ML20196K180

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Annual 10CFR50.59 & Commitment Rev Rept for 970701-980630 for Lgs,Units 1 & 2. with
ML20196K180
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/30/1998
From: Gallagher M
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9812300358
Download: ML20196K180 (27)


Text

.

Michael P. Grilagh;r, P.E.

Plant Mamger Limerick Generating Station PECO NUCLEAR ecco e"erov co-a "v Limerick Generating Station

  • d Unit Eff PECO Energy

{n,yg,,3y19464-os20 B

P 610 718 2000 December 23,1998 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 1

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Wuhington,DC 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 Annual 10CFR50.59 and Commitment Revision Report for the period July 1,1997 through June 30,1998 l'

Attached is the Annual 10CFR50.59 Report as required by 10CFR50.59(b).

If you have any questions or reouire additional information, please contact us.

't Sincerely,

/

M. P. Gallagher BDD:bdd cc: H. J. Miller, Administrator Region I, USNRC A. L. Burritt, USNRC Senior Resident Inspector, LGS

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PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT IEVISION REPORT JULY 1,1997 THROUGH JUNE 30,1998 LIMERICK GENERATING STATION

l PECO ENERGY COMPANY LIMERICK GENERATING STATION i

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT RF. VISION REPORT JULY 1,1997 THROUGH JUNE 30,1998 This report provides a brief description of changes to the facility and procedures as described in the Safety Analysis Report, tests, and experiments that were implemented between July 1,1997 and June 30,1998. A summary of the safety evaluation for each item concluded that an unreviewed safety question, as defined in 10CFR50.59(a)(2), was not involved.

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PECO ENERGY COMPANY LIMERICK GENERATING STATION UNIfS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1997 TIIROUGII JUNE 30,1998 TABLE OF CONTENTS

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PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 RElORT TABLE OF CONTENTS Modifications P_ age a

ECR 94-09678 1

ECR 95-00473 1

ECR 96-01206 1

ECR 96-02837 1

ECR 96-02839 and ECR 96-03081 2

ECR 96-03080 2

ECR 96-03082 and ECR 96-03084 2

ECR 97-00356 3

ECR 97-00916 3

ECR 97-01173 3

ECR 97-01505 3

ECR 97-02111 4

ECR 97-02257 4

ECR 97-02606 4

ECR 97-03548 5

ECR 98-00009 5

ECR 98-00453 5

P00210 6

P00227 6

P00285 6

P00291 6

P00391, Rev. I 7

P00391, Rev. 2 7

P00580 7

P00580-Z 8

P00702 8

P00703 8

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TABLE OF CONTENTS.

Nonconformince Reoorts Eags

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96-00518 8

l',

96-02654 9

i-96-03144 9

96-04087 9

l 97-00334 10 97-00611 10 97-01601 10 97-01824 11-j 97-01878 11 97-03126 11

'98-00061 12 98-00359 12 I

98-00724 12 98-01060 13 98-01141 13 98-01144 13

.98-01224 14 98-01417 14 i

l Temoorary Plant Alterations 96-03120 14 97-01183 ~

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97-01504 15 Procedures. Tests. or Exoeriments A-C-226, Rev. I 15 M-097-046, Rev. 0 15 RW-C-100, Rev, 4 15

. SE-1-1, Rev. 7 16 SP-S-067, Rev. 3 16 S.77.1.A, Rev.11 and ST-6-107-590-1, Rev. 92 16

TABLE OF CONTENTS

UFSAR Chanoes Eggg ECR 96-04379 17

- ECR 97-00025' 17 ECR 97-01494 17 ECR 97-01889 17 ECR 97-02063.

.18 ECR 97-03016 18

. Other Iron Oxide injection Via the GEZIP Skid 18 Conunitment Revisions

' - Surveillance Interval for Rosemount Transmitters 18

- T03645 19 4

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4 PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1997 THROUGII JUNE 30,1998 SAFETY EVALUATION SUMMARIES

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LIMEIUCK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 94-09678 Unit 1 OUnit 2 UCommon E This modification abandoned the domestic water system il the Water Treatment Facility, because the equipment was no longer in service. Domestic water is supplied by well water.

The construction well water system was made permanent and presently supplies all of the domestic water demands of the Limerick site. The domestic water system in the Water Treatment Facility was removed from service when the c3nstruction well water equipment was upgraded to supply domestic water. This chance affected a section of the UFSAR and is an overall enhancement to operations.

l MOD ECR 95-00473 Unit I ixjUnit 2 SConunon U This modification replaced the Unit I and Unit 2 Post Accident Monitoring (PAM) safety related small case recorders XR-042-1(2)R623A and B with Westronics 2100C series recorders. This change was necessary, because some of the recorders are no longer being manufactured and a reliable supply of spare parts is not available. The Westronics 2100C series recorders are functionally equivalent to the origim] recorders and meet the range, accuracy, and qualification requirements of the original equipment. This change is a digital upgrade, but does not render a system or component design, function or other method of

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functioning inaccurate or incomplete as described in the SAR. This change affected a section of the UFSAR and is an overall enhancement to ma' ter,ance and operations.

m MOD ECR 96-01206 Unit 1 Unit 2 UCommon 5 This modification deleted the automatic trip of the Main Control Room (MCR) air supply fans OA/B-V116 when a high fan discharge temperature exceeding the high temperature trip setpoint of TSHL-078-030A and B is sensed. This change mai'itains the annunciation configuration to alert operations of a high temperature condition and is being implemented to provide flexibility in operating the MCR air supply fans. This change reduces operation of the standby control structure chiller in the load recycle mode on loss of the operating MCR air supply fan unit cooling capability. This flexibility provides the opportunity for operations personnel to identify the cause of the high temperature condition and take corrective action to minimize the need to swap to the redundant train of MCR Heating, Ventilation, and Air Conditioning (HVAC) system. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 96-02837 Unit I gUnit 2 jCommon L This modification drilled a small hole in the upstream (Residual Heat Removal Service Water Pump) side of the wedge on the Residual Heat Removal (RHR) Heat Exchanger Residual Heat Removal Service Water (RHRSW) Inlet valve HV-051-lF014A to eliminate the potential for pressure locking of the valve disc. Numerous industry and regulatory documents identify the problem of flexible wedge gate valves which have failed to open from " pressure locking." This hole provides a continuous vent path from the valve bonnet area to the upstream side of the valve disc. This continuous venting prevents pressure build-up inside of the valve bonnet area resulting in the mitigation of the pressure locking phenomena. This change has no adverse impact on the safety related functions of this valve. This change affected a section of the UFSAR and is an overall enhancement to operations.

