ML17054B052

Proposed Tech Specs Reflecting Recent Mods to Control Room Air Treatment Sys

ML17054B052
Person / Time
Site:	Nine Mile Point
Issue date:	10/01/1984
From:	NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML17054B050	List: ML17054B049 ML17054B051 ML17054B052
References
NUDOCS 8410040409
Download: ML17054B052 (28)

Text

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT EMERGENCY VENTILATION SYSTEM Applicability:

Applies to the operating status of the emergency venti 1 ation system.

Objective:

To assure the capability of the emergency ventilation system to minimize the release of radioactivity to the environment in the event of an incident within the primary containment or reactor building.

Specification:

4.4.4 EMERGENCY VENTILATION SYSTEM Applicability:

Applies to the testing of the emergency ventilation system.

Objective:

To assure the operability of the emergency ventilation system.

Specification:

a ~

Except as specified in Specification 3.4.4e below, both circuits of the emergency ventilation system and the diesel generators required for operation of such circuits shall be operable at all times when secondary containment integrity is required.

a.

At least once per operating cycle, not to exceed 24 months, the following conditions shall be demonstrated:

Emergency ventilation system surveillance shall be performed as indicated below:

b.

The results of the in-place cold DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall showh99X DOP removal and>99K halogenated hydrocarbon removal when tested in accordance with ANSI N.510-1980.

(1)

Pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches of water at the system rated flow rate

(+ lOX).

(2)

Operability of inlet heater at rated power when tested in accordance with ANSI N.510-1980.

84i0040409 84100i

-PDR ADOCK 05000220 P,

PDR 173

i

LIMITING CONDITION FOR OPERATION SURVEILLANCE RE UIREMENT d.

Fans shall be shown to operate within

+ lOX design flow.

e.

From and after the date that one circuit of the emergency ventilation system is made or found to be inoperable for any reason, reactor operation and fuel handling is permissible only during the succeeding seven days unless such circuit is sooner made operable, provided that during such seven days all active components of the other emergency ventilation circuit shall be operable.

f.

If these conditions cannot be met, within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, the reactor shall be placed in a condition for which the emergency ventilation system is not required.

c.

The results of laboratory carbon sample analysis shall show ~905 radioactive methyl iodide removal when tested in accordance with ANSI N.510-1980 at 80'C and 95K R.H.

b.

C.

d.

e.

The tests and sample analysis of Specification 3.4.4b, c and d shall be performed at least once per operating cycle or once every 24 months, or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, whichever occurs first or following significant painting, fire or chemical release in any ventilation 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 maintenance on the system housing.

Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing.

Each circuit shall be operated with the inlet heater 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.

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 4.4.4b and Specification 3.4.4b.

174

0

LIMITING CONDITION FOR OPERATION SURVEILLANCE RE UIREMENT g.

At least once per operating cycle, not to exceed 24 months, automatic initiation of each branch of the emergency ventilation system shall be demonstrated.

h.

At least once per operating cycle, not to exceed 24 months, manual operability of the bypass valve for filter cooling shall be demonstrated.

When one circuit of the emergency ventilation system becomes inoperable all active components in the other emergency ventilation circuit shall be demonstrated to be operable within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and daily thereafter.

175

BASES FOR 3.4.4 AND 4.4.4 EMERGENCY VENTILATION SYSTEM The emergency ventilation system is designed to filter and exhaust the reactor building atmosphere to the stack during secondary containment isolation conditions.

Both emergency ventilation system fans are designed to automatically start upon high radiation in the reactor building ventilation duct or at the refueling platform and to maintain the reactor bui lding pressure to the design negative pressure so as to minimize 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 (HEPA) 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 th environment.

The in-place test results should indicate a system leak tightness of less than 1 percent bypass leakage for the charcoal adsorbers and a

HEPA efficiency of at least 99 percent remomval of OOP particulates.

The 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 HEPA filters and charcoal adsorbers are as specified, the resulting doses wi 11 be less than the 10CFR100 guidelines for the accidents analyzed.

Operation of the fans significantly different from the design flow will change the removal efficiency of the HEPA filters and charcoal adsorbers.

Only one of the two emergency ventilation systems is needed to cleanup the reactor building atmosphere upon containment isolation.

If one system is found to be inoperable, there is no immediate threat to the containment system performance and reactor operation or refueling operation may continue whi le repairs are being made.

If neither circuit is operable, the plant is brought to a condition where the emergency ventilation system is not required.

Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 6 inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

Heater capability and pressure drop should be determined at least once per operating cycle to show system performance capability.

The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsor ber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed.

If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified in Table 5-1 of ANSI 509-1980.

176

BASES FOR 3.4.4 AND 4.4.4 EMERGENCY VENTILATION SYSTEM The replacement charcoal for the adsorber tray removed for the test should meet the same adsorbent quality.

Any HEPA filters found defective shall be replaced with filters qualified pursuant to ANSI 509-1980.

All elements of the heater should be demonstrated to be functional and operable during the test of heater capacity.

Operation of the inlet heater will prevent moisture buildup in the filters and adsorber system.

With doors closed and fan in operation, DOP aerosol shall be sprayed externally along the full linear periphery of each respective door to check the gasket seal.

Any detection of DOP in the fan exhaust shall be considered an unacceptable test result and the gaskets repairs and test repeated.

If significant painting, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign material, the same tests and sample analysis 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 incident.

Knowledgeable staff members should be consulted prior to making this determination.

Demonstration of the automatic initiation capability and operability of filter cooling is-necessary to assure system performance capability.

If one emergency ventilation system is inoperable, the other system must be tested daily.

This substantiates the availability of the operable system and thus reactor operation or refueling operation may continue during this period of time.

177

LIMITING CONDITION FOR OPERATION SURVEILLANCE RE UIREMENT 3.4.5 CONTROL ROOM AIR TREATMENT SYSTEM App 1 ic ab ility:

Applies to the operating status of the control room air treatment system.

4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM App 1 i cab i 1 ity:

Applies to the testing of the control room air treatment system.

Objective:

Objective:

To assure the capability of the control room air treatment system to minimize the amount of radioactivity or other gases entering the control room in the event of an incident.

To assure the operability of the control room air treatment system.

Speci f ication:

Specification:

a 0 Except as specified in Specification 3.4.5e below, the control room air treatment system and the diesel generators required for operation of this system shall be operable at all times when containment integrity is required.

a.

At least once per operating cycle, or once every 24 months, whichever occurs first, the pressure drop across the combined HEPA filters and charcoal adsorber banks shall be demonstrated to be less than 6 inches of water at system design flow rate (+lOX).

b.

The results of the in-place cold DOP and halogenated hydrocarbon test design flows on HEPA filters and charcoal adsorber banks shall show > 99K DOP removal and > 99%%d halogenated hydrocarbon removal when tested in accordance with ANSI N.510-1980.

b.

The tests and sample analysis of Specification 3.4.5b, c

and d shall be performed at least once per operating cycle or once every 24 months, or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, whichever occurs first or following significant painting, fire or chemical release in any ventilation zone communicating with the system.

178

LIMITING CONDITION FOR OPERATION SURVEILLANCE RE UIREMENT Specification:

c.

The results of laboratory carbon sample analysis shall show> 90K radioactive methyl iodide removal when tested in accordance with ANSI N.510-1980 at 80'C and 95K R.H.

e.

From and after the date that the control room air treatment system is made or found to be inoperable for any reason, reactor operation or refueling operations is permissible only during the succeeding seven days unless the system is sooner made operable.

f.

If these conditions cannot be met, reactor shutdown shall be initiated and the reactor shall be in cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for reactor operations and refueling operations shall be terminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

d.

Fans shall be shown to operate within + lOX design flow.

C.

d.

e.

Specification:

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

Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal absorber bank or after any structural maintenance on the system housing.

The system shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

At least once per operating cycle, not to exceed 24 months, automatic initiation of the control room air treatment system shall be demonstrated.

178a

BASES fOR 3.4.5 AND 4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM The control room air treatment system is designed to filter the control room atmosphere for intake air.

A roughing filter is used for recirculation flow during normal control room air treatment operation.

The control room air treatment system is designed to automatically start upon receipt of a high radiation signal from one of the two radiation monitors located on the ventilation intake and to maintain the control room pressure to the design positive pressure so that all leakage should be out leakage.

High efficiency particulate absolute (HEPA) filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorbers.

The charcoal adsorbers are installed to reduce 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 leakage for the charcoal adsorbers and a

HEPA efficiency of at least 99 percent removal of DOP particulates.

The 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 HEPA filters and charcoal adsorbers are as specified, adequate radiation protection will be provided such that resulting doses will be less than the allowable levels stated in Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10CFR 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 no immediate threat to the control room and reactor operation or refueling operation may continue for a limited period of time while repairs are being made.

