L-2004-206, Supplemental Information Alternate Source Term License Amendment

Supplemental Information Alternate Source Term License Amendment

ML042710263
Person / Time
Site:	Saint Lucie
Issue date:	09/24/2004
From:	Jefferson W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2004-206
Download: ML042710263 (17)

Text

Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach, FL 34957 FPL September 24, 2004 L-2004-206 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 RE:

St. Lucie Unit 2 Docket No. 50-389 Supplemental Information Alternate Source Term License Amendment On September 18, 2003, Florida Power and Light Company (FPL) submitted the St.

Lucie Unit 2 Alternate Source Term (AST) license amendment request via FPL letter L-2003-220. As a result of the FPL submittals and a teleconference with the NRC staff on June 28, 2004, the NRC requested additional information to assist in their review of the proposed amendment via NRC letter dated July 9, 2004. An additional NRC question was provided to FPL via an NRC (Arroyo) to FPL (Madden) e-mail dated August 2, 2004.

FPL letter L-2004-203 dated September 21, 2004, provided the additional information requested.

The original license amendment request for St. Lucie Unit 2 did not take credit for the Unit 2 emergency core cooling system (ECCS) area ventilation system charcoal filters.

However, FPL's response to question 7.b in Attachment 1 of L-2004-203 required that credit be taken for the Unit 2 ECCS area ventilation system charcoal filters.

This development required a change to the previously proposed St. Lucie Unit 2 Technical Specifications for the ECCS area ventilation system. Although the need for the required Technical Specification changes were acknowledged in FPL letter L-2004-203, the Technical Specification page changes and revised No Significant Hazards determination are being submitted by this supplement.

A summary of the changes to the ECCS area ventilation system surveillance requirements and the justification of the changes are provided in Attachment 1. The revised No Significant Hazards determination and replacement marked up and smooth TS changes are attached as Attachments 2, 3, and 4, respectively.

C,(D an FPL Group company

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Page 2 In accordance with 10 CFR 50.91(b)(1), a copy is being forwarded to the State Designee for the State of Florida. Please contact us if there are any questions about this submittal.

William &4ers Vice President St. Lucie Plant WJ/GRM Attachments cc:

Mr. W. A. Passetti, Florida Department of Health

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Page 3 STATE OF FLORIDA

)

)ss.

COUNTY OF ST. LUCIE

)

William Jefferson, Jr. being first duly sworn, deposes and says:

That he is Vice President, St. Lucie Plant, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on b half of saicensel Williaf r

Jr.

STATE OF FLORIDA COUNTY OF ST. LUCIE Subscribed and sworn to before me this

.y day of 2004.

ai Geo R Mddsf 4,j MY COfllflioanD0318814 m

ofWJ Am W17 2006 tar~i y Pe rc pe r P nt William Jefferson, Jr. is personally known to me.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 1 Page 1 Attachment I Justification for the proposed Emergency Core Cooling System (ECCS) Area Ventilation System Technical Specification Surveillance Tests The July 9, 2004 NRC RAI included information requests on the calculation assumptions of ECCS area leakage and it's contribution to total dose in the LOCA analysis. The FPL response included a LOCA reanalysis as well as crediting the Unit 2 ECCS charcoal filter train in the dose calculation with a resulting net dose decrease to control room personnel of 40 mrem over the 30 day period. FPL committed in the RAI response (L-2004-203) to include the charcoal filters in the Unit 2 ECCS area ventilation system surveillance requirements as part of the Technical Specification amendment package.

The format for the new ECCS area ventilation system surveillance requirements was modeled after the similar Unit 1 ECCS area ventilation system specification.

The acceptance criteria for Unit 2 are based on the guidance of Reg. Guide 1.52 and the analysis assumptions of the revised LOCA analysis. The LOCA analysis assumes filter efficiencies of 99% particulate and 95% for elemental and organic iodine. The specified testing protocols are consistent with those required for other Unit 2 ventilation system surveillance requirements (i.e., ANSI N510-1980 for in-place and ASTM D3803-1989 for lab testing)

The original St. Lucie Unit 2 licensing basis did not include credit for the ECCS area ventilation system filter trains. In Section 6.5.1 of the Unit 2 Operating License NRC Safety Evaluation', no removal efficiency was assigned to the system since FPL took exception to Regulatory Guide 1.52, Revision 2, requirements regarding humidity control and inclusion of high efficiency particulate air (HEPA) filters downstream of the charcoal adsorbers. These exceptions are addressed in Updated Final Safety Analysis Report (UFSAR) Table 6.5-1.