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e LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF 85 MOD ECR 96-02839 and ECR 96-03081 Unit 1 EUnit 2 UCommon U This modification involved the drilling of a small diameter hole in the upstream (suppression pool) side of the Reactor Core Isolation Cooling (RCIC) pump suction valve, HV-049-lF031, wedge and the downstream (RCIC pump) side of the RCIC pump suction valve, HV-049-1F029, wedge. These holes provide for a continuous vent path from the valve bonnet areas to the upstream / downstream side of the valve wedge. This continuous venting prevents pressure build-up inside the valve bonnet area, resulting in the mitigation of the Thermally Induced Pressure Locking (TIPL) phenomena which enhances the reliability of the valve when operation from the closed to open position is required. Valve HV-049-lF031 serves as a Primary Containment Isolation Valve (PCIV). There was no change to the valve's capability to perform its open to closed safety related containment isolation function. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 96-03080 Unit 15 Unit 2 UCommonO This modification involved the drilling of a small diameter hole in the upstrer.m (suppression pool) side of the valve HV-055-lF042 wedge. This valve serves as the High Pressure Coolant Injettion (HPCI) pump suction from the Suppression Pool. This valve also serves as a PCIV.

This hole provides for a continuous vent path from the valve bonnet area to the upstream side of the valve wedge. This continuous venting prevents pressure build-up inside the valve bonnet area, resulting in the mitigation of the TIPL phenomena which enhances the reliability of the valve when operation from the closed to open position is required. There was no change to the valve's capability to perform its required open to closed isolation function. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 96-03082 and ECR 96-03084 Unit 15 Unit 2 Conunon[

This modification involved drilling a small diameter hole upstream (RHR pump) side of the wedge of valves HV-051-1F016A and B, Drywell Spray inlet valves for the Containment Spray Cooling Mode of the RHR system. These valves also serve as the outboard PCIVs. This hole provides for a continuous vent path from the valve bonnet area to the upstream side piping.

This continuous venting prevents pressure build-up inside the valve bonnet area, resulting in the mitigation of the pressure locking phenomena which enhances the reliability of the valve when operation from the closed to open position is required. There is no change to the valve's capability to perform its required open to closed isolation function. This change affected a section of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 97-01824 Unit 1 [ Unit 2 5 Common U This NCR discussed and reviewed the condition of the plant while a flow test fixture was attached to the Unit 2 north fuel prep machine resulting in information contained in the SAR being rendered inaccurate, because the fuel assembly was suspended a total of approximately 15 inches higher than stated in the UFSAR. The attachment of the flow test fixture was considered to be a temporary modification. The analysis of the limiting fuel bundle drop accident contained in the UFSAR remained bounding, because the energy assumed to be dissipated in that analysis continued to be greater than that available in the fuel assembly susnended in the fuel prep machine with the attached flow fixture, even considering the greater height. Postulated radiation releases to the refuel floor area were calculated with the design basis radiation source, much greater than the radiation levels in the fuel assemblies actually tested. These postulated radiation releases were determined to be well within the existing Radiation Zone IV limits as stated in the UFSAR, even with the reduced level of water coverage above the fuel assembly. This review determined that the use of the flow test fixture did not have a credible potential to cause dislodging of postulated contaminants from the fuel assembly during the flow test activity.

NCR 97-01878 Unit 1 UUnit 2 5 Common U This use-as-is disposition of the NCR evaluated and supported cross connecting the Unit I and Unit 2 spent fuel pools through the cask loading area. It was determined that one fuel pool cooling system could service both fuel pools and this has been demonstrated on numerous occasions by performance of S53.0.C, " Cross Connecting Fuel Storage Pools." The fuel pool / cask pit gates, which are removed to cross connect the spent fuel pools, have no safety related function. Cross connecting spent fuel pools allows the Spent Fuel Pool Cooling (SFPC) system of either unit to service both spent fuel pools. Therefore, the complete failure of a unit's SFPC system can be mitigated by the availability of the other unit's SFPC system. This NCR affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

NCR 97-03126 Unit 1 UUnit 2 hCommon[

This NCR reviewed continued plant operation without the fluence data that would have been provided by a flux wire specimen based on the inhcrent conservatism of the original design basis and re-rate predicted neutron flux. The TS SR 4.4.6.1.4 states, "The reactor flux wire specimens shall be removed at the first refueling outage and examined to determine reactor pressure vessel fluence as a function of time and power level and used to modify Figure B 3/4 4.6-1 (fast neutron fluence as a function of service life). The results of these fluence determinations shall be used to adjust the curves of Figure 3.4.6.1-1 (Pressure-Temperature curves) as required." The flux wire specimen was removed in accordance with the TS SR following the first cycle of operation, but there was no evidence that the specimen was examined. This review concluded, based upon the SAR documents used to define material surveillance programs (i.e.10CFR50 Appendix H and ASTM E-185), that there is no basis for the requirement to have first cycle flux wire measurements taken and analyzed. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION UNITS 1 Ah9 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 98-00061 Unit 1.xjUnit 2 Lj Common -

u This interim use-as is and deferred rework disposition of the NCR aduressed the operation of the HPCI turbine exhaust valve, HV-055-1F072, a primary containment isolation valve, with an intermittent valve intemals problem which occasionally affected the ability of this valve to close within the TS required 120 seconds on the first attempt. Evidence was provided that the valve consistently stroked closed to provide its remote manual isolation function by the second stroke from the control room without any additional actions other than from the ccntrol room hand switch. No damage was done to the valve by the first stroke attempt which prevented the required remote manual function from being completed. The service conditions which existed at the valve during static test strokes were representative of those occmring during the required isolation event per plant emergency procedures. Increased frequency testing per the Inservice Testing (IST) program was supplemented with diagnostic testing. This ensured that further degradation of the valve would be evaluated and that any new mechanisms that cause failure to stroke on the first attempt were properly identified. The normally open function of this valve to support HPCI operation was not in question since this valve was positioned open as part of HPCI system normal line up. A TS amendment was subsequently issued by the NRC to remove the license requirement for this valve to stroke closed on the first attempt within 120 seconds.

