emergency Diesel Generator Lube Oil Testing

~Descri tion:

This FSAR change revises Section 9.5.7.4 which provides the inspection and testing requirements for the Diesel Generator Lubrication System. The description of specific oil analysis tests to be performed is replaced with a description of the pertinent oil constituents and parameters recommended by the engine manufacturer to be analyzed.

Safet Summar This FSAR change revises Section 9.5.7.4 to reflect the current analysis techniques for analyzing oil samples to ensure that the engine manufacturer's specifications are met.

The diesel manufacturer's recommendations will continue to be met following this FSAR change. Use of modern analysis techniques will enhance detection of oil insoluble materials, thus decreasing the probability of equipment failure. The ability of the lubricating oil system to provide essential lubrication to the components of the diesel engine during all modes of operation is not comprorrised by this change. The ability of the routine oil analysis results to provide the basis for oil change intervals is not diminished. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. does not introduce a different type of accident or malfunction of equipment. and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

SE z 98-05S RAF 0 2520 Title: Procedure REG-NGGC-0001, Employee Concern Program

~Descri tion; The activity being evaluated is the changing of the name of the Harris Quality Check Program to the Employee Concerns Program.

Safet Summar This change is an administrative change only. The title of the Quality Check Program is being changed to the Employee Concerns Program. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-059 Title: ESR 97-00417, Revision 0

~Descri iion:

ESRs 95-00344 and 95-00492 evaluated the impact of revised LOCA and MSLB temperature profiles and a revised design-basis accident (DBA) pressure profile on the qualification of environmentally qualified (EQ) equipment. This ESR, 97-00417, reevaluated the combined MSLB/LOCA temperature profile in comparison to the EQ tests contained in the EQ data packages. In addition, the peak accident temperature and pressure profile were reevaluated for each affected EQ data package.

Safet Summar The affected EQ equipment will function as designed for the necessary post accident duration. The EQ equipment will perform its design function when subjected to the revised MSLB/LOCA accident profiles. ESR 97-00417 demonstrates that the original

.tested profile contained in the EQ data packages envelopes the new MSLB/LOCA temperature and pressure profiles for the required accident and post-accident duration.

This evaluation does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 98-060 RAF 2523 Title: Deletion of 100% Load Rejection Capability Without Reactor Trip D~escri tion:

The activity evaluated is a revision to the FSAR to delete the 100% load rejection without reactor trip capability originally available at Harris. During problems with the Feedwater System during initial plant start-up, the system was modified such that the capability of accepting a large step load decrease from full power is not possible without a plant trip. On October 12, 1987, CP&L requested relief from the requirement for performing Startup Test 9108-S-05, "Large Load reduction at 100% (Turbine Runback)'hich was written to test the 100% load rejection capability and was described in FSAR paragraph 14.2.12.2.18. The test requirement was based on Regulatory Guide 1.68, Appendix A, Section 5.nn. This paragraph specified a power ascension test to "demonstrate that dynamic response of the plant is in accordance with design for the case of full load rejection." On April 15, 1988 the NRC issued a Safety Evaluation that agreed that the test was not required.

S~fS The only accident case (anticipated operational occurrence) affected by the deletion of this capability is the bounding event "Loss of External Electrical Load," FSAR Section 15.2.2. No capability is assumed in FSAR 15.2.2 that would prevent a reactor trip. The consequences of full load rejection and hence Loss of External Electrical Load are bounded by the Turbine Trip per FSAR 15.2.2.2. Since reactor trip would result in turbine trip the consequences are the same. The capability for preventing reactor trip in response to a full load rejection involves relying on non-safety related systems, i.e. Feedwater,

'ondensate and Steam Dump. The inability of these systems to prevent reactor trip is a question of capacity at full power operation. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-061 RAF 2546 Title: ESR 98-00194, Update of Drawings to Show IDW-5 Locked Closed

~Descri tion:

The subject of this evaluation is a change to the design drawings and FSAR Figure 9.2.3-I to indicate the Refueling Water Storage Tank (RWST) fill valve as 'locked-closed." LER 96-020 reported an inadvertent dilution of the RWST. The cause of the event was personnel error on the part of the operator who opened the RWST fill valve

[IDW-5] from the Demineralized Water System instead of oPening the Condensate Storage Tank (CST) fill valve. A corrective action to this event was to lock valve IDW-5 closed and revise operating procedures accordingly.

~Sf S Valve IDW-5 is non-safety related and only supplies demineralized water to the RWST.

Its normal position is closed and it is opened only to makeup loss of inventory from the RWST. The valve is not opened during an accident. Locking valve IDW-5 closed prevents it from malfunctioning by opening inadvertently and diluting the RWST. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-063 RAF 0 2540 Title: Control Rod Guide Tube Support Pins Material

~Descri tion:

This change revises FSAR Section 4.5.2.1 and Table 5.2.3-2, "Reactor Vessel Internals Material Specifications" to reflect that the control rod guide tube support pins are made of Inconel X -750 material (ASME SA-637, Grade 688). This FSAR change corrects an oversight in material identification for reactor internal corn'ponents which has existed since initial plant startup.

Safety Summary:

This FSAR change is administrative in nature. The change in material identification from stainless steel to Inconel X-750 properly identifies the material for the support pins. The function of the support pins is to maintain the control rod guide tubes in alignment with the fuel assemblies, to assure that the control rods will physically insert into the core on a reactor trip signal. The use of Inconel X-750 is consistent with providing this function.

The structural integrity of the support pins is not degraded by changing the material identification from stainless steel to Inconel X-750. The change does not adversely affect the control rod insertion capability. Inconel X-750 is already identified in the FSAR as a material used for the reactor internals. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment.

and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

SE 0 98-064 Title: ESR 98-00004, Replacement Steam Generator Haul Route and Offload

~Descri iion:

The activity evaluated is ESR 98-00004 which includes:

l. installation, use and removal of the replacement steam generator (RSG) temporary offload gantry crane and associated components;

2. installation, use and removal of the temporary haul route protection and modifications;

3. construction activities supporting activities 1 and 2 above;

4. movement of the RSGs from the offload structure to the RSG storage facility (RSGSF);

5. temporary removal and reinstallation of the RSGSF wall;

6. extension'of the crushed rock access area installed per ESR 97-00798; and

7. reinstallation of the light pole removed per ESR 97-000798.

These activities will be performed in their entirety outside of the site protected area. An offload gantry crane, located greater than 450 feet from the security fence, will be utilized to offload the RSGs from the rail cars into a hydraulic transporter. The RSGs will be moved along a prepared haul route north-northwest of the containment. During movement, the RSGs will be transported over the following utilities: emergency service water (ESW) discharge piping, street lighting circuits, storm drains, telephone lines, and abandoned piping. Prior to movement of the RSGs, the h'aul route will be tested. Construction activities associated with the preparation and restoration of the RSG offload area and the haul route modifications may be performed during any mode of operation.

Safety Summary:

External events and design basis explosive events are independent of the activities associated with this modification. The design and location of these modifications ensures that there is no interface or impact to any existing plant safety-related structures, systems o'r components, and the reliability of equipment important to safety will not be degraded. Underground utilities have been demonstrated to withstand the surcharge loading from the construction equipment and the transporter. During movement of the RSGs the normal service water system will be in operation.

Temporary protection will be installed within the zone of influence to ensure that in the event of an RSG drop, the ESW discharge piping will not be adversely impacted and that the ESW system would remain operable. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ~ 98-065 Title: OST 1036, Shutdown Margin Calculation Modes 1 - 5, Revision 12

~Descri tion:

The activity evaluated is a revision to procedure OST 1036, Shutdown Margin Calculation Modes 1 - 5, which simplifies the boron-10 depletion correction. These changes yield a corrected boron concentration that is higher and therefore more conservative. This is due to the fact that the contribution of the Boric Acid Tank (BAT), whose boron-10 abundance is close to natural conditions and therefore higher than that of the RCS, is ignored. The boron-10 depletion correction is simplified to a one-step process: multiplication by the ratio of the BOC non-depleted boron-10 abundance to the latest isotopic measurement of the RCS boron-10.

S~fS The simplification of the boron-10 depletion correction steps in procedure OST-1036 improves the reaction time of control room personnel, yields more conservative shutdown boron concentration values and eliminates a potential human factor error source associated with cumbersome equations. This revision does not change any system interface to the Reactor Protection System or to Engineered Safety Features Actuation System functions nor does it cause systems to be operated outside their design g or. testing limits. Therefore, this change g does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore. no unreviewed safety question exists.

SE N 98-066 Title: Procedure PEP-110, Emergency Classification and Protective Action Recommendations.

Revision 4

~Descri tion:

Revision 4 to PEP-110, Emergency Classification and Protective Action Recommendations, Thermocouple temperature criteria from 2400 to 2300 ',

provides for site specific criteria for PAR trigger conditions, reducing the Core Exit listing the applicable subzones for Shelter PARs in addition to Evacuation, and multiple clarifications of a non-technical nature.

S~fS This revision adds site specific information for PAR trigger points as defined within site procedures (System Description), FSAR descriptions of the Inadequate Core Cooling Monitor and Post Accident Instrumentation, and R. G. 1.97 descriptions of these systems. This ensures consistent application of the intended thresholds for PAR decisions. The reduction of the Core Exit Thermocouple criteria by 100 ' establishes the criteria at a more conservative threshold and one that is within the design range of the installed plant instrumentation. Changes associated with clerical clarifications and consistency improvements do not alter any actions or decisions.

They serve to provide for minimizing the potential for inconsistent application due to elimination of potential conflicting information within the body of the procedure. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore. no unreviewed safety question exists.

SE 6 98-067 RAF 2530 Title: Interlock P-4 For Engineered Safety Features Actuation System (ESFAS)

~Descri tion; This change to FSAR Table 7.3.1-4 (Interlocks For Engineered Safety Features Actuation System) corrects the statements of functions performed by the ESFAS Interlock P-4. Table 7.3.1-4 currently states that the "Presence of P-4 signal allows manual reset/block of the automatic reactuation of safety injection" and the "Absence of P-4 signal defeats the manual reset/block, preventing automatic reactuation of safety injection." The second statement is incorrect since absence of the manual reset/block cannot both block and allow for automatic reactuation of the safety injection. The first statement is correct and consistent with the Technical Specification Bases 3/4.3.1 and 3/4.3.2. The second statement is being revised to read "Absence of P-4 signal defeats the manual reset/block, allowing for automatic reactuation of safety injection."

S~S This change to FSAR Table 7.3.1-4 will correctly describe the P-4 function when it is both present and absent as designed. This corrected description for the absence of P-4 is in agreement with the FSAR description for the presence of P-4 and is consistent with the description in the Technical Specification Bases. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different ty'pe of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-068 Title: ESR 9800134, RCP Long Term Operability with Reduced Compartment Cooling

~Descri tton:

FSAR Section 6.2.2 describes the use of 3 non-safety Containment Fan Coil Units (CFCUs) during normal operations to maintain containment average temperature. ESR 98-00134 evaluates the temporary condition whereby AH-39 is loss and only 2 CFCUs are available.

S~hS This evaluation concludes that temperatures resulting from the loss of the AH-39 CFCU has the effect of raising the "C" RCP winding temperature, and to a lesser degree, the temperature of the EQ components in the "C" Steam Generator compartment. Sufficient monitoring and constraints were put in place to ensure integrity of the RCPs. The temperatures were evaluated for effects on EQ and found to be acceptable. While the temperature increase does reduce the qualified life of certain equipment groups, the EQ analysis of record is maintained by adjusting the replacement intervals for the effected equipment. Containment average temperatures are not affected and

. therefore post LOCA and'MSLB initial temperatures and pressures are bounded by previous containment accident analysis. This evaluation also considered the possible effect on structural components in the area cooled by AH-39 and concluded that there is no affect. The short term localized temperature increase was evaluated in this ESR and found to be acceptable. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change, does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unrevieived safety question exists.

SE ¹98-070 RAP 2538 Title: ESR 97-00451, Permanent Connections for Mobile Boilers

~Descri tion:

ESR 97-00451 installs connections to the existing steam line, feedwater line, fuel oil line, instrument air, and electrical power at the auxiliary boilers to allow a mobile package boiler to be hooked up to supply steam for either main steam or extraction steam during periods when the existing auxiliary boilers are unavailable.

S~fll The Auxiliary Steam System is a non safety-related system and is not an accident mitigating or initiating system. The steam temperature, pressure and mass flow rates will not be changed as a result of this ESR. The design pressure rating and temperature rating is unchanged. The capacity and flow rate of the mobile boiler is the same as for the installed auxiliary boilers. The mobile boiler will meet the requirements of the North Carolina Boiler and Pressure Vessel Code. Addition of these connections to the existing steam line, feedwater line, fuel oil line, instrument air, and electrical power at the auxiliary boilers does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction, nor decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-071 Title: EPT-256, Pre-Outage Flush of Service Water Vents and Drains, Revision 0

~Descri tion:

The activity evaluated is EPT-256 which provides the instructions to systematically open selected vent and drain valves of the Emergency Service Water (ESW) system to flush or attempt to flush the attached line. The purpose of flushing is to identify plugged or partially plugged lines during pre-outage conditions in order to include the repair work into the outage scope. It also aids in clearance preparation by pre-identifying plugged vents or drains that were previously relied upon for component draining. The procedure is written to complete each set of train specific valves independently. The flushing is accomplished one valve at a time and attempts to minimize the volume of waste water for processing by routing the effluent to the appropriate drainage systems.

~Sf' The ESW system is not an initiating system; ESW is designed to mitigate design basis accidents.

Implementation of this procedure does not affect the ability of the ESW system to provide cooling water to its associated'components required to mitigate an accident. Any associated and impacted equipment would function normally. The procedure limits flushing to one line at a time and requires the test personnel to shut an open valve if abnormal (accident) conditions occur. Due to system margin incorporated into the set up of the system (flow balancing), the system line up required to perform this procedure, and required operator actions, sufficient flow would be available to perform the mitigating function of the system even if the valve was open when the accident began. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-072 Title: Procedure FPP-OI4, Fire Protection Surveillance Requirements, Revision 9

~Descri tion:

The activity evaluated is a change to procedure FPP-OI4, Fire Protection Surveillance Requirements which changes the periodicity of the fire protection valve position verification from monthly to a quarterly basis. This change is being made based on review of the monthly fire protection valve position verification procedures perforined during the past three years with no valves found inadvertently out of its normal position.

H~S Based on the performance history of the valve verification procedure, changing the valve position verification to quarterly will create no adverse operability concern. The inspection periodicity will have no impact on any portion of the Safe Shutdown Analysis in Case of Fire. A fire is not postulated in a Chapter 15 accident and fire protection equipment is not analyzed as "Equipment Important to Safety." Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. Thc proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-073 Title: Procedure EM-226, Temporary Power Feed to Lighting Panel LP-132, Revision 0 D~escri tion:

Procedure EM-226 provides the, necessary instructions and controls to install and remove temporary power to Lighting Panel LP-132. LP-132 provides power to area lighting in the Turbine Building.

s~al S The. temporary power source for this lighting panel is from non-class 1E motor control center (MCC) 1D31-5AR. The impact of shifting the load of this lighting panel from its normal power source non-class 1E MCC lE31 to MCC 1D31 has been analyzed and found to be acceptable.

Power cables are sized appropriately and cables routed in areas containing safety related equipment will be installed in accordance with existing separation criteria. LP-132 is non-class 1E and provides power to area lighting in the Turbine Building. These lights are non-safety.

Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-074 Title: Procedure EM-227, Temporary Power Feed to Lighting Panel LP-133, Revision 0

~Descri iion:

Procedure EM-227 provides the necessary instructions and controls to install and remove temporary power to Lighting Panel LP-133. LP-133 provides power to area lighting in the Turbine Building.

I~IS The temporary power source for this lighting panel is from non-class lE motor control center (MCC) 1D32-9E. The impact of shifting the load of this lighting panel from its normal power source non-class 1E MCC 1E32 to MCC 1D32 has been analyzed and found to be acceptable.

Power cables are sized appropriately and cables routed in areas containing safety related equipment will be installed in accordance with existing separation criteria. LP-133 is non-class 1E and provides power to area lighting in the Turbine Building. These lights are non-safety.

Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-075 Title: POWERTRAX Source Code Update

~Descri tion:

The proposed activity implements several POWERTRAX source code modifications.

POWERTRAX is an off-line computer code that provides predictions for various core related parameters including power peaking factors, power distributions, reactivity coefficients, estimated critical positions, and shutdown boron requirements. The modifications include correction of minor code malfunctions related to the Robinson Nuclear Plant and enhancements to output edit items related to both the Harris, and Robinson Nuclear Plants. The associated source code changes are limited to a few lines which have been demonstrated to perform as expected and result in no changes to methods or functions.

