ML17037C475

Letter Regarding Review of Technical Specifications Related to Installed Filter Systems and Requesting a Submittal of Application for Amendment to Technical Specifications in Conformance with Model Specifications

ML17037C475
Person / Time
Site:	Nine Mile Point
Issue date:	12/10/1974
From:	Lear G US Atomic Energy Commission (AEC)
To:	Raymond P Niagara Mohawk Power Corp
References
Download: ML17037C475 (20)

Text

DISTRIBUTION:

AEC PDR Local PDR Docket DEC 1 0 1974 ORBII3 Rdg KRGoller Docket Ho. 50-220 TJCarter GLear CJDeBevec SATeets Niagara Mohawk Power Corporation RO (3)

ATTN: Mr. Philip D. Raymond OGC Vice President Engineering ACRS (16) 300 Erie Boulevard ablest extra cps Syracuse, New Yorl: 13202 Gentlemen:

Our review of your Technical Specifications related to installed filter systems indicates a need for additional Limiting Condit1ons for Operation (LCO) and Surveillance Requirements. These are required in order to en-sure high confidence that the systems will function reliably, when needed, at a degree of efficiency equal to or better than that assumed in the accident analyses.

In order to assist you in the preparation of appropriate revisions, we have prepared model Technical Specifications which include LCO's, Surveillance Requirements and Bases for the following Nine Mile Point Unit 1 systems:

1) Control Room Air'reatment Systems

2) Standby Gas Treatment System You are requested to submit by not later than January 30, 1975, an application for amendment to your license that would change the Technical Specif1cations related to installed filter systems so as to be in confornI1nce with the requirements in the enclosed model Technical Specif1cations.

Sincerely, Original Signed George Lear, Chief Operating Reactors Branch 83 Directorate of Licensing

Enclosure:

Model BUR Technica1 Spec1fications cc: See next page OPPICC~ ORB//3 0 U It N A M C 3P'RBiI3 3t CDeBevec:kmf GLear QL DATC 12/ /74 12/ 0 /74 Foan AEC.318 (Ref. 9-53) AXCM 0240 4V 4 OOVCltNMCNT PltINTIN4 OffICCI IQ74 42d 'ldd

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Hr., Philip D. Raymond DEc 1 0 I cc: w/enclosure Mr.'Arvin E. Upton, Esquire LeBoeuf, Lamb, Leiby & HacRae 1757 N Street, NtT Mashington, D. C. 20036 Dr. Villiam E. Seymour Staff Coordinator New York State Atomic Energy Council New York State Department of Commerce 99 Mashington Street Albany, New York 12210 Hiss Juanita Kersey, Librarian Oswego City Library 120 E. Second Street Oswego, Ncw York 13126 OPPICC~

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~S 3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVE ILLRNCE REQUIREMENTS B. Control Room Afr Treatment S stem B. Control Room Air Treatment S stem

l. Except as specified in Specification l. At least once per operating cycle, the 3.0.B.3 below, the control room afr  ; pressure drop across the combined NEPA treatment system.and the diesel filters arid charcoal adsorber banks t

generators required for operation shall be demonstrated to be less than af thfs system shall be operable 6 incties of water at system design flow at all times when containment rate.

. integrity fs requfred.

2. a. The tests and sarrple analysis of

2. a. The results of the in-place cold -. ~

ti Spec i f i ca on 3..0. 8;2 sha 1 1 be DOP and halogenated hydrocarbon performed initially and at least tests at design flows on HEPA once per year foi 'standby service filters and charcoal adsorber banks or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system shall show >995 DOP removal and ~995 operation and following significant halogenated hydrocarbon removal. painting, fire or chemical release in any ventilation zone coomunfcatfr.

b. The results of laboratory carbon with the system.

sample analysis shall show >90K radioactive methyl iodide removal b. Cold DOP testing shall be performed at a velocity within 20K gf system after each complete or partial repla ment of the )IEPA filter bank or afte c.

design, .0;05 to 0.15 concentration, Fans shaH be shown

+10K design flow.

mg/m~ inlet iodide

>95K R.H. and >125'F.

to operate wfthfn any structural maintenance on the system housing.

c. 'iialogcnated hydrocarbon testing perforir.ed after each complete or shal'e t

partial replacement of the charcoal adsorber bank or after any structura.

maintenance on the system housing.

d. Each c!rcuit shall be operated at least 10 hours every month.

3.0 LIHITIHG COtlOITIONS FOR OPERATICtl 4.0 SURVEILLCtCE REQUIREt<EtlTS'.

From and after the date that the 3. At least once per operating cycle control room air treatuent system automatic initiation of the control is made or found to he inoperable. room air treatment y'stem shall be

.for any reason, reactor operation demonstrated.

or refueling operations is permissible on1y during the succeeding seven days unless such circuit is sooner made operable.

4. If these conditions cannot be net,

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reactor shutdown shall be initiated and the reactor shall be in cold

. shutdown vrithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for reactor operations and refueling operations shall be terminated iomediately.