NCR 98-00359 Unit 1 gUnit 2 D Common U This interim use-as-is disposition of the NCR allowed operation up to 105% core flow (105 Mlb/hr) and/orjet pump flow mismatches up to 45% for the period until the next refueling outage (IR07), not to exceed three months. This disposition was a conservative implementation of an analysis which permits operation at up to a higher 110% core flow with up to a 45% flow mismatch betweenjet pumps. On February 10,1998, jet pump #2 diffuser-to-lower plenum differential pressure dropped, exceeding its established pattem by more than 10%

and indicating a flow mismatch between the #1 and #2 jet pump pair. Two of the three conditions of Technical Specifications TS SR 4.4.1.2.a continued to be met as required.

Therefore, it was concluded that the TS SR were met with the observed condition.

NCR 98-00724 Unit 1 E Unit 2 [ Common ~

This NCR replaced four Molded Case Circuit Breakers (MCCB) with Thermal Magnetic (TM)

MCCBs in three Class 1E Unit 1480V Motor Control Center (MCC) compartments. These MCCBs provide protection for the dr: well electric penetrations, RCIC and HPCI main steam 7

isolation Motor Operated Valve (MOV) motors, located within the drymil. UFSAR Figure 8.1-2, "Drywell Penetration Protection Coordination Curve," indicated that the TOL is credited as pan of the protection in conjunction with the IM MCCBs. Regulatory Guide 1.63 requires dual protection for all drywell electrical penetrations. Review of the Unit 1 RCIC and HPCI main steam supply inboard isolation MOV controls indicated that the Thermal Overloads (TOL) were used for alarm only. This NCR reestablished this dual protection to meet the intent of Regulatory Guide 1.63 and UFSAR commitments by installing four TM MCCBs that provided protection over the entire fault range. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 98-01060 Unit 1 SUnit 2 Common [

This use-as-is disposition of the NCR evaluated the continued operation of the plant with lost parts potentially in the reactor coolant system. During the inspection ofjet pump #2 during refuel outage IR07, it was discovered that the B RHR pump lower bearing support had failed, causing damage. Removal and inspection of this pump revealed that portions of the assembly were missing. Many of these pump pieces were located and recovered, but some pieces were located within the reactor coolant system which could not be retrieved. This Lost Parts Analysis demonstrated that with these " lost" items in the Unit I reactor vessel, safe reactor operation is not compromised. There is no concern for fuel bundle flow blockage, interference with control rod motion, adverse chemical or conosion reaction, damage to other equipment important to safety, and no concern with the cumulative effects ofitems previously lost.

NCR 98-01141 Unit 1 UUnit 2 2 Common [

This NCR replaced two Instantaneous Magnetic (IM) Only MCCBs with two TM MCCBs for the Unit 2 RCIC main steam supply inboard isolation MOV 480 volt supply. UFSAR Figure 8.1-2, "Drywell Penetration Protection Coordination Curve," indicated that the TOL is credited as part of the protection in conjunction with the IM MCCBs. Regulatory Guide 1.63 requires dual protection for all drywell electrical penetrations. Review of the Unit 2 RCIC main steam inboard isolation valve MOV control indicated that the TOL was used for alarm only. This NCR reestablished this dual protection to meet the intent of Regulatory Guide 1.63 and UFSAR commitments by installing two TM MCCBs that provided protection over the entire fault range.. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

NCR 98-01144 Unit 1 UUnit 2 2 Common [

This NCR replaced a 50A IM Only MCCB and a 150A TM MCCB with two 100A TM MCCBs in the HPCI main steam supply inboard isolation valve MOV 480 volt supply.

UFSAR Figure 8.1-2, "Drywell Penetration Protection Coordination Curve," indicated that the a TOL is credited as part of the protection in conjunction with the IM MCCBs. Additionally, a discrepancy in the size of the TM MCCB existed between the UFSAR Figure and the installed plant configuration. The UFSAR indicated the TM MCCB was 100A, but a plant walkdowm indicted the TM MCCB was 150A. Regulatory Guide 1.63 requires dual protection for all drywell electrical penetrations. Review of the Unit 2 HPCI main steam inboard isolation valve MOV control indicated that the TOL was used for alarm only. Additionally, a discrepancy in the size of the TM MCCB existed between the UFSAR Figure and the installed plant configuration. The UFS.AR indicated the TM MCCB was 100A, but a plant walkdowm indicated the TM MCCB was 150A. Regulatory Guide 1.63 requires dual protection for all drywell electrical penetrations by installing two TM MCCBs that provided protection over the entire fault range. This NCR reestablished this dual protection to meet the intent of Regulatory Guide 1.63 and UFSAR commitments. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 98-01224 Unit I gUnit 2 gCommon This NCR evaluated the compliance to Regulatory Guide 1.63 for these six MOV 480V power circuits, Units 1 and 2 RHR shutdown cooling isolation, Units 1 and 2 main steam line drain isolation, and Units 1 and 2 instrument gas compressor isolation. These circuits contain TOLs that are bypassed by automatic logic signals. Analysis of these power circuits indicated that the containment penetration is protected by the IM Only MCCB and the TM MCCB. In these instances the IM MCCB setting at 1000 seconds is lower than the penetration damage curve value at 1000 seconds. Furthermore, ample margin exists to assure penetration protection for continued operation beyond 1000 seconds. This protection configuration and a review of the time-current-curve (TCC) indicated that the existing power circuits with the TOL bypassed meet Regulatory Guide 1.63 and the licensing commitment reflected in the UFSAR. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

NCR 98-01417 Unit 1 [ Unit 2 !xjCommon L This NCR reviewed the LGS TS and SAR with respect to starting up and operating Unit 2 with 1.0 PPM boron, due to the 2C Standby Liquid Control pump spuriously injecting approximately 300 gallons of enriched Boron 10 solution into the Unit 2 Reactor Vessel while the plant was in a cold shutdown condition. It addressed and verified no adverse affects with the fuel including issues of fuel reliability, reactivity management, fuel warranty, and licensing / transient analysis.

TPA 96-03120 Unit 1 EUnit 2 Common [

This temporary change involved installing a blind flange in place of the RWCU regen heat exchanger relief valve PSV-044-109. This blind flange was temporarily installed due to a steam leak on the relief valve. The equipment alignment (i.e., inlet valves locked open to respective non-regen heat exchanger trains for redundant pressure relief) was an optimal arrangement. It is acceptable to isolate one non-regen heat exchanger train (A or B) by closing the respective inlet and outlet valves. The relief valve for the in-service train provides the required pressure relief.

TPA 97-01183 Unit I d Unit 2 'x Common L.