S~fS The proposed activity does not change any system interface to the reactor protection system or to the engineered safety features actuation system functions nor does it cause systems to be operated outside their design or testing limits. This change does not modify any function of equipment important to safety. The source code changes are limited to a few lines and there are no changes to methods or functions. It does not introduce any changes to the reactor operating requirements as stated in the Technical Specifications. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-076 Title: EPT-328, 1SI-3 Boron Injection Tank Outlet Valve Generic Letter 89-10 MOV Test, Revision 4

~Descri tion:

The activity evaluated is Revision 4 to EPT-328. The purpose of EPT-328 is to establish test conditions required by Generic Letter 89-10 for motor operated valve 1SI-3, and capture data using, plant instrumentation and valve diagnostic equipment. This revision adds instructions for using pressure transducer/gauges to determine differential pressure across the valve. References to VOTES equipment were deleted to allow for use of other types of diagnostic equipment. The revision also reformats the procedure and provides instructions for obtaining an ERFIS short term archive. The overall purpose of the test remains unchanged.

~Sf S

, This EPT will be performed with the fuel removed from the reactor vessel. This effectively removes the possibility of mechanical damage to the fuel and subsequent release of radioactive material in the event of an MOV failure. The valve is being tested under its design conditions.

The test conditions established by this EPT have been analyzed for failure in equal or greater differential pressure conditions as part of the Generic Letter 89-10 program. The test equipment installed by this procedure does not increase the consequences of any analyzed accidents. Test gauges/transducers are approved for this application and will not introduce potential for equipment malfunction. No new control logic or changes to system operation are being introduced by this EPT. In conclusion, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-077 Title: Procedure EPT-329, 1SI-4 Boron Injection Tank Outlet Valve Generic Letter 89-10 MOV Test, Revision 4

~Descri tion:

Revision 4 to Procedure EPT-329, 1SI-4 Boron Injection Tank Outlet Valve Generic Letter 89-10 MOV Test, added instruction for using pressure transducer/gauges to determine differential pressure across valve 1SI-4 and makes format changes to the procedure. References to VOTES equipment was deleted to allow for the use of other types of diagnostic equipment. Instructions for obtaining an ERFIS short'term archive was added. The overall purpose of the test remains unchanged.

.SSSS During performance of this EPT the fuel is removed. from the reactor vessel. This effectively removes any possibility of mechanical damage to the fuel and any subsequent release of radioactive material. The overall purpose of the test remains unchanged. Valve 1SI-4 is being tested under its design conditions. No changes to the operation of plant systems or components are introduced by this change nor changes to analysis that effect the design basis of the plant.

Adding the test equipment in accordance with this procedure does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-078 Title: ESR 98-00209, Penetration Seal MR-5 for Block-out

~Descri tion:

The activity evaluated is the acceptance of penetration seal design MR-5 on penetrations P3308, P661, and P671. The seal design was fire tested with the use of a pipe sleeve and these penetrations do not use a pipe sleeve but consist of a block-out in a concrete wall or floor. This evaluation concluded that the use of the MR-5 seal design without a metal pipe sleeve was acceptable and therefore penetrations P3308, P661, and F671 are accepted as configured.

S~f ~

The penetration seal design MR-5 used for the three identified block-out penetrations was fire tested using a pipe sleeve configuration. Per discussions with the seal vendor (Promatec Technologies, Inc.) the metal sleeve is considered to be the worst case fire test condition than a concrete substrate because the concrete acts as a heat sink. The steel sleeve conducts heat more readily than concrete, representing an additional heat path through the barrier. Therefore, a block-out configuration without sleeving is a more conservative design than a sleeved configuration. Based on this, the 3-hour fire rating of this seal design used in a block-out is still valid. No fire accident scenarios are added by this evaluation. No accident scenarios different from those previously evaluated are affected. Acceptance of these penetration seals does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-079 Title: PLP-625, Harris Nuclear Plant Spent Fuel Management Program, Revision 9

~Descri tion:

The activity evaluated is a revision to procedure PLP-625, Harris Nuclear Plant Spent Fuel Management Program. PLP-625 is an administrative type procedure and the changes being made are also administrative in nature. Changes include recent organization and responsibility changes within Spent Fuel Management. The procedure is updated to reflect that qualified maintenance personnel can operate the spent fuel bridge crane and spent fuel tools for movement of spent fuel, and various other administrative changes and corrections.

S~S The changes made to PLP-625 are administrative in nature. There are no physical plant changes being made.'herefore, this procedure revision does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-080 RAF ¹ 2531 Title: Invalid Reference in FSAR Section 10.4.8

~Desert tien:

-1" This change revises FSAR Section 10.4.8 by removing a reference to "Table 10.3.5 and replacing it with a reference to "Section 10.3.5." Table 10.3.5-1 had been removed from the FSAR via Amendment 26 in 1985. Therefore, the reference to this table should have been removed.

Safet Summar This FSAR change is editorial in nature to remove a reference to a table that no longer exists in the FSAR. No actual plant modifications are involved with the change. There is no impact to any accident analysis or accident initiators. No plant systems or equipment are affected by this change. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-081 Title: ESR 98-00210, Evaluate Penetration Seal Design for Cooper Pipe

~Descri tion:

The activity evaluated is the acceptance of penetration seal design ML-2 for penetrations P477A and seal design MS-5 for penetrations P1187, P1218, and P1291. These penetrations have a cooper pipe as a penetrating element. Penetration seal designs ML-2 and MS-5 were not qualified by a fire test containing a cooper penetrating element. ESR 98-00210 concluded that use of seal design ML-2, for penetration P477A, in a configuration with cooper as a penetrating element is not acceptable. The use of penetration seal design MS-5 for penetrations P1187, P1218, and P1291 in a configuration with cooper pipe as a penetrating element is acceptable.

S~hS No new hazards or accident scenarios are being introduced by this activity. The acceptance of the subject penetration seal designs for the subject penetrations does not have any adverse affect on the plant safe shutdown analysis. The SAR Fire Hazards Analysis (FSAR Appendix 9.5A) remains unchanged. No accident scenarios different from those previously evaluated are affected. Acceptance of penetration seal design MS-5 for penetrations P1187, P1218, and P1291 and the unacceptability of seal design ML-2, for penetration P477A does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE T" 9S-082 Title: Procedure PPP-209, Condenser Inleakage Testing, Revision 6

~Desert tinn; Procedure PPP-209 is for detecting air inleakage on secondary plant systems with condenser vacuum.

Ssf SS This procedure does not change the function or design of plant structures, systems, or components. Procedure PPP-209 is for detecting air inleakage on the secondary plant systems.

No changes to the operation or maintenance of equipment important to safety is are being made.

This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-083 RAF 2532 Title: Snubber Augmented Inspection Program

~Descri tion:

This activity changes FSAR Section 16.3 and PLP-106 to clarify requirements of the Augmented Inservice Inspection Program for Snubbers.

s~s Snubbers are not an accident initiating system as described in the FSAR. There are no changes in the design or operation of any structure system or component as a result of this change. This change implements the verification of snubber operability as required by Technical Specifications. Therefore, the probability and consequences of an accident have not increased.

The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE ¹98-084 RAF ¹ 2533 Title: Residual Heat Removal System

~Descri tion:

This change revises FSAR Section 5.4.7 to indicate that the Residual Heat Removal System (RHRS) is placed in operation when the Reactor Coolant System (RCS) is less than approximately 360 psig. The approximate RCS pressure at which the RHRS is placed in service is changed to be consistent with similar sections of the FSAR.

Safet Summar No actual plant modifications are involved with this FSAR change. The approximate RCS pressure at which the RHRS is placed in service is being changed to provide consistency within the FSAR. This change does not affect the operation, or setpoint for the operation, of the RHRS. The change does not impact the ability of the RHRS its design functions. The FSAR change does not increase the probability or to'erform consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-085 Title: Post Modification acceptance test for ESR 97-00666

~Desert tion:

EPT-832T provides the test instructions for performing post-modification acceptance testing of ESR 97-00666. ESR 97-00666 will modify the Reactor Makeup Control System (RMCS) circuitry to allow the control room operator to select the total makeup flowrate when operating in the auto mode. The test will verify that blended makeup to the VCT via FCV-113B can be accomplished in automatic mode at various total makeup flowrates.

The test conditions for this acceptance test require that the unit be shutdown with fuel removed

-

~ from the core. This will effectively prevent a reactivity I

event from occurring during the test.

System alignment established by this test are the same as would be experienced during normal plant operations. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-086 RAF ¹ 2539 Title: FSAR Table 6.5.1-2

~Descri tion:

This change revises FSAR Table 6.5.1-2, "Comparison of Fuel Handling Building Emergency Exhaust System, Reactor Auxiliary Emergency Exhaust System and Control Room Emergency Filtration System with Regulatory Positions of R.G. 1.52, Revision 2."

Specifically, the description of Regulatory Positions Sa, b, c, and d is revised to indicate that in-place testing is performed in accordance with ANSI N510-1980. This change corrects an inconsistency between the FSAR and Technical Specifications.

Safet Summar No actual plant modifications are involved with this FSAR change. The 1980 version of the ANSI standard was determined to be appropriate for testing at HNP. This corresponds to what the Technical Specifications require. This FSAR change does not affect the operation of the HVAC systems addressed in Table 6.5.1-2. No accident initiators, accident mitigators, or equipment importarit to safety are impacted by the change. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-087 RAF 2560 Title: ESR 98-00181, Fuel Handling Tool Drop on to Spent Fuel Rack Evaluation

~Descri tion:

ESR 98-00181 evaluates the dose consequences and the effects on spent fuel rack structures due to dropped spent fuel handling tools. The tools evaluated are the PWR spent fuel tools (for HNP and RNP spent fuel), the BWR spent fuel tool, the BPRA tool, the RCCA change tool and the thimble plug tool. The spent fuel handling tools are evaluated as empty tools without spent fuel assemblies attached and with spent fuel assemblies attached to the tools. This evaluation applies only to the use of spent fuel tools outside the containment building in spent fuel pools "A"and "B" and the spent fuel racks located in pools "A" and "B".

Hsf Hs This ESR does not add any new equipment or components and does not modify any equipment or components. The evaluation demonstrates that if some of the tools are lifted to the full lift height that can be achieved by the spent fuel bridge crane, then the kinetic energy that could be achieved by the dropped spent fuel tool would be unacceptable. These tools are a RCCA change tool, BPRA tool, an empty PWR spent fuel handling tool (both tools used for HNP and RNP spent fuel) and an empty BWR spent fuel handling tool. If any of these tools were to fall onto a spent fuel rack from the maximum height by which it could be raised by the spent fuel bridge crane, the kinetic energy developed by the dropped tool would exceed the kinetic energy values used in the Westinghouse rack evaluations. The plant operating procedures which control the use of these tools are revised to reflect the appropriate lift height restrictions.

E The evaluation concludes that if these tools are not raised above the tool lift height restrictions, resulting dose consequences from a dropped item will be bounded by the values provided in FSAR Table 15.7.4-7 for a fuel handling accident outside containment. If the thimble plug tool, a refueling trash basket (including the specimen basket) with its handling tool or the failed fuel rod storage basket with its handling tool is dropped from the full height that can be achieved by lifting the item with the spent fuel bridge crane, the resulting dose consequences from a dropped item will be bounded by the values provided in FSAR Table 15.7.4-7 The subject of this evaluation does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

0 SE 8 98-088 RAF 2551 Title: Change Recycle Holdup Tank description/design bases to add the ability to be used as a make-up water source to the Spent Fuel Pools.

~Descri ttnn:

This RAF changes the Boron Recycle System description and Design Bases to allow the Recycle Holdup Tank to be used as an additional make-up water source for the Spent Fuel Pools. This change will facilitate recycling and provides additional water management flexibility.

e~fs The proposed activity involves transferring water from the Boron Recycle Holdup Tank to the spent fuel pools to facilitate recycling and to provide additional water management flexibility. Chemistry/Radiochemistry analysis will be performed prior to this type of water transfer process per approved plant procedures (CRC-860) to ensure no adverse impact. This new water transfer capability does not alter any safety-related structures, systems or components and will have no adverse impact on safe plant operation. This activity does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-089 RAF ¹ 2535 Title: FSAR Clarification of Reg. Guide 1.1

~Descri tion:

This change r'evises FSAR Section 1.8, "Conformance to NRC Regulatory Guides,"

regarding HNP's conformance to Regulatory Guide 1.1, "Net Positive Suction Head (NPSH) for Emergency Core Cooling and Containment Heat Removal System Pumps."

The statement regarding the Westinghouse methodology for calculating NPSH and the clarification statement regarding the NPSH calculation for the containment spray pumps are being removed. HNP conforms to Reg. Guide 1.1, and other sections of the FSAR accurately describe how NPSH is calculated.

Safet Summar No actual plant modifications are involved with this FSAR change. This FSAR change does not affect any accident initiators and does not change the ability of the related systems to perform their accident mitigation functions. The method for calculating NPSH for the ECCS and containment heat removal pumps is not being changed. No other equipment or systems are impacted by this change. The FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

/

SE ¹98-090 RAF ¹ 2541 Title: ESR 98-00238, Internal protective Coatings for Carbon Filter Tanks

~Descri tion:

ESR 98-00238 provides an alternative coating system to utilized inside the Carbon Filter Tanks which are located in the Water Treatment Building. The existing coatings in these tanks have experienced repetitive failures which have resulted in excessive corrosion and has required weld metal repair to these ASME Section VIIIpressure vessels. ESR 98-00238 approved the use of several immersion grade protective coating repair products for utilization on the interior of the Carbon Filter Tanks. The products are Belzonia 5811, Chesterton SR-1, Plasite ¹7156, or ¹7156-HAR, when applied in accordance with the vendor recommendations.

~ss The Deminerilizer System Carbon Filter Tanks are non-safety related and not required for the safe shutdown of the plant. A malfunction of these tanks would have no impact on safety related equipment. The replacement coatings evaluation was performed consistent with HNP design requirements and industry standards. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-091 RAF ¹ 2542 Title: Dixie Pipeline Co. Pipeline Size Change

~Descri tion:

A 6" liquefied petroleum gas pipeline, operated by the Dixie Pipeline Company, was previously changed to an 8" pipeline. This size change was previously. incorporated into FSAR Section 2.2.3. However, the analysis that shows that the new pipeline size is acceptable was not included in the previous FSAR revision. This FSAR change revises Section 2.2.3 to include a discussion of the engineering evaluation that was performed to demonstrate that the effects of the propane gas line rupture are still acceptable with a pipeline size increase from 6" to 8". The pertinent results of this evaluation are contained in Table 2.2.3-5, "Effects of Increase in Pipeline Size from Six Inches to Eight Inches."

This is a new table to be inserted in FSAR Section 2.2.3.

S~hS No actual plant modifications are involved with this FSAR change. The gas pipeline was previously increased from 6" to 8". While the gas pipeline is not an actual part of the facility, it does represent a hazard to the facility. Changing the gas pipeline size from 6" to 8" has been determined to have no effect on the probability of occurrence of a pipeline rupture. The consequences of rupture of an 8" line have not changed: No equipment important to safety would be impacted by the increase in pipe size. The engineering evaluation determined that the increase in peak overpressure for the atmospheric dispersion model and the increase in missile energy do not constitute a reduction in the margin of safety. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-092 RAF 2599 Title: Core Physics Data

~Descri tion:

The activity evaluated is a change to FSAR Section 4.3.2.2.7, "Experimental Verification of Power Distribution Analysis," and Section 4.3.2.2.8, "Testing". The change to 4.3.2.2.7 deletes one of the three data sources listed for accumulated data on power distributions in actual operation because it is no longer available, and clarifies another one of the data sources listed.

The change to 4.3.2.2.8 allows the use of the latest revision of ANSVANS-19.6.1, "Reload Startup Physics Tests for Pressurized Water Reactors."

S~IS The proposed change is primarily administrative in nature and will not result in a substantial change to either the low power physics testing program or the data collection process that is performed to validate that core models can accurately predict core transient data. In addition, the existing accident analyses are not sensitive to changes in the low power physics testing program or procedures used to collect incore-excore calibration data that is utilized to validate core model predictions. The proposed changed does not introduce new components or processes into the low power physics testing program nor the data collection process. The latest revision of ANSVANS-19.6.1 eliminates several errors that exist in the 1985 revision. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-093 RAF 0 2544 Title: Analog Testing Exceptions FSAR Chapter 7.3.2

~Descri tion:

This FSAR change clarifies acceptable exceptions to analog testing methods described in FSAR Sections 7.3.2.2.10.5 and 7.3.2.2.13 for RWST level circuitry and pressurizer pressure input to Permissive P-11. These exceptions are required since RWST level calibration is performed in "bypass" as allowed by HNP TS, Table 3.3-3 Action 16 and the P-11 permissive analog operational test is performed in "bypass" as required by TS Table 4.3.2 Item 10a if pressurizer pressure is above the P-11 setpoint.