The need for humidity control is addressed by virtue of the Unit 2 design similarity to the Unit 1 design. The Unit 2 ECCS area ventilation system provides the identical capacity and serves the same equi ment as the Unit 1 system. At the time of Unit 1 operating license Safety Evaluation, humidity control was also initially an NRC concern.

As documented in the Supplement 1 of the NRC Safety Evaluation Report3, this concern was addressed by an FPL analysis that determined the heat rise due to operating equipment is sufficient to reduce humidity to acceptable levels and a heater system was not required. Since the Unit 2 ECCS design is similar to Unit 1, this same logic can be applied. This position is discussed in Unit 2 UFSAR Table 6.5-1. Based on the above, heaters for humidity control are not required.

1 NUREG-0843, Safety Evaluation Related to the Operation of St. Lucie Plant, Unit No. 2, USNRC, October 1981.

2Safety Evaluation of the St. Lucie Plant Unit No. 1, USAEC, November 8, 1974.

3 Supplement No. 1 to the Safety Evaluation of the St. Lucie Plant Unit No. 1, USNRC, May 9, 1975.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 1 Page 2 The absence of HEPA filters downstream of the charcoal adsorbers is also discussed in Unit 2 UFSAR Table 6.5-1.

The Combustion Engineering Standard Technical Specifications4, Section B3.7.13, the downstream HEPA filters are not credited in the analysis. In addition, the RADTRAD-NAI program used to calculate St. Lucie alternate source term (AST) doses considers decay and progeny of isotopes on filters and the subsequent release of noble gases from the filters, whereas the NRC approved RADTRAD program does not. This feature of the RADTRAD-NAI filter model results in additional conservatism in the filtered dose calculation.

Based on the above, the absence of downstream HEPA filters is acceptable.

4 NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 3, USNRC.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 2 Page 1 ATTACHMENT 2 Revised Determination of No Significant Hazards Considerations Proposed Change Florida Power and Light Company (FPL) proposes to revise the St. Lucie Unit 2, licensing basis to implement the alternate source term (AST), described in Regulatory Guide (RG) 1.183, through reanalysis of the radiological consequences of the following limiting Updated Final Safety Analysis Report (UFSAR) Chapter 15 accidents:

• Loss-of-Coolant Accident (LOCA)

• Fuel Handling Accident (FHA)

• Main Steam Line Break (MSLB)

• Steam Generator Tube Rupture (SGTR)

• Reactor Coolant Pump Shaft Seizure (Locked Rotor)

• Control Element Assembly (CEA) Ejection

• Letdown Line Break

• Feedwater Line Break (FWLB), and

• Waste Gas Decay Tank (WGDT) Rupture.

As part of the full implementation of this AST, the following changes are assumed in the analysis:

The total effective dose equivalent (TEDE) acceptance criterion of 10 CFR 50.67(b)(2) replaces the previous whole body and thyroid dose guidelines of 10 CFR 100.11.

New onsite (Control Room) and offsite atmospheric dispersion factors are developed.

Dose conversion factors for inhalation and submersion are from Federal Guidance Reports (FGR) Nos. 11 and 12, respectively.

• Increased values for control room unfiltered air inleakage are assumed (unfiltered inleakage increased until applicable dose limit is approached).

• A steam generator tube leakage rate that is more restrictive than the current Technical Specification limit is utilized.

• Credit for the emergency core cooling system (ECCS) area ventilation system high efficiency particulate air (HEPA) and charcoal filters is being taken.

• The shield building ventilation system (SBVS) bypass leakage value selected is more restrictive than the current Technical Specification limit.

The full implementation of the AST is supported by the following Technical Specification (TS) changes:

The definition of Dose Equivalent 1-131 in Section 1.10 is revised to reference Federal Guidance Report No. 11 (FGR 11), Limiting Values of Radionuclide Intake and Air

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 2 Page 2 Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, 1989, as the source of thyroid dose conversion factors.

The reactor coolant system (RCS) operational leakage limits, stated in TS Limiting Condition for Operation (LCO) 3.4.6.2, RCS Operational Leakage, for total primary-to-secondary leakage through all steam generators is reduced from 1 gpm to 0.3 gpm. In addition, the limit specified for primary-to-secondary leakage through any one steam generator is reduced from 720 gallons per day to 216 gallons per day.

TS Surveillance Requirement 4.7.8 is being revised to include surveillance of the HEPA and charcoal filters in the ECCS area ventilation system to assure the filters meet the flowrate and filtration efficiency assumed in the AST analyses.

The leakage rate acceptance criterion for secondary containment bypass leakage paths (i.e. shield building bypass leakage) stated in TS 6.8.4.h, Containment Leakage Rate Testing Program, is reduced from 12% to 9.6%.