This temporary change was installed to adjust and maintain the output signal of the drywell air cooler drain flow transmitter FT-087-220C to summer FY-087-220 B as 1 Volts Direct Current (VDC), which made the transmitter inoperable. This transmitter measures the condensate drain flow from the 'C' and 'E' unit coolers. This change does not affect any of the other flow transmitters. The drywell air cooler drain flow system remained operable, because the alarm setpoint was set conservatively at.225 gpm. Per Regulatory Guide 1.45 and TS Bases 3/4.4.3.1 this monitoring system is required to detect a 1 gpm leak within I hour.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 TPA 97-01504 Unit 1 RUnit 2 2 Common U 4

This temporary change involved installing a blind flange in place of the RWCU regen heat exchanger relief valve PSV-044-209. This blind flange was temporarily installed due to a steam leak on the relief valve. The equipment alignment (i.e., inlet valves locked open to respective non-regen heat exchanger trains for redundant pressure relief) was an optimal arrangement. It is acceptable to isolate one non-regen heat exchanger train (A or B) by closing the respective inlet and outlet valves. The relief valve for the in-service train provides the required pressure relief.

PROCEDURE A-C-226, Rev.1 Unit 1 EUnit 2 ECommon U This procedure A-C-226, " Transient Response Implementation Plan (TRIP) and Severe Accident Management Plan (SAMP)," was revised to provide the necessary guidance for development of SAMP procedures for Peach Bottom Atomic Power Station (PBAPS) and LGS and incorporate additional enhancements identified by the Emergency Operating Procedure (EOP) program managers for PBAPS and LGS. These revisions were required to provide additional programmatic controls related to SAMP procedure development. Key attributes related to SAMP procedures incorporated in this revision included development of a Plant Specific Severe Accident Management Guideline (PSSAMG), writers guide requirements for SAMP procedures, verification and validation of SAMP procedures, and training for SAMP procedures.

PROCEDURE M-097-046, Rev. 0 Unit 1 EUnit 2 ECommon[

This change implemented procedure M-097-046, " Control of Fuel Inspection Activities," to control the use of vendor procedures which install two equipment systems which are specifically designed to perform nondestructive fuel cladding evaluations. This procedure describes the use of General Electric Nuclear Energy Company (GENE) approved procedures and equipment by qualified vendor personnel. These GENE procedures were reviewed by Reactor Services Technical Staff and were found to be accurate and appropriate to perform the activities described in the procedure. This was a procedure not previously described in the SAR.

PROCEDURE RW-C-100, Rev. 4 Unit 1 EUnit 2 ECommonI[

This procedure, RW-C-100, " Solid Radwaste System Process Control Program,"'was completely rewritten. This revision included commitments made to the NRC regarding the 10CFR20.2002 material dispositioning, annotated previously incorporated commitments regarding 10CFR20.2002, included a commitment number for a PBAPS commitment, incorporated a provision of LGS TS that describes the requirements associated with revising the Process Control Program (PCP), reformatted the procedure per A-C-1 Appendix 2 Exhibit 2, " Preparation of Radwaste Procedures CM-1," and revised sections of the PCP that refer to dispositioning of 10CFR20.2002 material to clarify the applicable requirements.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF 85 m

PROCEDURE SE-1-1, Rev. 7 Unit 11 Unit 2 [xjCommon U This procedure, SE-1-1, " Protected Depressurization Control (Long Term Gas Supply)," was revised to prescribe the installation and use of a " staged" air jumper in the event the Automatic Depressurization System (ADS) valves, the PCIG compressors, and the instrument air compressors are inoperable due to postulated fire damage. Existing nitrogen bottles for the ADS long term gas supply are used to support the MSRV operation. These bottles are designed for the ADS valves only, therefore quick connect fittings installed on the PCIG system and a

" staged" airjumper allows alignment of the nitrogen bottles to the MSRVs. Operator timeline analyses show that sufficient time is available after installation of the airjumper to support installation of supplemental nitrogen bottles by operations or maintenance personnel.

PROCEDURE SP-S-067, Rev. 3 Unit 1 EUnit 2 5 Common [

This procedure. SP-S-067, "Deenergizing and Reenergizing the D11 Safeguard Bus During a Refuel Outage," was revised in preparation for the Unit 1 Division I Bus Outage during refuel outage IR07. The temporary power for the Division 1 battery chargers was modified to take advantage of the non-safeguard, temporary power feed switches installed. In this revision, the Division 1 temporary power feeds from 114A-G-F-08 and 114A-G-F-37 are used and a temporary cable run between the switch location in the Division 2 battery room to the Division 1 battery rooms. In addition, refuel floor HVAC is prevented from isolating on loss of power to the pressure transmitter. A channel of the differential pressure signal is jumpered out in both the Unit 1 and Unit 2 logic. This is a temporary installation for the duration of the bus outage.

The other Unit 1 and Unit 2 channel remains functional to isolate on differential pressure, a feature no longer required by TS. This change allows both Unit I and Unit 2 refuel floor HVAC to be available and operable during the bus outage.

PROCEDURE / TEST S.77.1.A, Rev. I1 and ST-6-107-Unit 1 & Unit 2 LjCommon u 590-1, Rev. 92 This procedure, S77.1.A, "Startup of Diywell Recirculation System," and this test, ST-6-107-590-1, " Daily Surveillance Log /OPCONS 1,2,3," were revised to allow shutdown of the 1E Drywell Unit Cooler. This action eliminates the Air Cooler High Drain Flow nuisance alarm caused by condensate accumulation in the !EV212 drywell unit cooler drip pan. This action also results in reductions in local area drywell cooling airflow that was thoroughly evaluated by addressing these considerations: maintainMg leakage detection system operability to fulfill its function to provide reactor coolant boundary leakage detection capability, maintaining drywell bulk temperature below 135 F, and maintaining Environmental Qualification (FQ) service life for safety related equipment potentially affected by local area temperature increases resulting from the loss of selected drywell unit coolers.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE ECR 96-04379 Unit 1 UUnit 2 Common E This UFSAR change revised Section 9.2.6 and Tables 9.2-13,9.2-17, and 9.2.23 to increase the spray pond sedimentation allowance, reduce credited total pond capacity, correct spray pond dead storage volume requirements, update spray pond design water margin, and update the maximum spray pond temperature. These changes were made to reduce the frequency of pond dredging for sludge removal. The effect an both water inventory and peak water temperature margins was evaluated. The revised cabulations, LM-383 and M-12-26, conservatively reflect margins relative to the minimum TS Water Level.