~ Additionally, this change updates FSAR Table 7.3.2-1 to add ESFAS indicator lights that were previously omitted from the table. This particular change is administrative in nature since this list is being modified to add previously installed indicator lights to the FSAR Table.

Safet Summar No actual plant modifications are involved with this FSAR change. No equipment or procedures are being modified as a result of this FSAR change. The changes are consistent with HNP TS. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-094 RAF 0 2561 Title: Boration Time of 90 Minutes

~Descri tion Section 9.3.4.1.3.1 of the FSAR states that the rate of boration is sufficient to take the reactor from full power operation to 1% shutdown, with no rods inserted, in less than 90 minutes. This FSAR change revises this description to change the 90 minute requirement to a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> requirement. This change is consistent with the Technical Specification (TS) requirement to be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as the Required Action in response to one or more control rods being untrippable. The 90 minute value associated with boration does not appear in any other licensing basis documents.

Safet Summar No actual plant modifications are involved with this FSAR change. No credit is taken for the boration capabilities of the Chemical and Volume Control System (CVCS) in the analysis of transients presented in Chapter 15 of the FSAR. This FSAR change does not alter the ability of the CVCS to perform its intended .'unctions. No equipment or procedures are being modified as a result of this FSAR change. TS shutdown margin and other boration requirements are not being revised. This FSAR change does not affect the concentration or volume of the Boric Acid Tank, and does not affect any boration flow paths. This FSAR change does not increase, the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

e SE 0 98-095 Title: ESR 98-00188, Turbine Driven Auxiliary Feedwater Purgp Governor Valve Stem Replacement

~Descri tion:

The activity evaluated is ESR 98-00188 which addresses changing the turbine driven auxiliary feedwater pump (TDAFWP) governor valve stem to an inconel 718 coated stem manufactured by the original equipment manufacturer. The inconel 718 coated governor valve stem is equivalent to the original 410 stainless steel stem in function and quality, and the stem will not adversely affect operation of the TDAFWP. To address the different thermal expansion characteristics, the carbon spacer ID is increased to provide the minimum cold diametrical clearance between the stem and spacer.

I~IS Changing the TDAFWP governor valve stem to the inconel 718 coated stem will not affect operation of the turbine, and will not affect any other system or component. The AFW system is an accident mitigator. The TDAFWP will be capable of performing the necessary design basis safety functions with the new inconel 718 coated governor valve stem and increased ID carbon spacers. Changing the TDAFWP governor valve stem will not introduce a more limiting single failure that would impact more than one AFW train. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-097 Title: EM-210, Temporary Power Feed to Turbine Building Elevator ¹7

~Descri tion; The activity evaluated is Revision 0 to EM-210, "Temporary Power Feed to Turbine Building Elevator ¹7." The purpose of this new procedure is to control the installation and removal of temporary power to a non-safety related elevator from a non-safety related power source. The procedure was developed to take replace temporary modifications for this recurring temporary power need when its normal source of power is de-energized for maintenance. The normal power source for this elevator is non-class 1E.

s~hll The elevator being supplied temporary power is not important to safety; it does not mitigate the consequences of any accident or any malfunctioning equipment important to safety. The initiation of a fire is prevented by proper overcurrent protection of the temporary circuit. The exacerbation of an analyzed fire by addition of fuel is precluded by limiting transient combustibles below analyzed limits and observing cable separation criteria. Impact to the electrical distribution system loading is verified within analyzed limits prior to installation.

Interference with other electrical circuit function through electromagnetic coupling is prevented by observing cable separation criteria. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-100 RAF 0 2554 Title: Recorder Replacement

~Descri tion:

This FSAR change revises Table 7.5.1-11, "Control Room Indicators and/or Recorders Available to the Operator to Monitor Significant Plant Parameters During Normal Operation and Condition II, III and IV Events" to indicate the replacement of Steam Generator Level analog strip chart recorders with digital recorders. The recorders being replaced have become obsolete and spare parts required for maintenance are difficult to obtain. The new digital recorders will utilize the same power cables and input signals, and will display the process in a similar format as the analog recorders.

Safet Summar The recorders being replaced have no control or protection functions, but are relied upon to provide operators with key information during both accident and post-accident conditions. The new recorders are designed to function within the bounding environmental conditions of the control room, including EMVRFI emissions. The new digital recorders'oftware was Verified and Validated under the vendor's Appendix B program. The recorders will be seismically mounted and will not affect any equipment important to safety. The function of the recorders will not be adversely impacted, as the new recorders provide the same information as the analog recorders. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-101 Title: ESR 98-00036, SG Thermal Insulation

~Descri tion:

This safety analysis addresses the specification developed to procure thermal insulation for replacement steam generators.

I~IS The new thermal insulation shall be procured under the requirement that there is no induced corrosion of stainless steel piping. The new thermal insulation is a non-active component and is not a part of the reactor coolant system. The new insulation will be non-combustible and will not create any new ignition sources. Safety related systems will not be adversely affected by the new thermal insulation. Test data and calculations support no adverse impact on the containment sumps ability to perform their safety function due to insulation fragments. The insulation does not initiate nor mitigate the consequences of an accident. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-102 RAF 2543 Title: RHR System During Refueling

~Descri tion:

The activity evaluated is a change to the FSAR (Section 5.4.7.2.3) clarifying the way the Residual Heat Removal (RHR) System is operated during refueling operations. The change clarifies the use of one RHR train for filling of the refueling cavity allowing the other train to be used for shutdown cooling.

I~IS The use of one train of RHR for filling the refueling cavity maintains tQe second train for shutdown cooling. The loss of one train of RHR would not impact the second train.

Using the hot leg or cold leg flow path for filling does not impair the RHR system or the system's capability for accident mitigation since both are delivery paths for accident mitigation. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-103 Title: GP-005, Power Operation (Mode 2 to Mode l), Revision 20

~Descri tion:

The activity evaluated is Revision 20 to GP-005 which incorporates a "bumpless" synchronization method which changes Tavg from 561 degrees to a band of 560-564 degrees and changes power from 8-15% to 12-16% just prior to synchronizing. This is intended to get enough steam flow through the steam dumps to compensate for that needed for the synchronization, and allow the steam dumps to close afterward instead of Tavg decreasing. This revision also includes the following changes:

1. the minimum turbine roll power is changed from 5% to 4%,

2. the steam dump setpoint is allowed to be lowered as low as 81% to achieve a target steam dump demand of 12-18%,

3. a target 25% control bank D position of 130 steps and a target turbine roll control bank D position of 95-115 steps was established'versus obtaining targets from reactor engineering,

4. clarifying use of the feedwater regulating valves to supplement feedwater regulating bypass valve control, and

5. identifying expected alarms and computer points and reordering steps to accomplish the changes above and enhance plant control.

SSf SS This change to GP-005 does not introduce any new components or processes into turbine startup, synchronization, or steam generator level control. Changing the monitoring parameter from median Tavg to highest Tavg is more conservative in ensuring that the plant remains within the assumptions of the accident analysis. Primary and secondary parameters will remain more stable with the change in synchronization methods. Systems are operated within their respective design limits, and no changes in system to system interface are made. The mitigating systems involved are not challenged to remove more heat than currently analyzed. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-104 Title: ESR 98-00106, Revision 0

~Descri tion:

ESR 98-00106 was developed as a Configuration Change Engineering Evaluation type ESR to address issues related to revising several Electrical Modification (EM) procedures and generation of related work packages to provide temporary electrical power to certain plant equipment during an outage.

Safet Summar Implementation of the EM procedure changes and associated work packages results in changes to protective devices used to provide overcurrent protection of cables and loads while being supplied from alternate power supplies during an outage. This ESR and associated procedure EM-005 demonstrate that the cables are sufficient to carry the load and are adequately protected by breakers and/or fuses. The new protective device types, sizes and settings have been evaluated to ensure that they protect the cables and loads and will not trip during normal operation of the loads. Affected equipment which may be required to mitigate the consequences of an accident will operate as designed with respect to correct operation of the associated protective devices. Short circuits resulting from malfunctions of the loads will be isolated, ensuring that cable damage will not occur.

This evaluation does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 98-105 Title: EPT-442, Emergency Service Water 1B-SB Pump Curve Determination, Revision 0

~Desert tion:

The activity evaluated is Revision 0 of EPT-442, "Emergency Service Water 1B-SB Pump Curve Determination." The purpose of this procedure is to establish the conditions needed to obtain data for pump curve determination on the 1B-SB Emergency Service Water (ESW) Pump. The test is written to ensure the plant is operated within the guidance established by Technical Specifications.

~MS No permanent or temporary changes to the facility are being introduced by this EPT. Changes to operating procedures relative to ESW are not being made as a result of this new procedure. This EPT affects only one train of ESW and subsequently the essential chiller. The unaffected train remains operable and capable of removing 100% of the required heat load. The conditions established for the ESW pump for this test were evaluated by the pump vendor as acceptable for the time period necessary to gather data. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-106 Title: EPT-706T, Revision 0

~Desert tion:

EPT-706T, Revision 0, tests the completion of a modification (ESR 95-00121) to correct the overload indication for two non-safety related Reactor Auxiliary Building (RAB) fans, ES-7 and PV-39. EPT-706T inputs a signal for each fan to ensure that the correct indication is received for each fan in case of an overload condition.

Safet Summa The test ensures that a modification was installed correctly. Fans ES-7 and PV-39 are non-safety related, and are in sub-systems that are neither accident initiators nor required for safe shutdown. The inputting of a signal into the indication circuit will have no effect on the operation of the RAB HVAC sub-systems. There will be no additional equipment added, and only the overload indication circuit will be tested. This test will not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, will not introduce a different type of accident or malfunction of equipment, and will not reduce any margin of safety. Therefore, the test does not involve an unreviewed safety question.

SE ¹98-108 Title: ESR 96-00049, Draindown Indication Evaluation Between the Reactor Coolant System (RCS) and the Reactor Vessel Level Indication System (RVLIS)

~Descri tion:

The activity evaluated is ESR 96-00049 which evaluates that either the open pressurizer manway or the detensioned reactor vessel head is an adequate vent path for gravity feed cooling of the RCS when Residual Heat Removal (RHR) system cooling is unavailable during reduced inventory conditions, provided the RCS is subcooled. This review also addresses initiating gravity feed with the RCS subcooled after a loss of RHR cooling.

S~hS This ESR does not alter plant equipment or add new equipment to the plant. The status of the RCS vent paths and initiation of gravity feed cooling with the RCS subcooled does not affect the functioning of plant equipment which would be relied upon during shutdown and reduced inventory conditions., Loss of RHR cooling is the only accident analyzed at shutdown conditions that is affected by the presence of large vents in the FCS or by initiating gravity feed cooling with the RCS subcooled. Operation of the plant during reduced inventory conditions with a large vent path increases the likelihood of success of gravity feed for core cooling in the event of equipment malfunctions causing a loss of the RHR system or its support systems. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-109 RAF 0 2589 Title: LCV 430 and LCV 435 Removal and MS Traps Upgrade

~Descri tion:

This FSAR change revises FSAR Tables 3.2.1-1 and 3.9.3-14 and Figures 7.3.1-7 Sh. 01, 7.4.1-8, 10.1.0-01 and 10.1.0-6A to reflect a modification which eliminates main steam drain line isolation valves 1MS-336, 1MS-338, 1MS-354 and 1MS-356 and upgrades the piping and drain traps that remove main steam that collects in the drain pots.

Safet Summar This FSAR change reflects a modification that changes the method for main steam condensate removal at the turbine-driven Auxiliary Feedwater (AFW) Pump. The elimination of 1MS-336 and 1MS-354 will ensure that the turbine-driven AFW pump will remain available to perform its design function in the event that instrument air is lost.

The condensed main steam that collects in the drain pots will be removed by the upgraded drain lines and traps. Eliminating valves 1MS-336 and 1MS-354 and upgrading the drain lines and traps will increase the reliability of the condensate removal from the turbine.

This will reduce the likelihood that the turbine will experience mechanical overspeed due to condensation passing through the turbine and a possible mechanical overspeed trip caused by the loss of governor control. As such, the change will decrease the probability of equipment malfunction. This modification will not change the function of the AFW system, will not alter the manner in which the AFW system is designed to operate or is assumed to function in any analyzed event, and will not impact any other systems. The ability of the turbine-driven AFW pump to deliver sufficient flow and to adequately remove decay heat is not reduced as a result of this modification. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-110 RAF 0 2526 RAF 5 2591 Title: ESR 97-00551, AH-3 Fan Duct Improvements

~Descri tion:

The change evaluated is the addition of a straight section of HVAC duct to raise the AH-3 post-accident diffuser five feet off the reactor building operating deck floor. This will eliminate a loose article control concern and allow the area around the diffuser to be used as a laydown area without the need to temporarily divert the discharge flow during plant outages.

Safet Summar AH-3 is one of four containment fan cooling units that are part of the Containment Cooling System. Raising the AH-3 post-accident diffuser five feet off the floor will not adversely impact the safety-related function of the Containment Cooling System. The radial direction of air discharge will not change with the addition of the duct extension.

Also, the five'foot vertical increase in the location of the diffuser will have no significant effect on the mixing of air within containment. Raising the diffuser may slightly improve, cooling as this will help boost the cold air higher into the warm containment atmosphere.

The amount of flow resistance added to the AH-3 discharge path by the five foot extension will be negligible and will not affect the air discharge velocity or pressure to any measurable degree. The amount of zinc introduced by the added galvanized material to the containment has been evaluated and found acceptable. The overall construction of the duct extension meets the requirements for seismic safety-related duct work. These changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

SE ¹98-112 Title: PEP 400, Revision 5

~Desert tien:

PEP-400 is an implementing procedure for the Emergency Plan. Revision 5 of this procedure removes the attachment for performing a 10 CFR 50.54(q) evaluation and effectiveness review. This has been incorporated into REG-NGGC-0002. Instructions for completing the 50.54(q) evaluation and effectiveness review remain in PEP-400.

Other minor administrative changes are made for consistency.

Safet Summar No plant or equipment modifications are associated with this procedure change. The changes to PEP-400 will continue to provide adequate guidance for the evaluation of changes to the Emergency Plan and implementing procedures. REG-NGGC-0002 will assist in providing a comprehensive review for all 10 CFR 50.59 and other regulatory evaluations. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 98-115, Rev. 1 Title: PLP-201, Revision 33

~Descri tion:

PLP-201 is the Emergency Plan. Revision 33 of this procedure and its implementing procedures involves several significant changes in the program. The primary changes are the incorporation of the Severe Accident Management (SAM) Program and the new Emergency Response Organization (ERO) Training Program. In addition, several administrative changes are made.

Safe Summa No plant modifications are involved with this change. SAM guidelines are incorporated for use when plant conditions are beyond design basis. The primary goal is to protect fission product barriers and mitigate any ongoing fission product releases, with secondary goals to mitigate severe accident results and return the plant to a stable condition. PLP-201, Revision 33 also includes the new ERO training program which establishes performance based training and evaluation as the preferred method utilized for qualification on most ERO positions. The changes to the Emergency Plan and implementing procedures are administrative in nature. These changes will enhance the plant staff response to emergency conditions. This procedure revision does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-118 RAF-2547 Title: FSAR Figure 7.3.1-08, Sheets 1, 2, and 3, Feedwater to Steam Generator - 1B Instrument Schematics and Logic Diagrams

~Descri tion:

The subject of this evaluation is an FSAR revision which corrects the logic diagram on Figure 7.3.1-08 Sheets 1, 2, and 3 to indicate that the Feedwater Bypass valves receive only a Feedwater Isolation signal and not a signal from the Reactor Trip (P-4) with Low Tave circuit. This logic agrees with the functional diagram on FSAR Figure 7.3.1-1, Sheet 6 of 7 and the description of the P-4 interlock in FSAR Table 7.3.1-4.

Safet Summar This change is a correction to a section in the FSAR which will provide consistency with the design previously evaluated and stated in the FSAR in a different location. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, nor does it reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-119 Title: ESR 97-00769 D~escri tion:

ESR 97-00769 changes the maximum temperature for the Residual Heat Removal (RHR) pump seals. This allows the RHR pumps to be run with higher inlet temperatures concurrent with decreased cooling to the seal coolers.

Safet Summar The RHR system is not an accident initiator. It is an accident mitigating system.

Allowing the RHR system to operate in a condition with the seals at a higher temperature provides assurance that the pumps are not stopped due to a loss of Component Cooling Water (CCW) to the seal coolers. This provides additional assurance that the RHR pumps will run when needed. The RHR system is not degraded by this change based on input from the seal vendor. No other systems or components are affected by this change.

