ML18139A777

Application for Amend of Licenses DPR-32 & DPR-37,adding Tech Specs 3.22 & 4.20 Re Components of Auxiliary Ventilation Sys & Changing Tech Specs 4.15 Re IE Bulletin 79-14 & 4.18 Re Inservice Insp.Class III Fee Encl

ML18139A777
Person / Time
Site:	Surry
Issue date:	10/28/1980
From:	Ferguson J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Varga S Office of Nuclear Reactor Regulation
References
862, IEB-79-14, TAC-43113, TAC-43114, NUDOCS 8010310411
Download: ML18139A777 (12)

Text

e e-RrcIDto.:-.n. VrnoLY.LA. 23261 J .... c,.: H. :FEno-.:;soN October 28, 1930 Xr. Harold R. D~nton, Director Serial* No. 862 Office of_Nuclear Reactor Regulation ~O/~v1ill: ms Attn: Mr. Steven A. Varga, Chief Docket Nos. 50-280 Operating Reactors Branch No. 1 50-281 _

Division of Licensing License Nos. DPR-32 U. S. Nuclear Regulatory Commission DPR-37.

- w~shington, D. c~ 20555

Dear Mr. Denton:

Al'f2IDME~"'T TO OPERATING LICENSES DPR-32 A1'fD DPR-37 SURRY POw"ER STATION UNITS NO. 1 A:.'i-U 2 PROPOSED ~ECHNICAL SPECIFICATION C}L.i\NGE Pursuant to 10 CFR 50. 90, the Virginia Electric and Power Company requests .an amendment, in. the form of changes to the Technical Specifications, to Ope rat~

ing Licenses DPR-32 and DPR-37 for-:: the Surry Power Station, Units 1

• and 2.

The proposed changes are enclosed.

The pro.posed changes will add Technical Specifications Sections 3. 22 and 4. 20 to reflect changes to be ::nade to components of the safety related auxiliary ventilation system in order to provide redundancy ne*cessary t*o meet s_ingle failure criteria. The principal differences in the new design from the former design consist of the re:1ssignment and dedication of the system *components to-specific functions. Among these differences are that the new QC II filter will reduce the use of the QC I filters during. normal .St3tion operation, the dedication of the new QC I fans to exhaust ~ir withdrawal through tb.e QC I filters, and the additional assignment to the QC I filters of mitigating t~e consequences of a refueling accident inside the conta_illi::ie_nt in i::h~ sam~ ma,me:i;-

as the original design 111itig:1ted the consequences of* an accide!lt 1.n the fuel

'building.

The seismic* *reanalysis of safety related p1.p1.ng systems required for

• IE*

Bulletin 79--14 has indicated six new 'break points which must be incorporated in . the High Energy Pipe Break Inspection Program specified in Tech..11ica-l Specification 4.15-A. The proposed changes will -revise Specification "4.15-A co indicate that there are 26 welds to be included in the inspection progrc~

.,nd will revise TS Figure 4.15 to indicate the location of the six additional 11cof

~ce~k ins?~ction points.

In our* letter of 'April :22, 1980 (Serial No. 370) to :1r. D. G. Eisenhut, we. s provided information concerning the f;,ilure of a fire p~p. to :.ieet *th: accep-cance criteria of Specific3tion 4.18.B.l.£(2) for a periodic test des~gned to 3/vo

.iemonstrate ope:r3'bility. Further investigation h:1s indicated that the critc- w/cJ..cc./t~

-)J c./lfoo.oo t II f}

e e Mr. Harold R. Denton 2

\"1 f!Gl:-;I.\ tL!c:C:-f!IC .\~D ?ow:::11 CO!iP.\!-o--Y ro ria of 250 feet of head at 2500 gpm~fn Specification 4.18.B.l.f(2) exceeds both the origiI:lal desig~ criteria of 244.9 feet at 2500 gpm and the FSAR requirement of 100 psi discharge pressure at 2500 gpm. The proposed change will revise Specification 4.18.B.1.f(2) to require 231 feet (100 psi) Total Dynamic Head at 2500 gpm.

This request has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the System ~uclear Safety and Operating Committee. It has been determined that this request does not involve an unreviewed safety-*

question as defined in iO CFR 50.90.

We have evaluated this request in accordance with the criteria in IO CFR 170.22. This request involves issues which the Staff should be able to deter-mine do not pose a signific:int hazards consideration; therefore, _a Class III.

license amendment fee is required for Unit 1 and a Class I license amendment fee is required for Unit 2. Accordingly, a voucher* che.ck in the amount of

$4,400.00 is enclosed in payment of the required fees.

It should be. noted that issuance of the proposed chai.1ges related to the au.xiliary ventilation syste~ should be withheld pending completion of the associated design modifications. We will inform . you when the modifications are complete.