If the makeup system cannot be repaired within seven

days, the reactor is shutdown and brought to.cold shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> or refueling operations are terminated.

Pressure drop across the combined HEPA filters and charcoal adsorbers of less than six inches of water at the system design flow rate will indicate that 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.

In addition, air intake radiation monitors will be calibrated and functionally tested each operating cycle, not to exceed 24 months, to verify system performance.

The frequency of tests and sample analysis are necessary to show the HEPA filters and charcoal adsorbers can perform as evaluated.

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.

Each sample should be at least two inches in diameter and a length equal to the thickness of the bed.

If test results are unacceptable, all adsorbent in the system shall be replaced with an absorbent qualified according to Table 5-1 of ANSI 509-1980.

The replacement charcoal for the adsorber tray removed for the test should 178b

BASES FOR 3.4.5 AND 4.4.5 CONTROL ROOM AIR TREATMENT SYSTEM (Continued)

. meet the same adsorbent quality.

Any HEPA filters found defective shall be replaced with filters qualified

'ursuant to ANSI 509-1980.

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 month will demonstrate operability of the filters and adsorber system and remove excessive moisture built 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 fumes, chemicals or foreign materials, the same tests and sample analysis 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 incident.

Knowledgeable staff members should be consulted prior to making this determination.

178c

LIMITING CONDITION FOR OPERATION 3.6.2 PROTECTIVE INSTRUMENTATION App1 icab i 1 ity:

Applies to the operability of the plant instrumentation that performs a safety function.

SURVEILLANCE REQUIREMENT 4.6.2 PROTECTIVE INSTRUMENTATION App 1 icab i 1 ity:

Applies to the surveillance of the instrumentation that performs a safety function.

Objective:

Objective:

To assure the operability of the instrumentation required for safe operation.

Specification:

To verify the operability of protective instrumentation.

Specification:

a.

The set points, minimum number of trip

systems, and minimum number of instrument channels that rust be operable for each position of the reactor mode switch shall be as given in Tables 3.6.2a to 3.6.2m.

a.

Sensors and instrument channels shall be checked, tested and calibrated at least as frequently as listed in Tables 4.6.2a to 4.6.2m.

If the requirements of a table are not met, the actions listed below for the respective type of instrumentation shall be taken.

(1)

Instrumentation that initiates scram - control rods shall be

inserted, unless there is no fuel in the reactor vessel.

188

LIMITING CONDITION FOR OPERATION SURVEILLANCE RE UIREMENT (8)

Off-Gas and Vacuum Pump Isolation - The respective system shall be isolated or the instrument channel shall be considered inoperable and Specification 3.6.1 shall be applied.

(9)

Diesel Generator Initiation - The diesel generator shall be considered inoperable and Specification 3.6.3 shall be applied.

(10) Emergency Ventilation Initiation The emergency ventilation system shall be considered inoperable and Specification 3.4.4 shall be applied.

(ll ) High Pressure Coolant Injection Initiation - The high pressure coolant injection system shall be considered inoperable and Specification 3.1.8.c shall be applied.

(12) Primary Containment Monitoring - The primary containment monitoring instrumentation shall be considered inoperable and Specification 3.3.8 shall be applied.

(13) Control Room Ventilation - The control room ventilation system shall be considered inoperable and Specification 3.4.5 shall be applied.

b.

During operation with a Maximum Total Peaking Factor (MTPF) greater than the design value, either:

190

LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT (1)

The APRM scram and rod block settings shall be reduced to the values given by the equations in Specification 2.1.2.a; or (2)

The power distribution shall be changed such that the MTPF no longer exceeds the design value.

190a

Table 3.6.2m CONTROL ROOM AIR TREATMENT SYSTEM INITIATION Limiting Condition for Operation Parameter Minimum No.

of Tripped or Operable Trip Systems Minimum No. of Operable Instrument Channels per Operable Trip System Set Point Reactor Mode Switch Position in Which Function Must Be Operable (1) High Radiation Ventilation Intake

<1000 CPM O

Vl X

X X

232d

Table 4.6.2m CONTROL ROOM AIR TREATMENT SYSTEM INITIATION Surveillance Requirement Parameter (1) High Radiation Venti 1 ation Intake Sensor Check Once/shift Instrument Channel Test Once per quarter Instrument Channel Calibration Once each operating cycle not to exceed 24 months 232e