This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE ¹98-200 Title: ESR 98-00183, Revision 0

~Descri tion:

ESR 98-00183 verifies the adequacy of Revision 2 of the pressurizer stress report and updates the associated plant design document 1364-52710. The stress report provides an evaluation of the service conditions of the pressurizer and its subcomponents, and determines the acceptability of the components over their design life. Revision 2 of the stress report evaluates the low temperature overpressure transients for their impact on the stress analysis, and documents the acceptable results in an appendix to the stress report.

Safet Summar The revision to the pressurizer stress report does not result in any modifications to the plant or changes to the operation of the plant. The revision does not introduce a significant change in the design basis for the pressurizer or its subcomponents. The changes in stresses evaluated for the pressurizer by this activity do not increase the failure probability of the component. This activity does not change the structural characteristics or operating procedures for the pressurizer. The existing stress analysis is shown to be bounding for the new design basis low temperature transients. The structural integrity of the pressurizer is not adversely affected, and the components attached to the pressurizer will be available to perform their design functions. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-202 RAF ¹ 2558 Title: Auxiliary Feedwater Recirculation Valves Locked

~Descri tion:

This change revises FSAR Section 10.4.9A.5.1.1.1 by deleting the statement that the Auxiliary Feedwater (AFW) System recirculation mini-flow lines are not locked open.

The manual valves on these lines are in fact, locked open.

Safet Summar This FSAR change is made to accurately reflect that the AFW recirculation mini-flow line manual valves are locked open. Locking these valves in the open position decreases the probability of inadvertently mispositioning the valves. This provides assurance that the AFW pumps will have minimum flow protection in the event the flow to the steam generators needs to be reduced following AFW actuation. The ability of the AFW System to perform its safety function is not impacted by this FSAR change. No changes are made to the method of operating the AFW System. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different iype of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-203 RAF 2555 Title: Normal Purge System Sensing Line

~Desert tton; This change to FSAR Section 6.2.4.2.4.3 corrects an oversight related to exceptions taken to General Design Criteria (GDC) 56. FSAR Section 6.2.4.2.4.3 discusses GDC 56 and the acceptable alternate arrangements taken as exceptions to GDC 56. One of the exceptions taken to GDC 56 is the four containment vacuum relief sensing lines which pass through containment isolation penetrations M-94a, M-94b,M-95a, and M-95b. This exception approved an alternate arrangement for these penetrations as per NUREG-0800 and Regulatory Guide 1.11 (Safety Guide 11). An oversight to this exception (or alternate arrangement) was the inclusion of a Normal Purge System sensing line which passes through penetration M-94c. Penetration M-94c is of the same design as penetrations M-94a, M-94b,M-95a, M-95b and also meets the requirements of Regulatory Guide 1.11. Therefore, FSAR Section 6.2.4.2.4.3 is being revised to include penetration M-94c as an acceptable containment isolation arrangement for instrument lines.

S~RS This activity involves the Containment Purge sensing lines and penetration M-94c which have a containment isolation function. The penetration and associated isolation components is designed in accordance with NUREG 0800 and has been approved by the NRC as specified in Regulatory Guide 1.11. This activity does not modify or in any way affect this approved design. This activity serves to include penetration M-94c in the FSAR as an acceptable alternate to the requirements of GDC 56. The containment isolation function of penetration M-94c remains valid. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-204 Title: Administrative Limit on the Main Reservoir

~Descri tion; This safety analysis addresses an Administrative Limit on the Main Reservoir to increase required level from 205.7 feet (TS value) to 215 feet. This Administrative Limit would require the Main Reservoir to be declared inoperable should level be reduced to 215 feet. In conjunction with increasing the Main Reservoir level requirement, this change eliminate the ultimate heat sink temperature limit that is based on Emergency Service Water (ESW) pump operation (note:

the TS temperature limit for the main reservoir is still in effect).

S This activity increases the NPSH of the ESW pump and ensures the flow requirements for safety related heat exchangers cooled by ESW are met. This change does not adversely affect system operation or system configuration. This change modifies operating limits in a conservative direction. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-206 Title: PLP-620, Revision 5

~Descri tion:

PLP-620 provides the basis for the HNP Generic Letter 89-13 program and defines the scope and responsibilities of the program. The program ensures through testing and routine maintenance that the service water related systems remain reliable. Revision 5 to this procedure incorporates two ESRs and corrective action from a program assessment.

The changes provide administrative clarifications and incorporate additional service water related components for routine maintenance and inspections.

Safet Summar This revision to PLP-620 does not adversely impact any accident initiating or mitigating systems and does not alter the design, function of any associated equipment. The changes are administrative in nature with minor changes to the scope of the program. This procedure provides administrative controls for the service water program and Revision 5 increases the assurance that the associated systems will perform as required due to additional maintenance and testing. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-207 Revision l Title: EPT-282, Emergency Service Water Piping Erosion/Corrosion Monitoring Program, Revision 0

~Descri tion:

The activity evaluated is Revision 0 to EPT-282, "Emergency Service Water Piping Erosion/Corrosion Monitoring Program." This procedure establishes the erosion/corrosion monitoring program for emergency service water related systems and was created as part of the Generic Letter 89-13 program. The procedure provides the instructions necessary to implement a monitoring program and provides responsibilities for plant personnel. Testing completed by this monitoring program will be non-intrusive and performed externally on exposed piping. The intent of the program is to obtain initial baseline data and compare the results against nominal piping specifications. This procedure also provides guidance for the calculation of corrosion rates and for the scheduling of additional measurements.

S~f ~

This procedure is administrative in nature and provides the controls necessary to implement a service water erosion/corrosion program. The program is non-intrusive and will increase the reliability of the system. This procedure does not affect or change the original design of the service water system, and does not add or delete plant equipment. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-208 RAF 0 2570 Title: CST minimum useable level

~Descri tion:

This FSAR change revises FSAR Sections 9.2.6 and 10.4.9 to incorporate ESR 98-00186.

These changes are made to the minimum useable inventory in the CST. The amount of water necessary to remove the energy released and to refill the steam generators determines the minimum useable inventory. This evaluation clarifies the amount of useable water volume in the CST.

Safet Summar This FSAR change incorporates a Westinghouse analysis that reanalyzed the useable water volume in the CST. The safety function of the CST is to provide a minimum useable inventory to the Auxiliary Feedwater Pumps sufficient to maintain hot standby conditions for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> followed by a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> cooldown to mode 4. This change to the FSAR will not impact the ability of the CST to perform its safety function. This change is administrative in that no systems, structures, or components are being modified as a result of this change. There is no change to plant equipment or procedures being made, and no new means of initiating an accident is being introduced. There is no effect on fission product barriers as a result of this change. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-209 RAF ¹ 2566 Title: Turbine Trip

~Descri tion:

This FSAR change revises FSAR Sections 15.2.3.2 and 15.2.3.3, Tables 15.2.3-1, 15.2.3-2, 15.2.3-3, 15.2.3-4, inserts a new Table 15.2.3-5, changes existing Table 15.2.3-5 to Table 15.2.3-6, revises Figures 15.2.3-1 through 15.2.3-4, and adds new Figures 15.2.3-9 through 15.2.3-12. These changes are made to add a third case to the discussion of the Turbine Trip event presented in Section 15.2.3. In addition to the current cases of Maximum RCS Pressure and Limiting DNB, the new case is Maximum Steam Generator or Secondary Side Pressure. As a clarification, an editorial change is also made to the existing overpressurization case to qualify it as RCS or Primary Side overpressurization.

Safet Summar This FSAR change reflects the ultimate resolution of a generic concern that the Siemens analysis may not have been conservative with respect to secondary side pressure as a separate and unique acceptance criterion. Siemens used approved methods and calculated

'

peak pressure within acceptable limits. There is no change to plant equipment or procedures being made, and no new means of initiating an accident is being introduced.

The probability of a more severe accident is not increased. There is no effect on fission product barriers as a result of this change. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-210 RAF 2559 Title: Change to FSAR Section TMI-61, Inplant Iodine Radiation Monitoring (III.D.3.3)

~Descri tion:

The subject of this evaluation is a change to FSAR Section TiV11-61, Inplant Iodine Radiation Monitoring (III.D.3.3), which removes reference to the use of a mobile lab as a backup counting facility for airborne iodine analysis and . The mobile lab was removed from the Emergency Plan (Revision 15/1) in 1989. The FSAR is revised to state that the counting facilities of the Harris Energy & Environmental Center and other CP&L nuclear facilities will be utilized ifneeded.

e~s Safety and non-safety plant systems/equipment are not effected by this correction to the FSAR. Analysis of environmental samples off-site by the HEEC and other CP&L facilities would provide a low background. These would enhance the ability to mitigate an accident and therefore serve to decrease the consequence of an accident. Additionally, the subject change to reflect that the use of the mobile lab has been terminated and that other CP&L nuclear facilities labs are available options is an administrative change. The removal of the mobile lab was evaluated in the Harris Emergency Plan, Revision 15/1.

This change brings FSAR Section TMI-61 into agreement with the Harris Emergency Plan. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus. no unreviewed safety question exists.

SE ¹ 98-21 l Title: AP-041 Revision 2 Procedure Processing Using the Electronic Document Management System

~Descri tion:

AP-041 defines the Harris Plant Procedure process when using the Electronic Document Management System (EDMS). EDMS is a combination of software, hardware, and appropriate administrative controls used for the creation, approval, storage, control and retrieval of documents or data in electronic media. The Electronic Document Management System is divided into ten stages for the Procedure Revision Process. Each stage represents a specific function within the process that must be complete in succession prior'to a new procedure or procedure revision being completed. Controls are in place to ensure that only the latest revision is available for use by plant employees.

~Sf ~

This change does not impact the Operating license or Technical Specifications. This change does not involve a change to the FSAR, no actual plant modifications or field work were involved.

The change is administrative in nature. It does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. It does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE 0 98-212 Title: OST-1076, Auxiliary Feedwater Pump 1B-SB Operability Test Quataerly Interval Modes 1 - 4, Revision 9 t

~Descri tion:

activity is being performed to evaluate editorial corrections. setpoint changes. and to f'his evaluate the Auxiliary Feedwater (AFW) recirculation mini-flow valves being locked open.

S~fS The editorial corrections are additions to preclude the possibility of missing a task. The setpoint changes are in accordance with the IST program. The normal operating position of the recirculation mini-flow valves is open. Locking open these valves eliminates the possibility of a possible mispositioning incident. The AFW System continues to operate within the assumptions in the FSAR when the valves are locked open. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-213 RAF 2604 Title: ESR 98-00040, Emergency Lights for Fire Brigade Staging Area - Waste Processing Building Elevation 261

~Descri tion:

The activity evaluated is ESR 98-00040, "Emergency Lights for Fire Brigade Staging Area-Waste Processing Building Elevation 261." The Fire Brigade Staging Area does not contain any emergency lighting. If the site was to loose the normal lighting system, the fire brigade would not be able to respond to and dress out in this designated area. This ESR provides emergency lighting for the Fire Brigade Staging Area in accordance with Harris design criteria and regulations.

This modification will not adversely affect the function or operation of the normal AC lighting system or the emergency DC lighting system. There is no potential for installation of these emergency lights to adversely interact with any system, structure, or component important to safety. Analyses were performed to verify the required normal and emergency lighting levels were met for the impacted areas. This modification does introduce a new component to the Harris Plant. However, it's failure is self-contained to the individual fixture/lamp combination.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-215 Title: ESR 98-00299, Temporary Modification for Radiation Monitor REM-01TV-3534

~Descri tion:

The activity evaluated is ESR 98-00299, "Temporary Modification for Radiation Monitor REM-01TV-3534." The objective of this temporary modification is to dry and cool the condenser vacuum pump exhaust sample going to REM-01TV-3534 so that water will not get into the radiation monitor. A heat exchanger will be installed in the line prior to the already existing moisture control unit to dry and cool the condenser vacuum pump radiation monitor sample. The heat exchanger is a shell and tube type liquid to liquid heat exchanger installed so that condensation from the cooled sample will run into a moisture trap. Cooling will be provided from normal service water.

~SS This ESR provides cooling for the condenser vacuum pump radiation monitor sample by passing it through a heat exchanger and cooling it with normal service water. The additional heat load on the service water system is very small and has already been evaluated. A leak of the normal service water supplying the temporary heat exchanger would not adversely affect the normal service water system. Instrumentation is provided to detect a major system leak, and small leaks such as would be caused by the failure of the tubing do not affect the capability of the service water system to provide the heat removal necessary for safe shutdown. This change only affects the non-safety related portion of the service water system and non-safety related radiation monitors. No interfaces are made with equipment important to safety. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE N 98-216 Title: EST-709, Reactor Coolant System Flow Determination by Calorimetric, Rev'ision l6

~Deseri iion:

The activity evaluated is Revision l6 to EST-709. The purpose of this procedure is to verify the reactor coolant system (RCS) flowrate utilizing a precision primary-to-steam generator heat balance. This revision to EST-709 includes several administrative changes as well as the addition of an evaluation of the impact of reduced average temperature on the uncertainty analysis for RCS flow minimum requirements.

Safety Summary:

The proposed changes to the RCS flow determination procedure do'not alter the acceptance criteria, nor change the method of calculation of RCS flowrate. The change to require further evaluation on the uncertainty analysis and acceptance criteria of the test if RCS 'average temperature is low assures that the conduct of the test is consistent with analyzed conditions.

The determination of RCS flowrate has no impact on the functioning of any structure, system or component, including the reactor coolant pumps. The proposed changes do not introduce any new test methodologies or change the functioning of the plant equipment during testing or after completion of the test. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-217 RAF 2563 Title: Update of FSAR Regarding Removal of Thermal Sleeves From RCS Loop Nozzles

~Descri nen:

The activity evaluated is an update to the FSAR and design documents to reflect that thermal sleeves were not installed in the Reactor Coolant Loop nozzles at the CVCS charging connections, the Residual Heat Removal System return lines, a'nd the Pressurizer surge line connection. The removal of these thermal sleeves took place during plant construction and prior to the installation of the RCS piping under the design change process in affect at that time (1982). The removal of the thermal sleeves was recommended by Westinghouse, HNP's NSSS supplier.

Safety Summary:

NRC Information Notice 82-30 (July 1982) detailed fatigue failure problems with thermal sleeves. Subsequently, Westinghouse recommended the removal of these thermal sleeves from the Harris Plant primary system. Westinghouse concluded that thermal sleeves are not required to protect piping nozzles from thermal stress and that the integrity of the piping nozzles is not lost by operating without thermal sleeves over lifetime of the plant and Westinghouse recommended the thermal sleeves be removed. The thermal sleeves were removed (1982 and 1983) prior to installation of the piping in the system and have never been part of the operating plant. Weld data reports documented the removal and NDE of the removal areas. The only change being made at this time is to update the FSAR and design documents to reflect the current plant configuration. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-219 RAF 0 2587 Title: Steam Generator Water Hammer Prevention

~Descri tion:

This FSAR change revises Table 6.2.4-1, "Containment Isolation System Data," Section 10.4.8, Figure 10.1.0-06 and Table 16.3-5, "Containment Isolation Valves." The revisions are being made to reflect a plant modification which adds a 1-inch diameter bypass line around each of the Steam Generator Blowdown System (SGBS) outside Containment Isolation Valves (CIVs). Each 1-inch bypass line contains two manual globe valves, the first to function as a manual containment isolation valve, and the second to function as a throttling valve for slow fillingof the'piping downstream of the CIVs.

The purpose of this modification is to provide a slower method of fillingvoids in the piping downstream of the SGBS outside CIVs to prevent water hammer events from occurring.

Safet Summar This FSAR change reflects a plant modification designed to prevent steam generator water hammer events. The SGBS is not an accident initiating system. The containment isolation function associated with the SGBS CIVs is an accident mitigating function. The addition of a SGBS outside CIV bypass line with a manual CIV in the locked closed condition does not alter SGBS containment isolation function or capability during normal operations or accident conditions. An active failure of the existing outside automatic CIVs remains the most limiting single failure. The manual CIV will only be opened when restoring the SGBS headers to service following maintenance or shutdown, and will not affect operation of the existing outside CIVs. Technical Specification Action Statement 3.6.3 will be declared during restoration of the blowdown headers. A temporary relaxation of the single failure criterion applies to this restoration time (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Limiting Condition for Operation) to restore the headers to service. During this time, containment isolation or blowdown header low line pressure would be met by closure of the operable inside CIVs. ERFIS computer point wiring installation will maintain safety/non-safety isolation and separation criteria. Instrumentation added by this modification is for indication only, and does not affect any system controls. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹98-221 RAF 2565 Title: ESR 98-00339, Temporary Demineralizer Skid for Waste Evaporator Condensate Tank

~Descri tion:

ESR 98-00339 installs a demineralizer skid on the 236'levation of the Waste Processing Building to temporarily replace the Waste Evaporator Condensate Tank (WECT)

Demineralizer, which is out of service. The temporary vessel will connect to the Liquid Waste Processing System using quick-connect hoses and flush adapters'ttached to existing valves 3WE-174 and 3WE-186. Relief valve 1WL-80 will be removed and reinstalled on the top of the temporary vessel with the discharge routed to the permanent discharge piping using another hose. A temporary door will be installed at the entrance to the room containing the temporary equipment so that this area can be converted into a locked high radiation area if necessary. The temporary vessel itself will be shielded. The pipe and hose connections used by this modification include a combination of screwed, welded, flanged, and quick-disconnect type attachments.