No Significant Hazards Consideration The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists.

A proposed amendment to an operating license for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in the margin of safety. Florida Power & Light Company (FPL) has reviewed this proposed license amendment for St. Lucie Unit 2 and determined that would not involve a significant hazards determination. The bases for this determination follows.

1. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Alternative source term analyses have been performed for St. Lucie Unit 2 that demonstrate the dose consequences remain below limits specified in NRC Regulatory Guide 1.183 and 10 CFR 50.67. The proposed change does not modify the design or operation of the plant. The use of an AST changes only the regulatory assumptions regarding the analytical treatment of the design basis accidents and has no direct effect on the probability of any accident. The AST has been utilized in the analysis of the limiting design basis accidents listed above. The results of the analyses, which include the proposed changes to the Technical Specifications, demonstrate that the dose consequences of these limiting events are all within the regulatory limits.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 2 Page 3 The proposed Technical Specification changes to the RCS operational leakage limits, the shield building bypass leakage rate acceptance criterion, and the ECCS ventilation system surveillance requirements result in more restrictive requirements and support the AST revisions to the limiting design basis accidents. The ECCS area ventilation system does not initiate any design basis accidents.

Thus, performing additional surveillance tests do not increase the probability of any previously evaluated accident. The additional surveillance tests will not increase the consequence of any previously evaluated accident, rather the surveillance tests provide additional assurance that the HEPA and charcoal filters are capable of mitigating the consequences of accidents consistent with AST assumptions.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed change does not affect any plant structures, systems, or components.

The operation of plant systems and equipment will not be affected by this proposed change. The alternative source term, the more restrictive proposed leakage limits, and the ECCS filter surveillance requirements do not have the capability to initiate accidents.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment does not involve a significant reduction in the margin of safety.

The proposed implementation of the alternative source term methodology is consistent with NRC Regulatory Guide 1.183. The Technical Specification changes to the RCS operational leakage limits, the shield building bypass leakage rate acceptance criterion, and the ECCS ventilation system surveillance requirements, result in more restrictive requirements and support revisions to the radiological analyses of the limiting design basis accidents.

Conservative RG 1.183 methodologies have been used in performing the accident analyses.

The radiological consequences of these accidents are all within the regulatory acceptance criteria associated with use of the alternative source term methodology.

The proposed changes continue to ensure that the doses at the exclusion area and low population zone boundaries and in the control room are within the corresponding regulatory limits of RG 1.183 and 10 CFR 50.67. The margin of safety for the radiological consequences of these accidents is considered to be that provided by meeting the applicable regulatory limits, which are set at or below the 10 CFR 50.67 limits. An acceptable margin of safety is inherent in these limits.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 2 Page 4 Therefore, the proposed change does not involve a significant reduction in the margin of safety.

Based on the above discussion, FPL has determined that the modifications to proposed change do not change the result the original a significant hazards consideration.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 3 Page 1 Revised Marked Up TS Pages Adding Charcoal Filter Testing to the Surveillance Requirements TS Page 3/4 7-20 Inserts la, lb, and 1c

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 3 Page 2 PLANT SYSTEMS 314.7.8 ECCS AREA VENTILATION SYSTEM LI lTI1N CONDITION FOR OPERATION 3.7.8 Two independent ECCS area ventilation shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

t system trains ACTION:

trasin With one ECCS area ventilation system inoperable, restore the inoperable train systemrto OPERABLE status within 7 days or be in at least HOT STANDBY within

-he-next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MURVEQU1REMENI 4..6 Each ECCS area ventilation system shall be demonstrated OPERABLE:

a.

ast once per 31 days on a STAGGERED TEST i

nitiating from ntrol room and verifying that the syst erates for at least 15 mm

b.

At least once per 18 mon

1.

Verify sm flow rate of m + 10% during system a

ion.

2.

Verifying that the system starts on a safety injection actuation test signal.

See Insert la, lb, lc

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 3 Page 3 Insert la 4.7.8 Each ECCS area ventilation system train shall be demonstrated OPERABLE:

a.

At least once per 31 days on a STAGGERED TEST BASIS by initiat-ing, from the control room, flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 minutes.

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:

1.

Verifying that the charcoal adsorbers remove > 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

2.

Verifying that the HEPA filter banks remove > 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

ST. LUCIE - UNIT 2 314 7-20

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 3 Page 4 Insert lb PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (continued)

3.

Verifying that a laboratory analysis of a carbon sample from either at least one test canister or at least two carbon samples removed from one of the charcoal adsorbers demonstrates a removal efficiency of > 97.5% for radio-active methyl iodide when the sample is tested in accordance with ASTM D3803-1989 (300C, 70% RH). The carbon samples not obtained from test canisters shall be prepared by either:

a)

Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed, or b)

Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

4.