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• Bases 3.0.B. Control Room Air Treatment S stem The control room air treatment system is desiqn'.8 to filter the control r'oom atmosphere for intake for recirculation during control roo". i:olation conditions. The control room air air'ntj/or is designed to automatically start u,ion control room isolation and to maintain the control roon treatment'ystem pressure to the design positive pres:ure so that all leakage should be out leakage.

)ligh eff)ciency part)cu)ate absolute (IIL'M) fil:ers are installed before the charcbal adsorbers. to prevent clogging of the io1in adsorber;. The chai. coal adsorbers are installed to reduc the potential . ~

intake of radioiodine to the control room. The in-place test results should indicate a system leak tightness of less than 1 percent bypass'eakage for the charcoal adsorbers and a l{EPA efficiency cf at least 99 percent removal of DOP particulates. ,he laboratory carbon sample test results should indicate a radioactive methyl iodide removal efficiency of at least 90 percent for expected accident conditions.

If the efficiencies of the I!EPA filter" and charcoal aCsorbers are as specified, the re:ul ting doses will be less than the allowable levels stat'd in Criterion 19 of the General Design Criteria for ~:uclear Power Plants, Appendix A to 10 CFR'Part 50. Operation of the fans significantly different from the design flow will change the removal efficiency of the HEPA filters and charcoal adsorbers.

If the system is found to be inoperable, there is not ixt".iediate threat to the control room and reactor operation or refueling operation m~y contin~e for a limited period of time while repairs are being made.

If the system cannot be repaired within seven days, the reactor is shutdown and brought to cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or refueling operations are terminated.

Bases 4.O.8 Control Room Air Treatment 5 stem Pressure drop across the cothined.l!EPA filters and charcoal adsorhers of less than 6 inches of iiater at the. system design flow rate will indicate t'ot the filters and* adsorbers are not,clogged by excessive amounts of foreign matter. Pressure drop should be determined at least once per'operating cycle to show system performance capability.

The frequency of'ests and sample analysis are necessary to show that the llEPA filters ard charcoal adsorbers can perform.as evaluated. Tests rf,-'.sic charcoal adsorbers with halogenated hydrocarbon shall be perform)ed. in "accordance wi tlat IISALC fl~::) ~rt -1G'l2. Iodine reproval ef ficiency.tc..sts shall follow ROT Standard II-1C-1T. The clurcoal ahirber efficiency test procedures should allo:( for the removal of one adsorber tray, er:ptying of one !,cd from the tray, mixing the .adsorbent thoroughly and obtaining at least toto samples. Each s .:.pie shnuld be at least two inches in diameter and a length equal to the thief;ness of the bed. If test re,ults are unacceptable, all adsorbent in the system sha11 be=replaced with an ad:orbent qua'l.ified .according to Table 1 of Regulatory Guide 1.52. The replacement tray for the.ail;orbcr tray rorno'" l fo'r tne test 'hruld meet tne same adsorbent quality.

Te ts of the HERA filters with COP aerosol:l>..11 be perfonoed in accordance to AtlSI fl101.1-1972.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to.Regulatory Position C.3.d of Regulatory Guide 1.52.

Operation of the system for '10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every von'.h will. demonstrate operability of the filter's and adsorber system and remove excessive moisture Juilt up on the adsorber.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fu.~s, chemicals or foreign materials, the same tests and sample analysis shall be perfor...ed as required for operational use. The determination of significant shall be made by the operator or. d ty at the tire of the incident. Knowledgeable staff members should be consulted prior to raking this determination.

Demonstration of the automatic initiation capability is necessary to assure system performance capabil i ty.

~l 3.7 LIMITIHG CONDITIONS FOR OPERATION 4~7 SURVE ILLAHCE REQUIREMENTS

.B+ Standb Gas Treatment S stem B. Standb Gas Treatment S stem

l. Except as specified fn Specification 1. At least once per operating cycle, the.

3.7.8.3 below, both circuits of the following conditions shall be demonstrated standby gas treatjaent system and the diesel generators required for ~

a. Pressure drop across the combined operation of such circuits shall be HEPA filters and charcoal adsorber~

operable at all times when secondary banks fs less than 6 inches .of.

containment integrity is requir'ed. watei at the system design flow ra te.

2. a The results of the in-place cold DOP and halogenated hydrocarbon tests at b. Inlet 'heater input is capable 'of design flows on HEPA filters and reducing R;H. from 100 to 7sOX R.H..

charcoal adsorber banks shall show

>995 DOP removal and > 99Ã Cm Afr distribution i's uniform .wf.thfn Ralogenated hydrocarbon removal. 20$ across HEPA filters and charcoal adsorbers.

b. The results of laboratory carbon sample analysis shall show <<95K 2~ a~ The tests and sample analysis of

. radioactive methyl iodide removal Specification 3e7.8.2 shall be at a velocity within 20 percent of perforated initially and at least actual system design, 0.5 to 1.5 once per year for standby service mg/m~ inlet methyl iodide concentra- or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of tion, <<70K R.H. and >190'F. system operation and following.

significant painting, fire or

c. Fans shall be shown to operate within chemical release in any ventilation

+105 design flow. zone communicating with the system.

Cold DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural mafntenance on the system housing.