~Sf S The FSAR Section 15 analysis for a Liquid Waste System leak or rupture is bounding in that it assumes a complete failure of all non-safety and non-seismic Category 1 equipment in the Liquid Waste Processing System and Boron Recycle System as a result of a safe shutdown earthquake. This failure is defined as a limiting fault and is assumed to result in the simultaneous release of all liquids to the Waste Processing Building. Because the WECT Demineralizer, with it's welded pipe construction, is being replaced by a temporary demineralizer with flanged. screwed. and quick-disconnect construction, the probability of a leak within the Liquid Waste Processing System is being increased.

However, FSAR Section 15.7.2 analysis assumes the gross failure of all non-Seismic Category 1 equipment in both the Liquid Waste Processing System and Boron Recycle System. This activity does not increase the chances of such gross failure across systems due to the limited scope of this activity and the types and ratings of connections and components used for this activity. Therefore, this modification does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus.

no unreviewed safety question exists.

SE 0 98-224 RAF 0 2564 Title: Storage of New Fuel on 286'-0" Fuel Handling Building D~escri tion:

This FSAR change revises Figures 1.2.2-55 and 1.2.2-58 to reflect that loaded new fuel containers may be temporarily stored on the 286'-0" elevation of the Fuel Handling Building. The drawings currently show that empty new fuel containers stored in the area south of the equipment hatch, are allowed to be stacked three high. The revised drawings will show that this area is acceptable to store loaded new fuel containers, stacked two high maximum.

Safet Summar This FSAR change revises drawings to indicate that it is acceptable to store loaded new fuel containers on the 286'-0" elevation of the Fuel Handling Building. The structural considerations for this change have been determined to be acceptable, and storing loaded new fuel containers in this area does not pose a radiological problem. Empty fuel containers were already allowed to be stored in the area. The temporary storage of loaded new fuel containers in this area will not create the possibility of any new type of accident or equipment malfunction, and will not affect any previously evaluated accidents or equipment malfunctions. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 9S-225 RAF 0 2574 Title: FSAR updated to assume 130 gpm RCS letdown flowrate

~Descri tion The purpose of this evaluation is to evaluate the safety significance of operating letdown flowrates of up to 130 gpm as designed with RCS specific activity less than or equal to 0.1 uCi/gm Dose'Equivalent 1-131. The FSAR Section 9.3.4 will also be revised to describe this new administrative limit and to clarify the operation of the letdown system.

Safet Summar This FSAR change revises section 9.3.4 to describe the RCS letdown flowrate limit of 130 gpm and to clarify the letdown system operation. This change does not alter the design of the letdown system and all design basis safety related functions are maintained.

The letdown system was designed to operate up to a maximum flowrate of 130 gpm. The overall system performance and system interfaces are not affected and no design basis or testing requirements will be exceeded by operating at the design flowrates. The ability of the Chemical Volume and Control System to perform required safety related functions will not be affected by this change. Therefore, this change will not create the possibility of any new type of accident or equipment malfunction, and will not affect any previously evaluated accidents or equipment malfunctions. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment.

and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

0 SE N 98-226 RAF Ã 2567 Title: Correction of FSAR Table 7.3.1-12

~Descri tion:

This FSAR change revises Table 7.3.1-12, "ESF and Supporting System Actuation Instrumentation." The revision corrects the System Range provided for Auxiliary Feedwater (AFW) Actuation (Steam Generator Level), which is currently listed as "+ 6 ft.

from normal full-load wtr lvl." The range should be "0- 100%." This is consistent with the range listed on design documentation Drawing 1364-053067, Sheet 77.

Safet Summar This FSAR change revises Table 7.3.1-12 to provide the correct System Range for AFW Actuation (Steam Generator Level). AFW actuation occurs on low-low steam generator level. The Technical Specification setpoint for AFW actuation is greater than or equal to 38.5%. This change does not affect the ability of the AFW actuation instrumentation to perform its accident mitigation functions. This FSAR change is a documentation change only, and does not affect any installed plant equipment or any margins of safety as described in the basis for any Technical Specifications. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-227 RAF 8 2585 Title: Cycle 9 Core Design

~Descri tion:

This FSAR change revises FSAR Sections 4.2.2, 7.7.1, 15.4.3, 15.4.7 and 15.6.5 to reflect the Cycle 9 Core Design. Specifically, Section 4.2.2 is revised to note that Westinghouse VANTAGE5 fuel design is onsite, but not loaded in the core. Section 4.2.2.2.3 and Figure 4.2.2-4 are revised to indicate that new fuel has spacers welded to thimbles instead of using a locking ring. Section 7.7.1.3.3 is revised by deleting Cycle 8-specific values for RCCA insertion limits and all rods out park position. Table 15.4.3-3 is revised to change the Beginning of Cycle and End of Cycle Dropped Rod Augmentation Factor due to a less peaked radial core power distribution in the analysis of a dropped RCCA. Section 15.4.7.2 is revised to reflect the analysis of inadvertent loading of a fuel assembly into an, improper position. Section 15.6.5.2.4, Table 15.6.5-3, Figure 15.6.5-27 and the Section 15.6.5 References are revised'to reflect the changes in the Peak Cladding Temperature calculated for a Large Break LOCA.

~sa s This FSAR change reflects changes due to the Cycle 9 Core Design. Neither the core loading nor fuel design changes impact any equipment or conditions that are accident initiators. There is no change to the fuel design or reload procedures that would increase the probability of misloading or mishandling a fuel assembly. There are no changes which would increase the off-site dose assessments. The Cycle 9 reload has no adverse impact on any equipment important to safety. With only limited changes to plant equipment and procedures, no new means of initiating an accident are being introduced.

All acceptance criteria established to ensure the radiological barriers are adequately protected during operation and postulated transient and accident conditions will be met.

This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE ¹98-229 RAF ¹ 2598 Title: ESR 98-00349, Permanent Rollover of ESR 97-00785 - Steam Tunnel Thermocouple

~Descri tion:

ESR 98-00349 will roll temporary modification ESR 97-00785 to a permanent plant change. The change revises the setpoints at which the Steam Tunnel Ventilation Fans start with relation to outside ambient temperatures and incorporates the relocation of the temperature thermocouples to improve system operation. The low temperature setpoint for the steam tunnel fans was increased from 30'F to 43'F and the outside ambient temperature thermocouples were relocated to the exterior of the fan cubicles. The revision also describes operation of the fans manually via the control switches in the Main Control Room.

~SS The Steam Tunnel Ventilation Fan setpoint changes and thermocouple relocation will allow the system to operate in a more efficient manner. This modification will help to prevent low outside ambient air temperatures from affecting the operability of the Main Feedwater Isolation Valve (MFIV) actuators and will still provide reasonable assurance that the MFIV actuators remain above their minimum temperature limit of 60'F. Moving the outside ambient temperature thermocouples to the exterior of the fan cubicles will provide a more accurate temperature input to the steam tunnel fan control circuitry. This change does not increase the probabili:y or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-230 RAF 2569 Title: ESR 97-00064, Alignment of Feedwater Heater Instrument Line Valves

~Descri tion:

The activity evaluated is ESR 97-00064 which is a design change to provide the basis for operating the feedwater heaters 4A and 4B with the instrument tap at valves 1HD-291, 1HD-293, 1HD-297, and 1HD-299 closed. Water level gradients in feedwater heaters 4A and 4B originally caused the level switches, level transmitters and level controllers to read different levels. This was occurring because the sensing locations were at different points along the base of the feedwater heaters and the water levels in the heater shells were sloped. The slope in the water levels is created by the heater drain pump operation. The suction for the heater drain pump is neat the tube sheet end of the heater and the pump's operation drops the fluid level at one end of the feedwater heater. Previous modifications were installed to cross connect the sensing lines of the level controllers and the level switches to reduce the effect of the gradient. Field investigation by the system engineer determined the best valve arrangement was to utilize only one of the three lower sensing taps on a heater. This will provide a single level sensing point as opposed to three sensing locations. I Safety Summary:

The feedwater heaters 4A and 4B and their level controls are not accident initiating systems, and do not interface with any safety related equipment. The valve alignment evaluated is reducing the number of sensing taps feeding the feedwater heaters 4A and 4B level controls. This does not change the control logic for the feedwater heater level control system. The instrument sensing lines have no control of the condensate flow through the tube side of the feedwater heater. The feedwater heater level controls will remain functional with the four valves closed.

The improved stability of the level control system with the use of the common sensing taps has been demonstrated. The valve closures ensure the effects of the drain level gradient in each heater do not create unnecessary alarms or heater drain pump trips. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-231 Title: Procedure PLP-106, Technical Specification Equipment List Program and Core Operating Limits Report, Revision 18

~Descri tion:

Procedure PLP-106, Technical Specification Equipment List Program and Core Operating Limits Report, Revision 18 makes changes to the 300 ppm MTC surveillance limit contained in the COLR. The change to the COLR will replace the current value of the surveillance limit with the value calculated by Siemens (fuel vendor) in accordance with the analytical method listed in Technical Specification 6.9.1.6.2.a.

~SF s~

The proposed surveillance limit has been determined using NRC approved analytic methods that are listed in Technical Specification 6.9.1.6.2. The MTC surveillance limit ensures that the core operates within the Cycle 8 safety analysis without additional MTC surveillances. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-232 Title: EPT-285 Revision 0 Engineering Periodic Test Procedure

~Descri tion:

EPT- 285 is a new procedure that provides instructions to measure and record the Essential Service Chilled Water system compressor oil differential pressure during start up conditions.

This procedure has been developed to identify the oil pressure signature during start up conditions and provide data for the evaluation of possible design changes to the oil pressure trip circuit. This data collection is accomplished by connecting a pressure transmitter and chart recorder to the pressure trip sensing lines to track and record the oil pressure parameter during system start up.

~Sf ~

This change does not impact the Operating licen'se or Technical Specifications. This procedure test is completed during an Limiting Condition for Operation (LCO) and the system is returned to operable status at the completion of the test. This procedure temporarily adjust the oil pressure trip set point, it ensures the set point is returned to the design trip point. Therefore, no design, function or method or performing a function is altered. It does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. It does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

4 SE ¹98-233 RAF ¹ 2571 Title: Correction to FSAR Table 7.3.1-12

~Descri tie n:

This FSAR change revises Table 7.3.1-12 to correct the "System Accuracy" and "System Actuation Setpoint" for detection of ESF Bus Primary Undervoltage to match the values reflected in plant design documents, the surveillance test procedure, and HNP TS.

Safet Summar This FSAR change revises Table 7.3.1-12 to match the design basis documentation in the design documents such as HNP TS. This change to the FSAR is administrative in nature in that it is correcting requirements in the FSAR to previously NRC reviewed and approved requirements described in TS. Plant equipment will not be modified as a result of this change. Previous HNP calculations have demonstrated that the TS requirements are sufficient in meeting the design requirements for ESF Bus UV relays and associated circuitry. Therefore, this FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

0 SE P 98-234 RAF 2562 Title: Changes to FSAR Section 6.2.4

~Descri tion:

The activity evaluated is a change to FSAR Section 6.2.4.2.5 to make normal purge valve stroke time consistent with other sections of the FSAR. FSAR 6.2.4.2.5 discusses valve closure times for containment purge. The closure time for the normal containment purge make-up and exhaust is indicated as 5 seconds. It should be 3.5 seconds. 3.5 seconds is the valve closure time used to establish the PLP-106 total response time for valve and signal processing of 4.75 seconds. 3.5 seconds is consistent with the 15 second closure time for the pre-entry purge lines as shown in both FSAR 6.2.4.2.5 and Table 6.2.4-1. 3.5 seconds is the time used in the offsite dose calculation CPL-V-1. The closure time shown in the FSAR is being changed to 3.5 seconds.

Additionally, a change is being made to FSAR Section 6.2.4.2.7.l.e to make steam release weight consistent with the dose calculation. FSAR 6.2.4.2.7.l.e states that the amount of steam released to the environment is 275lbs. resulting in offsite inhalation thyroid doses of 0.85 rem at the exclusion boundary and 0.2 rem at the boundary of the low population zone. The basis for this offsite dose is calculation CPL-V-1. The input to the dose calculations was 97.92 lbs. rather than 275 lbs. The value shown in the FSAR is being changed to 98 lbs.

~Sf S This activity makes corrections to bring about consistency/clarification with other documents.

Specifically, this activity corrects the closure stroke time of the normal containment purge valve in the FSAR to correlate with the design basis information and plant testing procedures. It also corrects the value provided for the amount of steam released by the containment purge system during a LOCA before isolation as described in the FSAR. The resultant dose value listed in the FSAR is correct and conforms to the design basis calculation. No actual physical changes to the plant facility, equipment or operation/testing procedures are being made by this change. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE N 98-235 RAF 2572 Title: Revision of RHR Failure Modes, FSAR Table 5.4.7-3

~Deseri rien:

This change to FSAR Table 5.4.7-3 (Failure Mode and Effects Analysis - Residual Heat Removal System Active Components - Plant Cooldown Operation) eliminates a confusing and inaccurate statement regarding the controls for the Residual Heat Removal (RHR) System Heat Exchanger (HX) Bypass Flow Control Valves which are designated as FCV-605AEcB in the FSAR. There is no solenoid in the electro-pneumatic circuits for this Air Operated Valve as stated in the FSAR.

Instead, the valve is controlled by a standard electro-pneumatic positioner loop.

S~IS I Controls for the RHR HX bypass valves are not accident initiators. These controls regulate the amount of Reactor Coolant System flow during Shutdown Cooling. The basis and conclusions of the FSAR tables remain valid whether solenoids or positioners are used in the control loops.

This change to the FSAR in the type of component used in the valve control loops will not affect operation of the control loop. The RHR HX bypass valves continue to function as designed. The existing positioners meet the applicable codes and standards and are safety related. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-236 Title: Procedure EPT-242T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Eddy Current Testing of Steam Generator Tubes

~Desert tien:

The activity evaluated is Procedure EPT-242T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Eddy Current Testing of Steam Generator Tubes. The objective of the procedure is to inspect the steam generator tubing, locate tubing that doesn't meet established criteria and remove those tubes from service.

S~S Procedure EPT-242T is an element of steam generator maintenance. This EPT helps ensure compliance with the Operating License (OL) and Technical Specifications (TS). TS and OL requirements with respect to steam generator inspection and repair remain unchanged by this EPT. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce'a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-237 Title: Procedure EPT-243T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Data Acquisition for Steam Generator Tube Examinations

~Descri iioo:

The activity evaluated is Procedure EPT-243T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Data Acquisition for Steam Generator Tube Examinations. The vendor procedures that are contained within this EPT are a subset of the overall activity and are directed toward the mechanical aspects of acquiring the eddy current tube inspection data. The overall objective of the vendor procedures is to inspect the steam generator tubing, locate tubing that doesn't meet established criteria and remove those tubes from service.

s~s Procedure EPT-243T is an element of steam generator maintenance. This EPT helps ensure compliance with the Operating License {OL) and Technical Specifications (TS). TS and OL requirements with respect to steam generator inspection. and repair remain unchanged by this EPT. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-238 Title: Procedure EPT-244T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Tube Plugging and Repair of Steam Generator Tubes

~Descri tion:

The activity evaluated is Procedure EPT-244T, ABB/Combustion Engineering XS10370016, Temporary Procedure for Tube Plugging and Repair of Steam Generator Tubes. The vendor procedures that are contained within this EPT are a subset of the overall activity and are directed toward the mechanical aspects of tube repair and tube pressure testing. The overall objective of the vendor procedures is to inspect the steam generator tubing, locate tubing that doesn't meet established criteria and remove those tubes from service.

S~hS Procedure EPT-244T is an element of steam generator maintenance. This EPT helps ensure compliance with the Operating License (OL) and Technical Specifications (TS). TS and OL requirements with respect to steam generator inspection and repair remain unchanged by this EPT. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Therefore, no unreviewed safety question exists.