Verifying a system flow rate of 30,000 cfm + 10% during system operation when tested in accordance with ANSI N510-1980.

c.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation by either.

1.

Verifying that a laboratory analysis of a carbon sample obtained from a test canister demonstrates a removal efficiency of > 97.5% for radioactive methyl iodide when the sample is tested in accordance with ASTM D3803-1989 (300C. 70% RH); or

2.

Verifying that a laboratory analysis of at least two carbon samples demonstrate a removal efficiency of > 97.5% for radioactive methyl Iodide when the samples are tested in accordance with ASTM D3803-1989 (300C, 70% RH) and the samples are prepared by either.

a)

Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed, or b)

Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

ST. LUCIE - UNIT 2 3/4 7-20a

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 3 Page 5 Insert 1c PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3.

Subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the system shall be demonstrat-ed OPERABLE by also:

a)

Verifying that the charcoal adsorbers remove > 99.95%

of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%, and b)

Verifying that the HEPA filter banks remove > 99.95%

of the DOP when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

d. At least once per 18 months:

1.

Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is < 4.35 inches Water Gauge while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

2.

Verifying that the air flow distribution is uniform within 20% across HEPA filters and charcoal adsorbers when tested in accordance with ANSI N510-1980.

3.

Verifying that the system starts on a Safety Injection Actuation Signal.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove

> 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N51 0-1 980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

ST. LUCIE - UNIT 2 3/4 7-20b

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 4 Page 1 Revised Typed TS Pages Adding Charcoal Filter Testing to the Surveillance Requirements TS Pages 3/4 7-20 3/4 7-20a

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 4 Page 2 PLANT SYSTEMS 3/4.7.8 ECCS AREA VENTILATION SYSTEM LIMITING CONDITIONTOR-OPERATION 3.7.8 Two independent ECCS area ventilation system trains shall be OPERABLE.

APPLICABILITY: MODES 1. 2.3, and 4.

ACTION:

With one ECCS area ventilation system train inoperable, restore the inoperable system train to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.8 Each ECCS area ventilation system shall be demonstrated OPERABLE:

a.

At least once per 31 days on a STAGGERED TEST BASIS by initiating from the control room, flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 minutes.

b.

At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release In any ventilation zone communicating with the system by.

1.

Verifying that the charcoal adsorbers remove > 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

2.

Verifying that the HEPA filter banks remove > 99.95% of the DOP when they are tested in-place in accordance with ANSI N51 0-1980 while operating the ventilation system at a flow rate of 30,000 cfm

+ 10%.

3.

Verifying that a laboratory analysis of a carbon sample from either at least one test canister or at least two carbon samples removed from one of the charcoal adsorbers demonstrates a removal of > 97.5% for radioactive methyl iodide when the sample is tested in accordance with ASTM D3803-1989 (30 0C. 70% RH). The carbon samples not obtained from test canisters shall be prepared by either:

a)

Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed, or b)

Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

4.

Verifying a system flow rate of 30,000 cfm + 10% during system operation when tested in accordance with ANSI N510-1980.

ST. LUCIE -UNIT 2 314 7-20 Amendment No.

St. Lucie Unit 2 Docket No. 50-389 L-2004-206 Attachment 4 Page 3 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation by either

1.

Verifying that a laboratory analysis of a carbon sample obtained from a test canister demonstrates a removal efficiency of > 97.5% for radioactive methyl Iodide when the sample is tested in accordance with ASTM D3803-1989 (300C, 70% RH); or

2.

Verifying that a laboratory analysis of at least two carbon samples demonstrate a removal deficiency of > 97.5% for radioactive methyl iodine when the samples are tested In accordance with ASTM D3803-1989 (300C, 70% RH) and the samples are prepared by either a)

Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed, or b)

Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

3.

Subsequent to reinstalling the adsorber tray used for obtaining the carbon sample, the system will be demonstrated OPERABLE by also:

a)

Verifying that the charcoal adsorbers remove > 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place In accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%, and b)

Verifying that the HEPA filter banks remove > 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm +/- 10%.

d.

At least once per 18 months by.

1.

Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is < 4.35 inches Water Gauge while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

2.

Verifying that the air flow distribution is uniform within 20% across HEPA filters and charcoal adsorbers when tested in accordance with ANSI N510-1980.

3.

Verifying that the system starts on a Safety Injection Actuation Signal.

e.

After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove > 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm + 10%.

f.

After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove > 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 30,000 cfm

+ 10%.

ST. LUCIE - UNIT 2 314 7-20a Amendment No.