UFSAR CHANGE ECR 97-00025 Unit 1 EUnit 2 5 Common U This UFSAR change revised the requirement of the Turbine Enclosure HVAC system from maintaining the entire turbine enclosure at a slightly negative pressure to maintaining only the turbine enclosure equipment compartment areas at a slightly negative pressure. This change was necessary due to the normal Turbine Enclosure HVAC system aligninent not being able to consistently maintain the entire turbine enclosure at a slightly negative pressure. The design of the turbine enclosure structure; normal wear and tear on doors, openings, seals, gaskets, and penetrations; atmospheric conditions; and opening of doors for ingress of personnel and equipment contributed to a reduction in the overall leak tightness and the inability to maintain a slightly negative pressure at all times. The Turbine Enclosure HVAC is a non-safety related system and this change does not affect any safety related structure, system, or component and only involved revising the UFSAR commitment.

UFSAR CHANGE ECR 97-01494 Unit 1 EUnit 2 ECommon U This UFSAR change addresses the deletion of the auxiliary boiler enclosure steam unit heaters.

' Die original design basis for the auxiliary boiler enclosure required the use of two steam unit heaters to provide the necessary heating to maintain the design room temperature at a minimum of 65 F for personnel comfort and equipment operation. These two steam unit heaters were never installed and it was found that there was no need for these unit heaters since the sensible heat from the auxiliary boilers and the supporting equipment in the auxiliary boiler enclosure was sufficient enough to maintain the minimum temperature of 65 F.

UFSAR CHANGE ECR 97-01889 Unit 1 EUnit 2 SCommon[

This UFSAR change revised Chapter 13 to reflect changes to the offsite organization for LGS.

These changes included the separation of the Station Support Department into the new Nuclear Planning and Development Department and the Station Support Department, the creation of a Nuclear Planning and Development Business Unit, the merger of the Procedures Group and Engineering Assurance Group within Nuclear Engineering to form the Engineering Assurance and Procedures Group, the creation of the Nuclear Projects Depanment, and miscellaneous reorganization within line organizations. These organization changes do not have any direct impact or adverse effect on plant operations or safety.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE ECR 97-02063 Unit 12 Unit 2 ECommon U This UFSAR change revised Chapter 13 to reflect the Site Engineering Division organizational changes. These changes involved elimination of the Performance and Reliability Section from the Site Engineering Division and the transferring ofits responsibilities, renaming the Nuclear Steam Supply Systems Branch as the Emergency Core Cooling Systems Branch within the Plant Engineering Section, creation of the Equipment Focus Branch within the Plant Engineering Section and the transfer of responsibilities from the Performance and Reliability Section, renaming the Civil / Structural Design Branch as the Civil Design Branch within the Design Engineering Section, creation of the Design Change Branch within the Design Engineering Section, elimination of the use of Engineering Work Requests (T Rs) and Temporary Circuit Alterations (TCAs) in the description of the Design Engi.. ring and Plant Engineering Sections' responsibilities, and revision of the responsibilities witn the Component Engineering Section and the transfer of responsibilities from the Perfctmance and Reliability Section. These changes do not have any direct impact or adverse effect on plant operations.

UFSAR CHANGE ECR 97-03016 Unit 1 EUnit 2 ECommon[

This UFSAR change revised Section 4.6.3.1.1.5 to add clarification regarding increased frequency control rod exercising. The UFSAR previously stated that the control rod exercise test will be perfonned on an increased frequency of at least once each day if operation is continued with three or more control rods valved out of service for the purpose of ensuring reliability of the remaining control rods. This revision clarified this statement to exclude rods valved out of service for planned maintenance. This does not change the intent for this testing.

Iron Oxide Injection Via the Unit 1 EUnit 2 ECommon[

GEZIP Skid This change involved adding red iron oxide to the GEZIP tank along with the zine oxide, in order to restore feedwater iron concentrations to within the optimum range. The concentrations ofiron and zine oxides in the tank were adjusted to reach target values in the feedwater. The total solids concentration in the tank remained at 4 grams per gallon. The drawdown rate of the tank was increased to maintain feedwater zinc at 0.16 ppb. This required more frequent chemical additions to the GEZIP tank and reduced the dilution flow setpoint. After a trial period, the iron injection program will be evaluated for effectiveness. If successful, the GEZIP skid will be upgraded to improve reliability and reduce the potential for injection line plugging. This change affected a section of the UFSAR and is an overall enhancement to operations.

l COMMITMENT REVISION Surveillance Interval for Unit 1 ixj Unit 2 3 Commoni Rosemount Transmitters I

This commitment revision applied a one time 25 v extension to the 24 month surveillance interval for monitoring Rosemount transmitters susceptible to fill-oil loss. This change supported the transition from a February to an April refueling outage. This revision allowed for a one time 27 month monitoring interval in the Rosemount Fill-Oil Loss Program. Plant safe operation is not affected by applying this one time extension.

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LIMERICK GENERATING STATION

. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 -

LICENSE NOS. NPF-39 AND NPF-85 COMMITMENT REVISION T03645 Unit 1 EUnit 2 UCommon U This commitment revision deleted suction strainer differential pressure trending for CS, RHR),

and RCIC and deleted the fiber sampling requirement for the Suppression Pool for Unit 1 only.-

These parts of the commitment were only to continue until the new suction strainers were installed per PECO response to Bulletin 96-03 and PECO response to NRC Request for Additional Infonnation (RAI) for Bulletin 96-02. The Unit I suction strainers were installed during refuel outage 1R07.