SE 0 98-239 RAF 0 2573 Title: West Auxiliary Dam Piezometer Drawing Revision

~Descri iion; This FSAR change revises Figure 2.5.6-3, "Reservoir - West Auxiliary Dam General Plan" by indicating the location of piezometer ADP-21A and by including pertinent data on the Schedule of Piezometers. This piezometer has been included in the list of piezometers for which periodic water elevation measurements are recorded, but its location and pertinent data were not included on plant drawing CAR-2167-G-6270 (FSAR Figurc 2.5.6-3).

Safet Summar This FSAR change revises Figure 2.5.6-3 to indicate the location of piezometer ADP-21A, which provides a method of monitoring the structural integrity of the Auxiliary Dam by determining pore water pressure in the impervious core and the rock foundation of the dam. The piezometers are non-safety related, and they are not accident initiators or mitigators, and they do not contribute to any postulated accident scenarios. The depiction of the piezometers on drawings has no effect upon the safety-related functions of the Auxiliary Dam and Reservoir. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-239Rev 1 RAF 0 2607 Title: West Auxiliary Dam Piezometer Drawing Revision

~Descri tion; This FSAR change revises Figure 2.5.6-3, "Reservoir - West Auxiliary Dam General Plan" by indicating the location of piezometer ADP-21A and by including pertinent data on the Schedule of Piezometers. This piezometer has been included in the list of piezometers for which periodic water elevation measurements are recorded, but its location and pertinent data were not included on plant drawing CAR-2167-G-6270 (FSAR Figure 2.5.6-3). Revision 1 of SE 98-239 corrects the depth, depth to top of seal, and slotted between depths values in the Schedule of Piezometers that were provided in Rev. 0 of SE 98-239.

Safet Summar This FSAR change revises Figure 2.5.6-3 to indicate the location of piezometer ADP-21A, which provides a method of monitoring the structural, integrity of the Auxiliary Dam by determining pore water pressure in the impervious core and the rock foundation of the dam. The piezometers are non-safety related, and they are not accident initiators or mitigators, and they do not contribute to any postulated accident scenarios. The depiction of the piezometers on drawings has no effect upon the safety-related functions of the Auxiliary Dam and Reservoir. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 98-240, Rev. l Title: ESR 97-00620, Revision I

~Descri tion ESR 97-00620, Revision l evaluates the upgraded element to be installed in the "B"

Charging Safety Injection Pump (CSIP), and the addition of vibration probe mounting brackets to the pump for future use. The modifications are being done due to the "B"

CSIP exhibiting increased vibration. A spare element was upgraded for installation, which includes a material change of the shaft and configuration chan'ges at the balancing drum retainer. Both of these changes are intended to reduce the likelihood of shaft cracking or failure. Brackets are being added to the pump for permanently mounting vibration probes in the future. This ESR reviews the pump performance and compares it with the analysis limits.

Safet Summar The changes to the "B" CSIP element are intended to increase the reliability of the pump shaft. The addition of vibration probes is for future use in monitoring pump vibration.

These changes do not degrade the pump beyond the existing analysis limits. The changes do not impact any other plant system or components. The ability of the "B" CSIP and the system to perform its accident mitigating function are not impaired. The vendor performance testing demonstrates that the pump with the new'element performs within the band formed by the existing pump curves. The addition of the brackets does not impact the seismic qualification of the pump. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

SE 0 98-241 Title: EST-923, Revision 0

~Descri i ion:

EST-923 was developed from existing procedures to make use of the Framatome automated reactivity computer "RMAS" and Framatome recommended practices to reduce the duration of low power physics testing. EST-923 establishes the procedural steps for performing the low power physics test program to ensure compliance with the FSAR requirements.

Safet Summar The RMAS software automates many of the manual calculations that were performed in the previous combination of procedures. The software has been provided in accordance with QA requirements for safety related calculations. The calculation methods employed satisfy the requirements specified in ANSI 19.6.1. The procedure specifies limits for core parameters that are either bounded by the current FSAR Chapter 15 analyses or are allowed by the Physics Testing provisions of Technical Specifications. The probability of accident occurrence during low power physics testing is mitigated by administratively reducing plant trip setpoints and the monitoring of plant parameters during Special Test Exceptions. The conditions established in EST-923 do not prevent actions described or evaluated in the SAR. The full power accident analysis consequences remain bounding when evaluated against the operating restrictions specified in EST-923. Plant systems will be operated in a manner that is consistent with system design and assumed in the SAR. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

4' SE 0 98-242 RAF 2584 Title: Rod Deviation Alarm

~Descri tion:

ESR 9700636 calculates expected fuel pool heatloads for RF08 and Cycle 9. Changes to inputs which can affect the total fuel pool heatload have been implemented which required the heatload analysis to be reevaluated. A revised curve representing the minimum decay time prior to fuel movement in the vessel versus CCW temperature was generated which will ensure all applicable system requirements remain satisfied. This curve will be implemented in PLP-114. Additionally, changes to the FSAR are being made to remove applicable references to the Cycle 8 heat load analysis.

S~fS No changes have been made to equipment involved in the handling of fuel assemblies or to other plant equipment and structures associated with the initiation and mitigation of an FSAR evaluated accident. The probability of fuel handling accidents or those related to the failure of plant equipment and structures are not increased by the items evaluated in ESR 9700636.

Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE ¹98-243 RAF 2576 Title: Manager of Operations responsibilities with respect to plant mode changes

~Descri tion:

This change to the FSAR chapter 13, documents the responsibilities of the Manager of Operations or designee with respect to allowing mode changes under TS 3.0.4. IfTS equipment is inoperable and the plant wishes to change modes under TS 3.0.4, then the Manager of Operations or designee must ensure remedial measures prescribed by the applicable TS action requirements provide sufficient level of protection to permit operational mode changes and safe long term operation consistent with the licensing basis as described in the FSAR, and also it will be the exception when plant startup commences to have important safety features inoperable.

S~hS This change to the FSAR and OMM-001 are administrative in nature in that responsibilities of the Manager of Operations or designee is provided with respect to application of TS 3.0.4. The NRC has reviewed an HNP proposed TS change that incorporates this guidance. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE ¹98-244 Title: Procedure MMM-022, Rigging Loads From Permanent Plant Components, Revision 12

~Descri tion:

The activity evaluated is Revision 12 to Procedure MMM-022, Rigging Loads From Permanent Plant Components, which removes the requirement to perform engineering review of attachments of temporary loads to operable safety related components utilizing the Engineeri'ng Service Request (ESR) process. The procedure has a generic allowable section qualified through calculations. If the generic allowable criteria can not be satisfied a Temporary Load Release is required which must be reviewed by appropriately qualified engineering personnel.

I~If S To perform an engineering review the responsible engineer must be qualified as a Modification Engineer and have completed specific training. Utilizing the procedures included in the training guides ensures the design requirements included in the FSAR are implemented appropriately and that no unreviewed safety question is created by temporary rigging. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-246 RAF 2578 Title: RAF 2578, Editorial Corrections and Clarifications

~Descri tion:

This evaluation was performed on changes to FSAR Sections 7;1.0, 7.1.2, 7.2.2 and 1.8 which are clarifications to descriptions and administrative in nature. These changes resolve wording discrepancies in the FSAR regarding trip setpoints and compliance with IEEE Standard 279-1971 for anticipatory reactor trips.

S~IS The changes made to the FSAR under this evaluation are administrative in nature and improve the quality of the descriptions contained in the FSAR. No changes have been made to the operation of the plant or to any plant equipment under this evaluation. No setpoint changes are made by these changes. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction than already evaluated in the FSAR, nor does it result in a decrease in the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-247 RAF 2577 Title: PLP-106 Revision 19 Administrative corrections

~Desert tien:

This activity changes FSAR Section 16.3.8 and PLP-106 to revise administrative requirements related to valves in closed systems which are relied upon as isolation boundaries but are not required by Technical Specifications. Additionally, several typographical errors are being corrected. Other changes made in PLP-106 Revision 19 are evaluated under ESR 97-00784 and ESR 98-00031.

S~IS The changes to PLP-106 and the FSAR are administrative in that systems and components are not being modified. Additionally, the method in which equipment is being operated is not being altered. An administrative limit is being added to PLP-106 and the FSAR to limit the inoperability time for valves in closed systems which are relied upon as isolation boundaries but are not required by Technical Specifications. Should these valves exceed the administrative limit, a plant shutdown will be required. All other changes are either typographical or minor editorial corrections. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE ¹98-248 Title: Procedure OST-1823 (Temporary Change ¹89002), 1A-SA Emergency Diesel Generator Operability Test 18 Month Interval Modes 5 A, 6, Revision 12

~Desert tion:

The activity evaluated is Temporary Change ¹89002 to Procedure OST-1823, Revision 12 which allows use of a spare 6.9 KV breaker in the C-SAB Charging/Safety Injection Pump (CSIP) cubicle on safety bus 1A-SA. OST-1823 tests Emergency Safeguards Sequencer actuations of safeguards equipment for the A-SA safety bus following Undervoltage and Safety Injection test signals.

s~ls The proposed change does not allow the spare 6.9 KV breaker to be physically connected to the A-SA safety bus. The breaker will be observed to cycle open and closed, but it will not have any impact on plant safety related power distribution. This procedure change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE 0 98-~49 RAF 2583 Title: ESR 98-00205, Recycle Hold-up Tank Diaphragm Analysis

~Descri tion:

ESR 98-00205 evaluates the impact of operating the Recycle Hold-up Tank (RHT) with a diaphragm that has air leakage. Calculation results indicate that even without the presence of a diaphragm the gaseous effluents from the plant still remain under 10CFR20 and IOCFR50 Appendix I limits. This ESR concludes that credit will be taken for the presence of the diaphragm and testing will be performed to determine that a Decontamination Factor (DF) with an acceptance criteria of greater than or equal to 100 exists for active gases. This provides additional margin to assure operating the RHT with leakage does not result in unacceptable gaseous releases from the plant. This ESR updates the FSAR to recognize the air leakage of the diaphragm and provides guidance to operations on the venting of the diaphragm using the Waste Gas System.

Safety Summary:

This activity is limited in scope to the RHT venting to the Waste Gas Processing System. The RHT diaphragm does not meet the definition of equipment important to safety, nor does it interface with such components. Failure of this system is bounded by FSAR Chapter 15. The FSAR Chapter 15 analysis for the Waste Gas System leak or failure assumes a complete failure of a gas decay tank, all non-safety and non-Seismic Category I equipment in the Waste Processing System, and the Boron Recycle System as a result of a safe shutdown earthquake.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus. no unreviewed safety question exists.

SE 0 98-253 RAF 2592 Title: RTD response time

~Descri iion:

This activity changes the value for the RTD thermal time constant in Attachment 1 to PLP-106 and in FSAR Table 16.3.1 to match the corresponding data in table 2.2 of DBD-314 (and Siemens report EMF-2002). The proposed activity is a correction to PLP-106 and the FSAR table instead of a change to the actual accident calculations.

S~S RCS RTD's are not mentioned in the Failure Modes and Effects Analyses presented in the FSAR. This small change to allowable response time does not affect the basic function of the RTD's. The RTD form, fit, material, installation, strength, and means of testing remain unchanged. The analysis value for the RTD sensor remains conservatively slow with respect to the proposed changes to PLP-106 and the FSAR. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

0 SE ~ 98-255 Title: PLP-511 Revision 14 Radiation Control and Protection Program

~Descri tion:

This activity makes minor changes in terminology, clarifies certain program requirements, and revises the description of the E&RC Unit organization. The position of Supervisor - HP Programs has been deleted and the position of Supervisor - Spent Fuel Management has been added. Some reporting relationships for subordinate positions have been realigned. The term High Contamination Area (HCA) was deleted from this procedure revision of PLP-511 to agree with the Radiation Control Protection Manual (RCPM) NGGM-PM-0002. The term Restricted High Radiation Area (RHRA) was revised to Locked High Radiation Area (LHRA) to agree with the RCPM. The term "non-exempt" quantities was changed to "Licensed" to match 10CFR20.1801 and "Radiation Safety Violation" was revised to "Adverse Radiological Conditions" to align with the RCPM.

S~III

/

0 No actual plant modifications are involved with this change. This change is administrative in nature. Except for the control of high radiation areas, the detailed contents of the health physics program are not specifically addressed in the Operating License or Technical Specifications. The changes made do not affect HRA control and are consistent with the Operating License and Technical Specification requirements for maintaining a radiation protection program. The position of Supervisor - HP Programs in the E&RC Unit has been eliminated. i%lost of the duties and responsibilities of this position have been transferred to the Superintendent - Radiation Protection. The aspect of the E&RC Unit activities dealing with solid radioactive waste and spent fuel are directed by a new position. the Supervisor - Spent Fuel Management. This activity does not increase the probability of occurrence of a malfunction of equipment important to safety. The change does not make any changes to structures. systems. components. or equipment. There is no increase in the probability or consequences of analyzed accidents, nor is an accident of a different type than previously evaluated presented. This activity does not reduce the margin of safety. The change is not a test or experiments. Based on this, no unreviewed safety question exists.

SE 0 98-256 Title: ESR 98-00417, ESW Piping Temporary Patch

~Descri tion:

ESR 98-00417 evaluates a temporary patch over a leak in a 1- 1/2" ESW supply line to the "A" CSIP coolers. This patch is not a repair, and is to be installed/removed during Mode 6 of RFO 8. The pipe will receive a Code repair prior to entering Mode 5 during plant startup.

Safet Summar Placing a temporary patch over the leaking ESW pipe while the plant is in Mode 6 will not increase the probability of malfunction of any safety related component. The leak itself does not adversely affect the function of the ESW system; the patch merely prevents water from leaking into the Service Water Pipe Tunnel. There is no safety related equipment in the vicinity of the leak that could be adversely affected by the leak. The ESW system is not required to be operable during Modes 5 and 6. At least one train of ESW must remain-functional during this time though, to support the RHR system and/or .

the operable CSIP. This evaluation has determined:hat this activity will not affect the functionality of the ESW system. The temporary patch will be removed and the pipe will be repaired prior to leaving Mode 6 and entering Mode 5. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an

. unreviewed safety question.

SE 0 98-257 RAF 2594 Title: Chemical and Volume Control System (CVCS)

D~escri tion:

The activity evaluated is a change to FSAR section 9.3.4.1.2.6 (CVCS operation). The change allows the Reactor Coolant System (RCS) and the Reactor Makeup Control System to be at greater than or equal to the cold shutdown boron concentration. The change allows the CVCS charging and letdown lines to be filled with water that is the same concentration as the current RCS boron concentration. The change allows the CVCS letdown orifice isolation valves to be opened prior to securing the RHR low pressure letdown path. The requirement to wash off the BTRS demineralizer beds when they become loaded has been removed. The change involves other clarifications to the FSAR to avoid potential misinterpretation.

S~fS The changes being made to the FSAR are consistent with system design and are consistent and bounded by the safety analyses performed in support of the current FSAR Section 9.3.4.1.2.6 description. The specific analyses that are affected are CVCS malfunctions that decrease RCS boron concentration, CVCS malfunctions that increase RCS inventory, malfunctions that decrease reactor coolant inventory and low temperature overpressure protection of the reactor coolant system. The proposed FSAR change is within the current accident analysis assumptions for these accidents.

The alignment of the normal letdown flow path prior to securing RHR low pressure letdown has the greatest potential to produce a safety concern since the proposed change will pressurize additional piping when compared to the'previous description of operation contained in the FSAR. The proposed change will have minimal impact on letdown flow, even if all of the letdown orifices are opened. The normal letdown flow is sufficient to warm the normal letdown piping and components but insufficient to adversely impact the safety analyses.

The proposed change to the CVCS makeup setpoint (greater than cold shutdown concentration versus cold shutdown concentration) does not adversely impact the equipment analyses or accident analysis assumptions until the concentration exceeds 2600 ppm. At concentrations greater than 2600 ppm there are challenges to the post accident ph concentrations that can not be controlled by the available sodium hydroxide volume in the containment spray additive tank. In the proposed range (greater than or equal to the cold shutdown boron concentration and less than 2600 ppm) the accident analyses assumptions are conservative, since response time for boron dilution accident assumes that a minimum boron concentration (cold shutdown boron concentration) exists.

No new installations of equipment or modifications of existing equipment are being introduced.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-258 RAF 2595 Title: ESR 98-00432, Removal of Capped Connection on Auxiliary Feedwater Piping

~Descri tion; The activity evaluated is the removal of a capped connection from Auxiliary Feedwater (AFW) piping. AFW piping Line 2AF6-140SAB-1 is scheduled to be replaced during refueling outage 8 (RFO-8) due to flow accelerated corrosion (FAC). This line has a 2.5 inch OD capped connection on it (Line 2AF2/z-114SAB-1) which was capped during plant construction and serves no design function at present. Since Line 2AF2'/~-114SAB-1 is no longer functional, this capped connection will not be reinstalled. This ESR evaluates the removal of Line 2AF2/~-

114SAB-1 from all plant documents and allows 2AF6-140SAB-1 to be replaced without the capped connection.