3.7 LIHITING CONDITIONS FOR OPERATION 4 ~ 7 SURVEILLANCE REgUIACtXHTS

c. Malogena ted hydrocarbon ter,ting shall be performed after each. complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

d. Each circuit. shall be operated with the heaters on at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

e. Test sealing of gaskets for housing doors downstream of the HEPA-filters and charcoal adsorbers shall be performed at and in conformance-with each test performed for compliance with Specification 4;7.8.2.a and Specification 3.7.B.2.a.

3+ From and a fter the da te tha t one 3.. System drains where present shall be inspected circuit of the standby gas treatment quarterly for adequate water level in system is made or found to be loop-seals.

inoperable for any reason, reactor operation and fuel handling is 4. a. At least once per operating cycle

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permissible only during the succeeding seven days unless such circuit is sooner made operable, provided that- during such seven days of circuit shall be all active operable.

components the other standby gas treatment b.

automatic initiation of each. branch of the standby gas treatment system shall be demonstrated.

At least once .per operating cycle manual operability of the bypass valve t

for filter cooling shall be demonstrated.

4, If these conditions cannot be met, procedures shall be initiated c. When one circuit of the standby gas immediately to es.tablish reactor ~ treatment system becomes inoperable conditions for which the standby ~ the other circuit shall be demonstrated to be operable immediately and daily gas treatment system is not required.

thereafter.

Bases 3,7,8 Standb Gas Treatment S stem The standby gas treatment'system is designed to filter and exhaust th'e reactor building atmo'sphere to

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the stack during secondary containment isolation conditions. Doth standby gas treatment system fans are designed to automatically start upon containment isolation and to maintain the reactor building pressure to the design negativ'e pressure so that all leakage should be in-leakage. Should one system fail to start, the redundant system is designed to start automatically. Each of the two fans has 100 percent capacity.

High efficiency particulate absolute (IIEPA) filters are installed before and after the charcoal adsorbers to minimize potential release of'particulates to the environment and to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the envirorment. The in-place test results should indicate a system leak tightness of less than.l percent bypass leakage for the charcoal adsorbers and a IIEPA efficiency of at least 99 percent removal of OOP.

particulates, The laboratory carbon sample test results should indicate a radioactive methyl iodide removal efficiency of at least 95 percent for expected accident conditions. If the efficiencies of the IIEPA filters and charcoal adsorbers are as specifird, the resulting doses will be less than the 10 CFR 100 guidelines for the accidents analyzed. Operation of the fans significantly different from the design flow will change the removal efficiency of the IIEPA filters and charcoal adsorbers.

Only one of the two standby gas treatment systems is needed to cleanup the reactor building atmosphere upon containment isolation. If one system is found to be inoperable, there is no iranediate threat to the containment system performance and reactor operation or refueling operation may continue while repairs are being made. If neither circuit is operable, the plant is brought to a condition where the standby gas treatment system is not required.

t g Bases 4.7.B. Standb Gas Treatment S stem Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 6 inches of water at the system design fIow rate will indicate that the filters.and a4sorbers are not clogged by excessive amounts of foreign matter. Heater capability, pressure drop and air distribution should be determined't least once per operating cycle to show qstem performance capabilfty.

. The frequency of tests and sample analysis are necessary to show that the HEPA'ilters and charcoal adsorbers can perform as evaluated.- Tests of the charcoal adsorbers wfth halogenated hydrocarbon refrigerant shall be perfortncd in accordance with USAEC Report OP-10."2. Iodine removal efficiency tests shall follow RDT Standard H-16-IT. The charcoal adsorber, efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples. E'ach sample should be at least two inches fn diamete'r and a length equa1 to the thickness of the bed. If test results are unacceptable, all a4sorbent in the system shall be replaced with an adsorbent qualified according to Table I of Regulatory Gu'ide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. Tests of the HEPA filters with DOP aerosol shall be performed fn accordance to AIISI HIOI.I-1972. Any HEPA filters fo'und defective shall be replaced With filters qualified pursuant to Regulatory Posftfon C;3.d of. Regulatory Guide 1.52.

All elements of the heater should be demonstrated to be functional and operable during the test of Operation of the heaters will'revent moisture buildup fn the filters and adsorber system. heatel'apacity.

Mfth doors closed and fan fn operation, DOP aerosol shall be sprayed externally along the full linear perfphery of each respectfve door to check the gasket seal. Any detection of OOP fn the fan exhaust shall be considered an unacceptable test result and the gaskets repairs and test repeated.

If system drains are present in the filter/adsorber banks, loop-seals must be use4 with adequate water level to prevent by-pass leakage from the banks.

If significant painting, fire or chemical release occurs such. that the HEPA filter or charcoal adsorber could become contaminate4 from the fumes, chemicals or foreign material, the same tests and sampIe analysfs deafly.

shall be performed as required for operational use. The determination of significant shall 'be made by the operator on duty at the time of the fncident. Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capabilfty and operability of filter cooling is necessary to assure system performance capability. If one standby gas treatment system is inoperable, the other system must be tested This substantiates the availability of the operable system and thus reactor operation

<B'efueling op<<tfon can continue far a limited period of time.

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