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LIMERICK GENERATING STATION UNITS 1 AND 2 i

DOCKET NOS. 50-352 AND 50-Z3 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 97-00356 Unit 1 EUnit 2 [ Common U This modification installed an altemate replacement item for the Electrohydraulic Control l

(EHC) system backup over speed trip (BOST) card. The previous card, known as a Megacycler, was no longer available. The vendor recommended replacement is known as an Auxiliary Frequency to Voltage Converter (AFVC). The BOST card receives an input pulse signal, which is proportional to turbine speed, and provides a voltage output proportional to turbine speed for use in the electrical BOST circuitiy. This activity did not include any changes to any trip or actuation setpoints or sarveillance intervals. The EHC system and the l

BOST circuitry will cont...ae to operate consistent with the current design and licensing requirements. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 97-00916 Unit 1 x Let 2 3] Common U This modification removed the four smoke detectors located in the Emergency Diesel Generator (EDG) room. The smoke detectors often caused nuisance alarms whenever the EDGs were started. The pre-existing detection system in each room consisted of four photo-electric smoke detectors, one flame detector, and one heat detector. The new detection system has one flame and one heat detector and meets the design cornmitments. This modification made no changes to the suppression systems in the EDG rooms. The heat detectors that provide the pre-action for the suppression system were not affected. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 97-01173 Unit 1 Unit 2 UCommon S This modification involved the partial re-roofing of the Chemistry Laboratory Expansion Building. The Chemistry Laboratory Expansion Building is a non-safety related, non-seismic building, however, the small part of the re-roofing area is over the Instrument Laboratory which is within a Radiologically Controlled Area (RCA) boundary. The openings created during the re-roofing created a possibility of an unmonitored, unanalyzed release path for contaminated air. An analysis was performed and concluded that the amount of contaminated air released through the openings would be insignificant and within the Offsite Dose Calculation Manual (ODCM) limits. Also, a review of HVAC heat load and impact of dust generation during re-roofing indicated no adverse impact on the HVAC system when specified installation instructions were followed. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 97-01505 Unit 13] Unit 2 ; 1 Common!.

This modification installed a thennal relief valve in primary containment on the non-safety related Reactor Enclosure Cooling Water (RECW)line HBC-191 to enhance the design of the RECW piping inside the containment to li.uit thermally induced pressurization. The set l

pressure was established using criteria for overpressure protection of system faulted conditions and to provide adequate simmer margin for the relief valve to minimize the potential for spurious lift. The set pressure (274 psig) protects components for rated design at faulted conditions. This change affected a section of the UFSAR and is an overall enhancement to operations.

3

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 97-02111 Unit 1 @ Unit 2 Common LJ This modification increased the torque capability of the actuator for the HPCI system injection valve, HV-055-1F105, to the 'A' feedwater line by increasing the gear ratio of the actuator.

Increasing this gear ratio increased the stroke time of the subject valve. Therefore, the maximum allowable stroke time for HV-055-1(2)F105 was increased. The operation of this valve is required for the initiation and termination of the HPCI system during design basis accident conditions. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 97-02257 Unit 1 @ Unit 2 UCommon[

This modification relocated the Unit 1 Reactor Water Cleanup (RWCU) regen heat exchanger channel side rehef valve, PSV-044-109, downstream of the regen heat exchanger. this modacation also relocated the Unit 1 RWCU regen heat exchanger shell side relief valve, PSV-044-108, upstream of the heat exchanger shell side inlet. These valves historically had problems with premature lifting at pressures below the desired set pressure of 1425 psig. The problems appeared to be related to pressure transients that reach into the simmer margin coupled with high process fluid temperature on or passing through the valves. Therefore, it was decided to relocate the valves to cooler piping locations. The affected portion of the RWCU system is non-safety related, but is maintained in accordance with the original design requirements, American Society of Mechanical Engineers (ASME) III, Class 3. The piping is qualified to seismic II A requirements. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 97-02606 Unit 1 @ Unit 2 Common U This modification modified Core Spray (CS) valve HV-052-1F005 to eliminate pressure locking by drilling a small pressure relief hole, approximately 1/8", in the high pressure Reactor Pressure Vessel (RPV) side of the disc. This valve was previously modified under Engineering Change Requests (ECRs) 94-06387 and 94-06390 to eliminate pressure locking by installing an external bypass line between the bonnet and the valve test / drain connection. With the hole drilled in the valve disc, the external bypass line was no longer required and was removed by ECR 97-02606. CS valve HV-052-lF005 is the system's loop A injection valve and pressure isolation valve, and is a normally closed PCIV. The valve is Q active, ASME Section III, Class 1, and seismic category I. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

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i

LIMERICK GENERATING ST.4 TION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 97-03548 Unit 1 EUnit 2 0 Common 0 This modification removed the Thermo-Lag in the Combustible Free Zone (CFZ) of Fire Area 45 (Control Rod Drive, CRD, hydraulic equipment area - Unit 1) and replaced it with an approved steel cable tray enclosure system. Fire Area 45 utilized Thermo-Lag 3361 encapsulation around several non-safeguard cable trays to establish a combustible free zone.

UFSAR Section 9A.5.4.17 states that in order to provide separation between redundant fire safe shutdown methods that "A 20 foot wide zone that is free of combustibles was created by using I hour rated fire barriers to enclose the cable trays that pass through the zone." However, Thermo-Lag no longer qualifies as a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated fire barrier. The Thermo-Lag was removed because it contributed to the combustible loading in this CFZ. Replacing the Thermo-Lag barrier with an approved tray enclosure system did not change the original Fire Protection Design Basis. This change affected a sc lion of the UFSAR and is an overall enhancement to operations.

MOD ECR 98-00009 Unit 1 EUnit 2 UCommon U This modification replaced the main transformers 1 A-X101, IB-X101, and 1C-X101 oil coolers with larger oil coolers. The new coolers were required because the higher efficiency turbine installed during the Unit I refuel outage IR07 increased the generator output. The coolers were a direct replacement of the existing oil coolers using the existing piping connections. The new coolers have four 1.5 hp fans as opposed to three 1 hp fans on the old units and the new fans use high efficiency motors which increase the electrical load from 8.1 amps to 9.6 amps. The coolers.are fed from a primary and a secondary non-Q power source.

The main transformers and equipment associated with the main transformers are considered non-Class 1E. This ECR also documents the Unit 1 main transformer rating increase from 387 MVA to 422 MVA which is required due to the increased generator output caused by turbine retrofit. The starting sequence for the cooling pumps / fans has also been changed to reduce the possibility of a transformer failure due to " static electrification." The new oil coolers are longer than the old oil coolers and required the relocation of the fire suppression piping and nozzles.