H~l ~

Eliminating the 2~/z inch OD capped piping segment from Line 2AF6-140SAB-1 is an enhancement to the system in that it removes several pressure boundary welds thereby decreasing the number of welds in the inspection criteria for the FAC program. The modification only removes an unnecessary segment of capped piping and makes no functional or operational change to the AFW system. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-261 RAF 2601 Title: Snubber replacement

~Descri tion:

ESR 98-00462 is intended to determine the equivalency and approve the installation of a Lisega brand snubber on hanger MS-H-65. The Lisega snubber is constructed of corrosion-resistant materials and functions comparable to the existing Paul Munroe snubber. FSAR 3.9 describes the Paul Munroe hydraulic snubbers as the brand of hydraulic snubbers used at HNP, shows the different sizes and locations for these snubbers and shall be revised to include the Lisega snubber that is being installed on hanger MS-H-65.

FSAR 3.9 also lists the construction Codes applicable to hydraulic snubbers. The Paul Munroe snubbers were built to the requirements of ASME Section III, Subsection NF, 1980 Edition, including Addenda through Winter 1981 and the requirements of ASME Code Cases N-71-10 and N-249-1. The replacement Lisega snubber is built to the same construction requirements with the exception of N-249-1. The Lisega incorporates materials that are described in Code Case N-249-11, the latest approved revision of Code Case N-249 and is listed in the latest approved revision of Regulatory Guide 1.85.

SsfsS ESR 98-00462 evaluates the suitability of the Lisega snubber and determines that the Lisega functions in an acceptable manner compared to the existing Paul Munroe snubber. The Lisega meets all design basis requirements for the Main Steam system. Therefore, the probability and consequences of an accident has not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE k 98-262 RAF 2605 Title: Changes to the FSAR for sources of Makeup to the Spent Fuel Pools

~Descri tion:

This change revises sections 6.3.3 and 9.1.3 of the FSAR. The FSAR previously implied that the RWST is used for normal makeup to the Spent Fuel Pools, when thiy would result in increasing the boron concentrations in the fuel pools as water evaporates. The normal procedure for makeup is to use unborated water sources, like demineralized water or water from the primary makeup system. The RWST is available for makeup in case of a pool leak and emergency service water is also available.

~~ SS~

Boron concentration in the Spent Fuel Pools is not affected by the use of unborated water for makeup due to evaporation. The safety analyses does not credit boron in the fuel pools.

Therefore, the probability and consequences of an accident has not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

0 SE ¹98-263 RAF 2597 Title: ESR 98-00482, WC-2 Chiller Service Water Condenser Isolation Valve Auxiliary Control Panel Transfers

~Descri tion:

The activity evaluated is ESR 98-00482, "WC-2 Chiller Service Water Condenser Isolation Valve Auxiliary Control Panel Transfers." The proposed activity modifies valve control circuit logic for valves 1SW-1055 and 1SW-1208 to eliminate a design flaw which allows the valves to sometimes fail open when control is transferred between the main control board (MCB) and the auxiliary control panel (ACP). Specifically, the time delay relay and associated control relay seal-in contact in the auxiliary relay panel will be removed. This will allow the valves to be modulated directly from the respective MCB or ACP control switch when positioned to AUTO without the unnecessary interposing relay logic.

I~la S This activity corrects a design problem associated with chiller WC-2 service water condenser outlet valves ISW-1055 and 1SW-1208. Correcting this problem eliminates potential chiller trips upon transfer to or from the ACP. This activity should decrease the probability of an accident or equipment malfunction previously evaluated by ensuring proper transfer of control per the Technical Specifications. This activity will not prevent or alter any mitigative actions assumed to occur in the accident analyses. This design activity does not reduce the redundancy.

reliability or diversity assumed in the facility design. This change does not increase the probability or consequences of analyzed accidents. nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ¹98-265 RAF 2600 Title: ESR 98-00468, Replacement of Gland Steam Drain Valve 1GS-100

~Descri tion:

ESR 98-00468 evaluates a replacement valve for obsolete valve 1GS-100 located in the drain service in the Gland Steam System. The valve type will change from a globe valve to a ball valve. The valve function remains the same.

~5h S Although the replacement valve is not identical to the old valve configuration, it will be identical in function. Both the current and replacement valves are air operated, open/close valves with no modulation capability. Both have limit switches to identify valve position, and both have solenoids to control the flow of air to the actuator. The Gland Steam System is non-safety, non-seismic, and the valves are located in the Turbine Building where there are no interactions with safety related components. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 98-266 RAF 2603 Title: Stuck Reactor Head Guide Stud in Hole kS8

~Descri tion:

One reactor vessel guide stud was bound and could not be removed during reactor vessel reassembly for refueling outage 8. The guide stud was cut off and the bottom portion along with the guide stud bushing will remain in the vessel flange. The head will be tensioned and operated with one stud out of service. This condition has been evaluated and determined to be acceptable.

Safet Summary:

The evaluation of plant operation with one reactor vessel stud out of service has been determined acceptable for structural integrity of the vessel. It has been demonstrated that even with one reactor vessel closure stud out of service, the ASME Code allowable stresses are not exceeded.

The sealing ability of the vessel 0-rings is maintained, and the function of the remaining reactor vessel closure studs is maintained. There are no material compatibility or seismic concerns due to the guide and bushing components remaining in the vessel flange. during operation. Therefore.

the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE ¹98-269 RAF 2614 Title: Service Water Flooding Scenario

~Descri tion:

The activity revises the service water flooding analysis described in FSAR Section 9.2.1. The revision corrects the area of the 236'eactor Auxiliary Building (RAB) and Tank Building and the volume of water required to flood this area to a depth of one foot. The activity also makes a minor change to the FSAR's description of how water travels between the 236'AB and the pipe tunnel to bring the FSAR in better agreement with the actual plant configuration. The paragraph describing flooding from service water has been rearranged for clarity.

~Sf S This change to the FSAR does not change the level to which the 236'AB can be flooded, nor does it change the flooding mechanism. Flooding from service water is not an initiating event to an accident.

Thus, the activity cannot increase the probability of any accident or malfunction. Although the amount of water needed to flood the 236'AB to a depth of one foot (not including the volume of the pipe tunnel) has been reduced from approximately three million gallons to approximately 220,000 gallons, the ability of the plant to respond effectively to a service water leak or rupture has not been changed.

Several alarms exist to alert operators to an ESW header leak. In addition, there are alarms for low service water flow through various components, and the pipe tunnel sump is instrumented. Using the value of 220,000 gallons for floodable volume of the 236'AB and Tank Building, it would conservatively take 75 minutes to fill the pipe tunnel and flood the 236'AB and Tank Building to a depth of one foot. Existing flooding calculations assume that operator action is taken in thirty minutes to stop the flooding. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-270 RAF 2627 Title: Change to commitment Reg. Guide 1.144 Auditing of Quality Assurance Programs for Nuclear Power Plants (Rev. 0)

~Descri tion:

This activity changes FSAR Section 1.8 commitment to Reg. Guide 1.144, paragraph which begins "Subparagraph 3.3.7 requires...", to delete the parenthetical statement "(with the approval of the quality organization)".

I~I ~

This FSAR change deletes the "with the approval of the quality organization" statement, to.

reflect actual practice. This still satisfies the intent that the quality organization, NAS, concur with the timeliness of corrective actions on the part of the audited organization. This implication is clear because the requirement that, "when there is a disagreement between the audited and the auditing organization on what constitutes "timely corrective action", it "must be escalated to higher authority", remains. Therefore, the probability and consequences of an accident have not increased. The probability and consequences of equipment malfunction important to safety has not increased. A new and different type of accident or equipment malfunction that is important to safety has not been created. The Margin of Safety as defined in the Technical Specification Bases has not decreased.

SE 0 98-271 RAF 2606

'itle: Regulatory Guide 1.45, Reactor Coolant Pressure Boundary Leakage Detection Systems.

~Descri tion:

The activity evaluated is a change to the FSAR which revises Section 1.8 regarding HYP's commitment to Regulatory Guide (RG) J.45. The revision adds an exception to the requirement to detect a one gpm increase in RCS leakage within one hour by the particulate and gaseous radiation detectors. This exception is based on the fact that the radiation monitors ability to detect this increase is dependent on the actual RCS activity. If the RCS activity is less than the assumed activity in the FSAR Section 5.2.5 then the radiation detectors may not be able to detect a one gpm increase in RCS leakage within one hour.

Safety Summary:

This change affects the containment atmosphere RCS leak detection radiation monitor. It adds an exception to the requirements of RG I A5 to Section l.8 of the FSAR. This change only affects the RCS leakage detection radiation monitor. This monitor is used to detect small operational leakage from systems and components in the reactor containment building. The radiation monitoring system is not an accident initiating system. This radiation monitor does not perform any accident mitigating function.

No changes are being made to the RCS leakage detection radiation monitor or to any other plant equipment and therefore does not increase the probability of equipment malfunction. The change has no affect on any equipment important to safety that is used to mitigate the consequences of equipment malfunctions. No new type of accident or equipment malfunction are introduced by this change. The proposed change does not decrease the margin of safety as described in the Technical Specifications.

Thus. no unreviewed safety question exists.

0 SE 0 98-272 RAF 2608 Title: Organization Change in the Nuclear Engineering Department (EGR-NGGC-0001 Rev. S)

I

~Descri tion:

The subject of this evaluation is a change in the Nuclear Engineering Department (NED) organization. The organization will no longer contain a dedicated Design Control Unit at each plant site. The Configuration Management sub-unit of the Design Control Unit will now report to the respective site Engineering Section. Design control will be the responsibility of the Engineering Sections as well as the Chief Engineering Section. The function will not cease to exist but the method of implementing the function is changed. Other changes include the addition of a Major Projects Section to the NED to concentrate on assigned major projects.

S~IS design control function will continue to exist but under a different method. The addition of

'he the Major Projects Section will provide additional staff to ensure assigned major projects are designed and implemented in a high quality manner. Therefore, this change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE ¹98-273 Title: ESR 98-00539

~Descri tion:

ESR 98-00539 evaluates a temporary modification to remove defective thermocouple elements TE-01FW-2006A1, A2 and B1 which monitor. Steam Generator 1A and IB back leakage temperatures. The defective thermocouples are causing a Main Control Board annunciator light to stay in alarm. In accordance with the Harris "blackboard" philosophy, this alarm is unacceptable. Due to the location of the thermocouples, they cannot be replaced at power. The temporary modification will remove the defective thermocouple inputs from the annunciator window and allow continued monitoring of the remaining good thermocouple inputs associated with Steam Generator ba'ck leakage.

This will reduce Control Room Operator distractions and prevent masking of valid alarms.

~llf S The temperature elements detect steam or hot water back leakage into the AFW system.

Steam back leakage can cause bubble collapse water hammer, and hot water back leakage can flash to steam and cause bubble collapse water hammer or vapor bind the AFW pumps. The temperature elements provide detection and control room annunciation of any back leakage. These thermocouples are non-safety related, and are a backup to the safety related components. The AFW system does not rely on them to perform any design basis safety functions. Removing the defective thermocouple inputs from the annunciator window to allow continued monitoring of the remaining good thermocouple inputs does not affect operation of the AFW system. The AFW system will perfoim all necessary design basis requirements. Removing the non-safety related temperature element inputs from the annunciator widow will not introduce a more limiting single failure that would impact the AFW system. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve,an unreviewed safety question.

SE N 98-274 RAF 2630 Title: ESR 96-00169, Heater Drain & Vent System Level Control. FSAR Figure 10.1.0-5

~Descri tion:

The activity evaluated is a revision to drawing 2165-G-0046 and corresponding FSAR Figure 10.1.0-5 to show valves associated with the level instrumentation on Feedwater (FW) Heaters l.

2, 3, and 5 A&B, Moisture Separator Reheater Drain Tanks A & B and Moisture Separator Drain Tanks A & B. The configuration for level instrumentation was field verified which also revealed that a cross tie between the vents and drains shown on the design drawing did not exist and was not shown on any of the referenced I&C details for level instruments. Two valves that were added to a test connection line on Heater 4A were tagged incorrectly and will be corrected by retagging valves. Similarly, flow drawing 2165-G-0046 currently shows the FW heaters, except Heaters IA & 1B, with capped drain connections off of the vents for the heaters but there is a test connection installed in the field. There were no additional valves installed. This ESR also corrects some valve and line numbers that were inadvertently changed on design drawing during previous revisions.

~Sf S This is a document change to as-build the level instrumentation on FW Heaters 1, 2, 3, and 5 A&B.

Moisture Separator Reheater Drain Tanks A & B and Moisture Separator Drain Tanks A & B. No functional or operational changes to the system are being made. These document changes will aid Operations in writing clearances for isolating certain level instruments on the heaters which are outside the usual constraints of the Ebasco instrument isolation root valves. The existing instrument configuration is in agreement with the approved Ebasco design. This change does not increase the probability or consequences of analyzed accidents. nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease thc margin of safety as described in the Technical Specifications. Thus. no unreviewed safety question exists.

SE 0 98-276 RAF 0 2618 Title: RCS Temperature Control

~Descri tion:

This FSAR change revises FSAR Sections 5.1.0 and 7.7.1 to add information on Reactor Coolant System (RCS) temperature control which is an assumption in the FSAR Chapter 15 accident analysis. Section 5.1.0 is revised to identify that a programmed average temperature exists and is a linear ramp based on turbine impulse pressure, and is controlled by the combination of rods and boron. Section 7.7.1 is revised to provide the same information about the programmed average temperature, and to include the analysis assumptions regarding the control band during various modes of plant operation.

Safet Summar This FSAR change provides clarifying information with regards to RCS temperature control and the method of developing programmed reference temperature. It also identifies assumptions relevant to the Chapter 15 analysis with regards to deviations from programmed temperature. The FSAR change does not involve any change to the assumptions used in the accident analysis and does not result from or require any changes to RCS. temperature control components or procedures. The added information will ensure that the FSAR accurately reflects system operation and analytical assumptions.

The capability of the RCS as a fission product boundary is not impacted. This FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment. and does not reduce any margin of safety. Therefore. the change does not involve an unreviewed safety question.

SE 0 99-004 RAF 2610 Title: Auxiliary Feedwater System Description, FSAR Section 7.3.1.3.3

~Descri tion; This change to FSAR Section 7.3.1.3.3 removes specific valve numbers stated for the Auxiliary Feedwater Pump discharge motor operated isolation valves from the FSAR text. The valve numbers were listed incorrectly. The FSAR is changed to just clearly identify the valves without stating the individual valve numbers which are not needed for the purposes of this particular FSAR discussion.

SSf SS This change to FSAR Section 7.3.1.3.3 removes incorrect information from the FSAR and replaces it with the correct information at the appropriate level of detail. This is considered an administrative correction and as such, this FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor does it introduce a different type of accident or malfunction of equipment, or reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹99-005 RAF ¹ 2611 Title: Clarification to FSAR Section 10.4.8, Steam Generator Blowdown System

~Descri tion:

The activity evaluated is a clarification to FSAR Section 10.4.8, Steam Generator Blowdown System (SGBS). The change provides further clarification of the SGBS containment isolation and ESF actuation functions. No changes are being made to the operation of the plant or any equipment.

~Sf S The change to FSAR Section 10.4.8.4 provides further clarification of the SGBD containment isolation and ESF actuation functions. The change has no safety implications. No change is being made to the operation of the plant or plant equipment.

No licensing, technical specification or design basis functions are affected. Therefore, this change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE n 99-007 RAF n 2613 Title: ESR 97-00637. Fuel Handling Building Auxiliary Crane

~Descri tion:

Procedure EST-809, Reactor Vessel Surveillance Specimen Removal and Examination, requires the use of the Fuel Handling Building (FHB) Auxiliary Crane. The Auxiliary Crane is a single failure proof crane rated at 12 tons but has an administrative load limit of 10 tons. The Reactor Vessel Specimen will be removed from the Transfer Fuel Canal placed in a shipping cask while suspended from the FHB Auxiliary Crane. The weight of this shipping cask, along with the associated rigging, cable winch and specimen will be 20,600 lbs. Also, existing safe load path drawings must be revised to reflect the proposed travel path of this shipping cask. The safe load path does not move the'ask over spent fuel or safety related equipment.

ESR 97-00637 documents the acceptability of increasing the load lift limit on the FHB Auxiliary Crane and the revision of the safe load paths in the Fuel Handling Building for the movement of the Reactor Vessel Specimen Cask. The FHB Auxiliary Crane is addressed in FSAR Section 9.1A. The FSAR gives an administrative load limit on the Auxiliary Crane of 10 tons. The FSAR is being revised to include the statement, "The handling of loads weighing more than 10 Tons but less than 12 Tons are administratively controlled". Engineering calculations document the 10 ton design load of the Auxiliary Crane. This ESR and a revision to the calculation documents the acceptability of exceeding that limit by 600 lbs.