This relocation of the fire suppression nozzles did not impact the operation of the fire suppression system. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 98-00453 Unit 1 EUnit 2 ECommonU This modification installed a ten second time delay into the low suction pressure trips of the Fuel Pool Cooling (FPC) pumps in both units. The existing design (without the time delay) had resulted in nuisance trippings as a result of pressure perturbations. Following installation of the modification, the low suction pressure condition needs to persist for ten seconds in order for the pump to trip. This modification was prompted by the need to assure the reliability of the FPC System during Altemate Decay Heat Removal. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

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1 1

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF.85 MOD P00210 Unit 1 E Unit 2 [ Common This malification replaced the steam admission valve with a cage type disc, and modified the logic to throttle the steam flow to the turbine for a specified time period. As identified in GE SIL 377, the RCIC system as designed experiences a significant speed spike during the initial system startup. The higher reactor pressure after power rerate increases the potential for an overspeed trip during system startup. This change improved the speed control of the RCIC Turbine during RCIC system startup, and thus improved the overall reliability of the RCIC system. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD P00227 Unit 1 EUnit 2 Common [

This modification removed the hand switch from valve HV-051-lF011 A in the Remote Shutdown Panel (RSP). The removal of this hand switch was inadvertently omitted during modification 6240-1 which removed the RHR steam condensing mode from Unit 1. This modification did not affect the operation or safety-related design function of the RHR or HPCI systems. This change affected a section of the UFSAR and is an overall enhancement to maintenance.

MOD P00285 Unit 1 EUnit 2 UCommon u n

This modification installed large capacity passive strainers in the RHR and CS systems. The NRC issued NRC Bulletin 96-03 (NRCB 96-03), " Potential Plugging of Emergency Core Cooling Suction Strainers by Debris in Boiling Water Reactors," requesting that Boiling Water Reactor (BWR) licensees implement appropriate procedural measures and plant modifications to minimize the potential for clogging of Emergency Core Cooling System (ECCS) pump suction strainers by debris generated during a Loss of Coolant Accident (LOCA). The strainer design is of sufficient capacity to ensure that debris loading effects following a LOCA, as calculated in accordance with the guidance specified in Regulatory Guide 1.82, Revision 2,

" Water Sources for Long-Term Recirculation Cooling Following a Loss of Coolant Accident,"

do not cause a loss of Net Positive Suction Head (NPSH) for the ECCS pumps. This design is completely passive and requires no operator inte:vention, nor does it require an intermption of ECCS flow for strainer cleaning or backflushing. Since this design relies solely on passive structures and components, no new Technical Specifications (TS) surveillance requirements (SR) for the strainers are required. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00291 Unit 1 EUnit 2 UCommon[

This modification replaced fourteen large case multipoint recorders in the MCR with one Data Acquisition System (DAS). These recorders monitored non-safety related plant parameters l

such as temperature, conductivity, vibration, eccentricity, and metal expansion. They provided l

no control or trip functions. None of the recorders were safety related, or were required for TS compliance. One of the recorders interfaced with a safety related system, HPCI, but it was not being utilized as indication for any safety related parameters. This change affected a section of l

the UFSAR and is an overall enhancement to maintenance and operations.

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LIMERICK GENERATING STATION UNITS 1 AND 2 i

DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPI-85 MOD P00391,Rev.1 Unit I hUnit 2 lx, Common u This modification involved the installation of a Hydrogen Water Chemistry (HWC) control l

system which provides the capability to inject hydrogen gas into the reactor coolant through the l

feedwater system to control oxygen concentration to a level that reduces the potential for l

Intergranu'ar Stress Corrosion Cracking (IGSCC). This modification involved the installation of equipment modules and interconnecting piping and wiring inside the Control Structure and l

Turbine Enclosures, breaching walls and floors with barrier requirements, and tie-ins to existing piping systems. None of the HWC equipment is safety related. This revision addressed the integrated startup testing and operation of the HWC system in addition to providing justification for the use of Programmable Logic Controllers (PLCs) and Digital i

l Process Controllers (DPCs). The operations of the HWC system does not affect the function or l

operations of the feedwater, condensate, offgas or interfacing systems in a manner that would increase the probability of occurrence of a malfunction of equipment important to safety. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00391, Rev. 2 Unit 12 Unit 2 5 Common U This modification involved the installation of a HWC control system which provides the capability to inject hydrogen gas into the reactor coolant through the feedwater system to control oxygen concentration to a level that reduces the potential for IGSCC. This modification involved the installation of equipment modules and interconnecting piping and wiring inside the Control Structure and Turbine Enclosures, breaching walls and floors with barrier requirements, and tie-ins to existing piping systems. None of the HWC equipment is l

safety related. This revision added a master trip function to provide an off-normal shutdown of l

the HWC system. This system shutdown capability is provided to allow HWC system I

shutdown from the MCR in the event the Programmable Logic Controller (PLC) would fail in a locked-up mode. This revision also covered the automatic reset of the MCR HWC system trouble alarm when local trouble alarms are acknowledged, a provision for automatic switching from a depleted gas supply tube trailer to a standby trailer, relocating the hydrogen injection piping tie in, and increasing the line size for the Unit 2 HWC oxygen injection line from 1" to 1 1/2" This change affected a section of the UFSAR and is an overall enhancement to i

maintenance and operations.

MOD P00580 Unit 1 [x Unit 2_jCommon i This modification replaced the Unit I low pressure (LP) turbine rotors and high pressure (HP) turbines. The replacement turbines were designed and manufactured by Siemens Power l

Comoration (SPC). The replacement LP turbines are a " shrunk-on-disk" design. Therefore, SPC has provided a new methodology for analyzing missile generation probability that addresses the design of the replacement turbines in combination with the existing General Electric (GE) Control System. This modification involved revisions to the Turbine System Maintenance (TSM) Program based on the SPC missile generation probability methodology.

This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF 85 MOD P00580-Z Unit 1 EUnit 2 hCommon[

This modification installed a third crane in the turbine enclosure to support the Turbine Retrofit Project, Modification P00580. These changes included: adding a 110 ton capacity crane with a 30 ton capacity auxiliary hoist, adding a ladder and a cab necess platform, st pplying a new offsite power source from Load Center 00-B150 to the cranes, and adding a local area radiation monitor in the cab of the new crane. This crane is non-safety related, seismic category II, and is designed to the same requirements as the other two existing cranes. The installation of the third crane or operation of all three cranes simultaneously has no ic the plant operaing status. The testing of the crane installation was performed to confirm n acturalintegrity and functional adequacy in accordance with procedures. This change affected a section of the.

UFSAR and is an overall enhancement to maintenance and operations.

MOD P00702 Unit 1 xjUnit 2 LjCommon LJ This modification added two local valv? control stations for the emergency operation of six Residual Heat Removal (RHR) valves in the event of fire induced control cable damage. This modification was required to satisfy the Fire Safe S!,atdown (FSSD) re-analysis under Project 8655, Thermo-Lag Reduction. This change did not alter the design basis operation of these valves. It provides a new location for the emergency operation of these valves in the event of a fire. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00703 Unit 15 Unit 2 [ Common U This modification rerouted cables associated with the Main Steam Relief Valves (MSRV),

Reactor Vessel Instrumentation (RVI), and Suppression Pool Instrumentation (SPI) systems to allow them to survive the new FSSD fire analysis in fire areas 025,043E,043W,045E,047E, t

and 047W. The cables associated with PSV-041-lF013 A, C, and N were rerouted between the RSP and penetration 10JX105A. This reroute moved the cables out of fire areas of concern per the new FSSD fire analysis and allows for a reduced amount of additional encapsulation in room 506W. The cables for LT-042-lN010, PT-042-IN006, and SV-057-183 were rerouted and will be encapsulated in room 506W as part of modification P00736. The cables to TE-041-101D and H were repulled between the RSP and the instruments and encapsulated in room 506W. This modification also added check valves and accumulators in-line with the Primary Containment Instrument Gas (PCIG) piping to MSRVs PSV-041-lF013A, C, and N. This change assures that the valves have an adequate air supply to operate during the initial FSSD event. The accumulators and associated piping are non-Q, classified Seismic Category IIA, consistent with the pre-existing piping design. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

1 NCR 96-00518 Unit 1 x_ Unit 2 LCommoni This NCR addressed the concern about the level of compliance to the ASME code for the Unit 1 RHR heat exchangers. A review was performed of the records for material certification, testing, inspection, Quality Assurance (QA) audits, and preservice testing and inspection. This review concluded that the heat exchangers have been demonstrated to be structurally sound and capable of performing their required function in their present condition.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 96-02654 Unit 1 AUnit 2 ACommen U The repair disposition of this NCR addressed concerns regarding the adequacy of the 150 micro-ohm number specified in TS SR 4.8.2.1.b.2 and 4.8.2.1.c.3. There was a concem that if enough of the connection resistances deteriorated to the TS limit, then the affected battery might not be capable of performing its safety function. A review of the basis of the TS SR for cell-to-cell and terminal connection resistance was performed and concluded that the value in the TS is not nonconservative. An evaluation of the as-installed condition of the batt' ries by examining a e

significant number of surveillance tests performed was done on the Class 1E batteries and determined that the current as-installed condition of the batteries is in conformance with the TS and the manufacturer's recommendations. It was recommended that the surveillance test procedures be enhanced by performing the surveillances for connection resistance in accordance with the latest industry guidance, Institute of Electrical and Electronics Engineers (IEEE) 450-1995. This NCR affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

NCR 96-03144 Unit 1 EUnit 2 UCommon U This interim use-as-is disposition of the NCR evaluated a pin hole leak on Emergency Service Water (ESW) system room unit cooler l A-V209 in the Unit 1 HPCI compartment. The cooler is a safety related, ASME Section III, Class 3 component. The leak is characterized as a " pin hole" and is not actively leaking, which does not present a problem for the cooler or surrounding equipment. The structural integrity and functionality of this component with this leak was evaluated by visual examination of the leak, review of the stress analysis of the adjoining piping, assessment of the characteristics of previous room cooler leaks, and comparison with evaluation of ESW system pipe pin hole leaks as described in calculations LM-068 and LM-080. Based on the conservati<ms contained in the previous evaluations in comparison with the visually observed conditic : of the subject cooler, it was concluded that the structural integrity requirements of the cooler am maintained within the ASME Section III and XI stress limits. The leak is isolatable and will be reworked during the next available equipment outage window using acceptable ASME repair methods developed under ECR 95-00243 or by cooler replacement.

NCR 96-04087 Unit 12 Unit 2 [ Common This NCR provided justification that the Drywell Chilled Water (DCWS) and the RECW systems' piping and equipment are qualified to all required accident conditions, including LOCA. In the case of DCWS and RECW, only a portion of the systems are Seismic Category I. The balance of the systems are Seismic Category IIA and Seismic Category II. It was concluded that the requirement to maintain loop seal by RECW and DCWS is solely related to a LOCA inside of primary containment and that there is no postulated scenario that would require this post accident loop seal function to depend on Seismic Category I equipment. This change affected a section of the UFSAR and is an overall enhancement to operations.

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LIMERICK GENERATING STATION UNITS 1 AhT 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF485 NCR 97-00334 Unit I hUnit 2 x Common!_j This NCR removed the pressure restricting orifice plates from fire hose stations at Limerick Generating Station (LGS). A re-evaluation of the maximum pressure requirements in National Fire Protection Association (NFPA) 14,1996 edition, revealed that the pressure restrictions had been raised from 100 psi to 175 psi for hose valves used by fire department personnel. The hose stations at LGS are for fire brigade use only and employees are prohibited from using these hoses, therefore 175 psi is the appropriate pressure limitation. The increased pressure at the spray nozzle resulting from the removal of the orifice plates does not have any adverse effects on the fire brigade personnel operating the hose line. This change affected a section of the UFSAR and is an overall enhancement to operations.

NCR 97-00611 Unit 15 Unit 2 Common U The interim disposition for this NCR, revisions 0 and 1, abandoned the Unit I recirculation pump seal leak detection flow switches FSH-043-lN002A/B. The switches measure seal leakage flow to the drsvell equipment drain sumps and actuate a main control alarm when leakage flow exceeds a high fww setpoint. The subject flow switches were determined to be inoperable due to their installed configuration which did not provide adequate hydraulic head to operate the internal parts of the switches. The final disposition for this NCR, revision 2, replaced the abandoned flow switches with a combination thermal flow tube and electronic switch FT/ FISH-043-101 A/B to restore the functionality of the pump seal leakage high flow alarms. The thermal flow tube contains no internal components that can impede fluid flow and will function in this low hydraulic head application. This final disposition involved non-safety related equipment and systems, and the affected equipment does not impact or interface with any safety related systems or components. This NCR affected a section of the UFSAR and is an overall enhancement to operations.

NCR 97-01601 Unit 1 LUnit 2 xjCommon J This use-as-is disposition of the NCR addressed the effects of a lost tie wrap in the Unit 2 spent fuel pool. It was determined that the presence of this item in the spent fuel pool would not cause any unacceptable blockage of coolant to any fuel bundle being stored in the pool, and would not physically damage the spent fuel, the spent fuel storage racks, or the spent fuel pool liner. In addition, if this tie wrap were to migrate into the reactor vessel during refueling activities, it would disintegrate at reactor operating conditions, thereby causing no impact on reactor safety.

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