Safety Summary:

ESR 97-00637 evaluates the impact'ot'he increase of the load lit't limits for the FHB Auxiliary Crane and the addition ot a sate load path for the Reactor Vessel Specimen Cask. The ESR documents that the design stresses of the Crane and its supporting structures are within allowable stresses and that the heavy load of the Reactor Vessel Specimen Cask does not pass over any spent fuel or safety related equipment. The changes addressed in the ESR meet all design basis requirements for the movement of heavy loads. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety.

Therefore, the change does not involve an unreviewed safety question.

SE ¹99-008 RAF ¹ 2616 Title: Summary of Pipe Break Locations, FSAR Figure Update

~Descri iion; The activity evaluated is the revision of FSAR Figures 3.6A-14 CALC sheets 2 and 3, 3.6A-23 CALC and 3.6A-20.2 CALC. The changes to these figures are the result of Westinghouse analysis associated with as-built pipe break locations. These figures contain summary information associated with postulated rupture of piping. The changes to figure 3.6A-14 CALC sheet 2 and 3 involve an increase in the cumulative usage factor at several break locations and the elimination of two break locations. The changes to figure 3.6A-20.2 CALC involve increases in the cumulative usage factor at several break locations and the addition of 4 new break locations. The change to Figure 3.6A-23 CALC involves an increase in the cumulative usage factor at a break location.

S~S FSAR section 3.6 describes the design bases and measures that are taken to demonstrate that the systems, components and structures required to safely shutdown and maintain the reactor in a cold shutdown condition are adequately protected against the effects of blowdown jets, reactive forces, and pipe whip resulting from postulated rupture of piping both inside and outside containment. The changes introduced by the Westinghouse analysis have been reviewed and found to be acceptable without further plant modifications. The design basis to support revision of the FSAR figures is already contained in the affected calculations. The FSAR figures require updating to reflect the information already contained in the base calculations for the figures. This change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated. does not introduce a different type of accident or malfunction of equipment. and does not reduce any margin ot safety. Therefore. the change does not involve an unreviewed safety question.

SE 0 99-010 Title: ESR 99-00013, Evaluation of BWR Fuel Assemblies Supported by Channel Fasteners

~Descri iion:

The activity evaluated is ESR 99-00013 which evaluates the condition where BWR fuel assemblies are not fully seated in their storage racks. The Harris Plant has experienced problems with the storage of BWR fuel assemblies that cannot be fully inserted in their storage cells. The spent fuel assemblies cannot be fully seated in their storage racks because the channel fasteners located at the top of the assembly interfere with the top of the spent fuel rack. The channel fastener may be bent such that when the top 4 inches of the spent fuel assembly is positioned in the spent fuel rack storage cell, the channel fastener becomes caught on the top of the spent fuel rack cell wall. At the time of the evaluation, two spent fuel assemblies were in this condition.

This ESR evaluates the acceptability of leaving the two spent fuel assemblies temporarily stored in this condition and provides guidance for any future assemblies that must be temporarily supported from their channel fasteners. The ESR evaluates the impact on the spent fuel rack spent fuel assembly, fuel pool water level and effects of a 5 inch drop of a BWR spent fuel assembly.

I~IS The evaluation determined that this condition will have no adverse impact on spent fuel criticality, spent fuel pool cooling. and the ability of spent fuel racks to restrain spent fuel assemblies during a seismic event. Due to administrative controls. operator error and willful disregard for procedural cautions would be required for an assembly in one of these racks that is supported by its channel fasteners to be contacted by a transported assembly. A calculation has demonstrated that a 5 inch drop of a BWR fuel assembly will not result in fuel cladding failure.

Procedural requirements ensure that the minimum required water level will be maintained by measuring the height of water above the fuel assembly when the assembly cannot be properly seated. By maintaining 23 feet of water over the assembly, the consequences of damaged fuel is unchanged from previous fuel handling analyses. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed change does not decrease the margin of safety as described in the Technical Specifications. Therefore, no unreviewed safety question exists.

SE ff 99-011 RAF 2615 Title: Radioactive Release From a Subsystem or Component

~Descri tion:

The activity evaluated is the correction of an oversight in the accident analysis discussion of a Radioactive Release from a Waste Gas System Failure, FSAR Section 15.7.1, and Radioactive Release from a Liquid Waste System Failure, FSAR Section 15.7.2. The current discussion inappropriately describes the resulting offsite dose as less than a small fraction of the SRP limit.

Instead of "SRP" (as NUREG-0800, the NRC's Standard Review Plan) the appropriate characterization is a small fraction of the "10CFR100" limit. The values calculated for offsite dose are not affected and are not changing. The scope of this correction or clarification is limited to the acceptance limit for these two postulated accidents.

S~fS "SRP" is incorrect in the subject FSAR discussion because these two sections (15.7.1 and 15.7.2) have been deleted from NUREG-0800 by Revision 2. "10CFR100" is the correct reference because of its use in the preceding paragraph (in both sections 15.7.1 and 15.7.2). As specific verification, the whole body offsite dose presented in FSAR Table 15.7.1 are 0.28 REM and 0.065 REM. These values are well below 1.25 REM as 5% of 25 REM. Likewise, FSAR Table 15.7.2 presents conservative estimates of 1.6 and 0.37 REM for thyroid doses and 1.8 and 0.41 REM for whole body doses. These values are well below 30 REM (as 10% of 300 REM) to the thyroid and 2.5 REM (as 10% of 25 REM) whole body.

This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

0 SE 0 99-0 l4 RAF 5 2617 Title: Correction to FSAR Table 6.3.2-9

~Descri tion:

The activity evaluated is a change to FSAR Table 6.3.2-9. A previous FSAR change revised FSAR Sect. 6.3.2 to provide consistency between Engineering Calculation CT-30 and the FSAR regarding calculated flow rates out of the RWST during ECCS suction switchover from the RWST to containment sump. Among the changes made was the removal of Note 9 from Table 6.3.2.-9 which described the relation between the times given in the table and operator performance. An oversight was made in that this note is repeated a second time on the next page of Table 6.3.2-9 and it was not removed. This change corrects the oversight and removes the same note from the next page of Table 6.3.2-9. This is considered an administrative correction.

Safety Summary:

The proposed FSAR change is considered an administrative correction to an oversight in the processing of an earlier FSAR change. This correction provides consistency within FSAR Table 6.3.2-9. Therefore. this FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 99-020 RAF 2620 Title: Correction to FSAR Table 7.3.1-12, ESF and Supporting System Actuation Instrumentation

~Descri tion:

The activity evaluated is a correction to FSAR Table 7.3.1-12 which changes the Feedwater Flow System Range to read 0 - 5 MPPH instead of the original 0 - 110%, or revised 0 - 120% ranges.

This is consistent with the MCB indicated range and the instrument list. The System Accuracy is also changed in the table based on the equation presented for this determination in the table footnotes. The footnote lists the accuracy as the technical specification setpoint minus the technical specification allowable value divided by the span. In the case of feedwater flow the only technical specification setpoint that applies is the Steam Flow Feed Flow Mismatch Coincident with Low SG Level Reactor Trip Setting. The technical specification for this trip (Table 2.2-1) lists the setpoint as less that or equal to 40% of full steam flow at rated thermal power with an allowable value of less that or equal to 43.1% of full steam flow at rated thermal power. Since Steam Flow equals Feed Flow minus Blowdown, and Blowdown is insignificantly small compared to feed flow, the steam flow specs are used to calculate the feedwater flow system accuracy for the purposes of Table 7.3.1-12. Full steam flow at rated thermal power is 4.07 MPPH per SG therefore full feedwater flow is also 4.07 MPPH per SG. The Feedwater Flow Instrument Spans are 0 - 5 MPPH. Therefore the accuracy is calculated as follows: (40% x 4.07 MPPH - 43.1% x 4.07 MPPH) / 5 MPPH = -0.0252, or -2.52%. The accuracy as defined in the footnote is therefore+/-2.52% of span. This value is entered into the table.

S~fS System Range for the Feedwater Flow instrumentation installed in the plant exceeds that which had previously been included in FSAR Table 7.3.1-12. Similarly, the System Accuracy for the installed instrumentation (derived for the Technical Specification in accordance with the equation provided in the footnote to Table 7.3.1-12 of the FSAR) is more accurate, than that which had previously been included in the Table. Additionally, the FSAR Table 7.3.1-12 range and accuracy changes of this activity reflect the existing plant configuration and no physical changes to the plant are implemented. Based on these considerations, this change to the FSAR does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.

SE 0 99-021 RAF N 2622 Title: Measuring and Test Equipment

~Descri tion:

This FSAR change revises FSAR Section 1.8, Regulatory Guide (R.G.) 1.33 and R.G.

1.38 to clarify the definition of Measuring and Test Equipment (M&TE). As written, section 1.8 of the FSAR could be interpreted to include as M&TEany device used to make measurements, while ANSI N18.7 provides a detailed list of devices that are excluded (i.e., rulers, tape measures, and levels).

S~fS The HNP FSAR currently requires compliance with ANSI N18.7-1976. The proposed change only involves the clarification of the definition of M&TE by using words consistent with the ANSI N18.7-1976 definition and putting these words into the FSAR.

Therefore, this FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹99-024 RAF ¹ 2623 Title: FSAR Figure 3.8.1-6, Concrete Containment Structure - Equipment Hatch Reinforcing

~Descri tion; The activity evaluated is a change to FSAR Figure 3.8.1-6 to reflect a design change evaluated and implemented during construction of the plant that was inadvertently not reflected in the FSAR figurc. Construction design changes (Field Change Requests)

FCR-C-4097 and FCR-C-4228 evaluated the placement and method of attachment of reinforcing steel in the containment building, specifically addressing shear bars. A design tolerance of one (1) ring bar was allowed for placement of the shear bar and the method of attachment via a jam nut was allowed in lieu of using epoxy.

S~hS The sheer bars are an integral part of the containment structure reinforcing steel in providing for pressure boundary integrity and control of the release of radioactivity. The changes have been reviewed in accordance with the design change process in affect at the time and evaluated against the design basis allowables and were found to be acceptable.

The design installation provisions made by the subject FCR's do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, they do not introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE 0 99-025 RAF k 2626 Title: ESR 94-00220, Revision 1 - EDBS Update for Refueling Machine

~Descri ttnn:

ESR 94-00220, Revision 0 addressed the quality class of the reactor cavity manipulator crane (refueling machine). ESR 94-00220, Revision 1 revises FSAR Table 3.9.2-1 to state that the manipulator crane will not collapse, become derailed or allow disengagement of a fuel assembly as a result of an SSE.

s~s These changes do not effect the operation of the manipulator crane or any other safety related equipment. The manipulator crane is not used to mitigate an accident but, a malfunction of the crane could result in a fuel handling accident. FSAR section 15.7.4 evaluates a fuel handling accident inside containment where a fuel assembly is dropped by the manipulator crane, and falls into the refueling cavity. The offsite dose consequence's of this accident are provided in FSAR Table 15.7.4-7. By specifying in the Q-list and in the FSAR that the manipulator crane is Q-Class B, maintenance and design activities associated with the manipulator crane will assure that the crane will not collapse, derail or drop a fuel assembly as a result of a SSE. As such, these changes do not increase the probability or consequences of accid=nts or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

0 SE 0 99-027 RAF 0 2636 Title: Fire Suppression Foam System D~escri tion: This FSAR change revises FSAR Section 9.5:1.2.3 by removing the statements that the fire suppression foam material and equipment, provided for the auxiliary boiler fuel oil storage tanks, are stored in a nearby hose house. The hose house is unheated, and as such results in the lower useable temperature criteria of the foam being exceeded at times. Removing the location-specific information in the FSAR will allow the foam and equipment to be stored in any location that is available to fight a fire at the auxiliary boiler fuel oil storage tanks.

S~fS . FSAS3 2 9.3.1.23 lf 9 lfl S*l 2 f 3 f2*

protection foam material and equipment provided for the auxiliary boiler fuel oil storage tanks. The reference to the specific location in the FSAR is not required. Removing this location detail will allow the foam and equipment to be stored in an environment that meets the usable temperature criteria while ensuring that the equipment is available for fire fighting activities. The ability of the foam suppression equipment to perform its function is not affected by this FSAR change. Therefore, this FSAR change does not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, does not introduce a different type of accident or malfunction of equipment, and does not reduce any margin of safety. Therefore, the change does not involve an unreviewed safety question.

SE ¹99-030 RAF 2629 Title: FSAR Section 7.3.1 Changes, Computer and Communications Room Ventilation

~Descri tion; This evaluation incorporates changes to FSAR Section 7.3.1 figures which were omitted by ESR 97-00708. ESR 97-00708 eliminated the pressurization mode for post-accident operation of Computer Room ventilation. This was necessary to maintain Control Room Ventilation operable during an accident. Technical Specifications require the Control Room to be capable of being pressurized to I/8" greater than adjacent areas. The Computer Room is an adjacent area, therefore to maintain the Control Room Ventilation system operable, the Computer Room cannot be allowed to be pressurized. These changes were evaluated under safety evaluation (SE) ¹ 97-

¹ 343. This evaluation (SE 99-030) specifically addresses the update of the FSAR Section 7.3.1 figures omitted from ESR 97-00708.

~Sf S The update of FSAR Section 7.3.1 figures does not change any of the conclusions of the original

¹ SE 97-343. It only adds the appropriate references to FSAR Section 7.3.1. The Computer and Communications Room HVAC System is a non-safety system. Preventing the Computer Room from being'pressurized during an accident, maintains Control Room Ventilation operability.

Removing the capability to pressurize the Computer Room does not affect habitability of the area. The change being made only affects the non-safety portion of the plant ventilation system and ensures the plant is operated within the parameters defined by Technical Specifications. The plant computer is not credited to mitigate the consequences of an accident. There are no control functions operated by the plant computer'. Therefore, the possibility of a new or different type of accident will not be created. The probability and consequences of an accident will not increase.

The probability or consequences of equipment malfunction will not increase. Since the system will still be operated within the pressure, temperature, and humidity limitations, then a new type of equipment malfunction will not be created. Thus, no unreviewed safety question exists.

SE 8 99-035 RAF 0 2633 Title: Organization Change, Superintendent - Work Coordination

~Descri tion:

This evaluation covers a change to the plant organization as described in the FSAR. A recent Operations Unit reorganization resulted in the Superintendent-Work Coordination no longer holding an SRO license for the HNP. Additionally, the Superintendent-Work Coordination now reports to the Manager - Outage and Scheduling instead of reporting to

~~

the Manager-Operations. The Manager-Outage and Scheduling no longer reports to the General Manager-Harris Plant but now reports to the Director of Site Operations.

~S~S These changes to FSAR section 13.1.2 are administrative and organizational in nature.

The requirement for the Superintendent-Shift Operations to report to an off shift Superintendent with an SRO license when the Manager-Operations does not hold an SRO license has not changed. These administrative and organizational changes do not increase the probability or consequences of accidents or malfunctions of equipment previously evaluated, nor introduce a different type of accident or malfunction of equipment, and do not reduce any margin of safety. Therefore, the changes do not involve an unreviewed safety question.

0 SE ¹99-036 RAF 2631 Title: Changes to FSAR Section 1.8, Regulatory Guide 1.8

~Descri tion:

The activity evaluated (RAF 2631) is a change to FSAR Section 1.8, Regulatory Guide (RG) 1.8, "Personnel Selection and Training" to correct typographical errors introduced during a previous amendment and to make a correction to the qualification requirements for the Shift Technical Advisor (STA) position as stated. The FSAR wording is being changed to be consistent with Technical Specification (TS) 6.2.4.1 which requires that an STA have a bachelor's degree or equivalent in a scientific or, engineering discipline. As previously described, one could interpret that other substitutes for a bachelor's degree were allowed which in the case of the STA these other exceptions are not applicable.

S~S Based on review of applicable licensing documents, including NUREG 0737, I.A.1.1, and GL 86-04, Policy Statement on Engineering Expertise On Shift, it is concluded that these other substitutes for a'bachelor's degree are not applicable to the STA position. It is clear that the Commission's objective is to enhance engineering expertise on shift through more stringent educational requirements. The Commission specifically states in the policy statement referenced above that the bachelor's degree or the equivalent in a scientific or engineering discipline continues to be the educational requirement for a dedicated STA. This change will add wording consistent with those stated in TS 6.2.4.1. This change does not increase the probability or consequences of analyzed accidents, nor introduce a different type of accident or equipment malfunction. The proposed changes do not decrease the margin of safety as described in the Technical Specifications. Thus, no unreviewed safety question exists.