Very truly yours, J. H. Ferguson Executive Vice President Power

..\t t:ichments:

1. Proposed Technical Specification Change

2. Voucher Check No. 42727 for $4,400.00 cc: Mr. James P. O'Reilly, Director Office of Inspection and Enforcement Region II

e TS 3.22-1

3. 22 AUXILIARY VENTILATION EXlL\UST FILTER TRAINS -

Applicability Applies to the abilities of the safety-related system to remove particulate matter and gaseous iodine following a LOCA or a refueling accident.

~ective To specify requirements to ensure the proper function of the system .

Specificatio*ns A. During station operation or refueling operations, the following conditions

• shall be met:

1. System flow rate test in the LOCA mode of operation shall show design flow of 36,000 cfm +/- 10 percent.

2. Air distribution test at the fac~ of the prefilte~-bank shall show uniformity of air velocity 1;ithin +/- 20 percent of average velocity.

3. Ill-place cold DOP.tests on HEPA filterS shall Show greater than or equal co 99.percent removal.

4. In-place halogenated hydrocarbon leakage tests on charcoal adsorb~r b,rnks sha 11 show ~rc3 ter th,1n or equal to 9-9 Dercent re!novaL

e e. TS 3.22-2

5. Laborntory analysis on charcoal samples shall shoYl .at least 95 percent methyl iodide removal at 0.125 sec.+/- 20 percent residence time, 0~5 to 1.5 mg/in3 inlet methyl iodide concentration, .relative humidity greater than or equal to 80 percent, and air temperature greater 'than or equal to 125°F.

6. The pressure drop across filter cells -and adsorbers shall not exceed 7,0 inches W.G.

B. With one circuit of the filter system inoperable for any reason, return the circuit to operable status within 7 days or initiate reactor shutdown and immediately terminate fuel handling operations .

Basis The purpose of the filter trains located in the atLxiliary buil1ing is to provide standby capability for removal of particulate and iodine contaminants from the exhaust air of the .charging pump cubicles of the auxiliary building, fuel buildi.:1g, decontam,ination building, sa.feg~ards building adj 3cent to the containHients, and the reactor contai::w.ent (during sb.utdowq) whic_h discharge through the ventilation vent and could require filtering prior to release.

Duri~g nor,!!31 plant operation, the exhaust from any one of these areas can

• be diver:ed, if required, ~hrougb the auxiliary building filter trains re2ote-*

ly £':-:.;;. ~h:: cont:::-ol room. The s::fc:gt!2r,.is b 1ild:ng exhai.:st .:rnd t:-ie charging 1

pW,Jp ;:1.1oicle exhaust are aut.om:1ti"c:1lly diverted through the filter trai!ls in the event of a LOCA (diverted on high-high contain.ment pressure)'. The fuel build:.n 5 cXhJ.t!st and pu:::ge ~xh.rnst .He aligned to contirrnously f'3SS through the filters during spent fuel hJndling~

e. e.

TS 3.22-3 High efficiency particulate absolute (H:EPA) filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the 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 removal of *DOP particulates. The heat release from operating ECCS equipment limits the relative humidity of the exhaust air to.less than*SO percent even ~};l.en outdoor air is*assumed to be 100.

percent relative humidity arid all ECCS. leakage *evaporates into the exhaus*t air stream. The laboratory carbon sample tests are required to indicate a radioactive methyl iodide removal efficiency of at least 95 percent at a relative humidity greater than or equal.to 80 percent. If the efficiencies of the HEPA filters and charcoal adsurbers are as specified, at flow rates, velocities, and relative hwnidities ~hich are less :*than the d~sign values*

of the filter banks, the resulting doses will be less than IO CFR 100 guidelines for the accidents analyze~ The offsite dose calculations. for LOCA and fuel handling accidents assume only 90 perce!lt and 70 :perce~t, respectively, iodiu.~ remova.l efficiency- for the ai!." passing through the*

charcoal filters. Therefore, _the*demonstr~tion of 99 percent leakage efficiency and 95 percen.'t methyl iodide remova1 efficiency :;.;i_ll ...

assure the req~~red capability of the filters is met or exceeded.

~. TS 4.20-1

4. 20 AUXILIARY VENTILATION EXll.'\UST FILTER TR:\INS Applicability Applies to the testing of safety-related air filtration systems.

Objective To verify that leakage efficiency *and iodine removal efficiency are within acceptable limits.

-~'Specifications

r.

• A. Tests and Frequencv I. Auxiliary ventilation system exhaust flow rate through the filters in the LOCA mace of operation shall be determined initially and after

.. . ---~; ..... - . ': :: . - ,,- ~-~-. ~  ; .

. * -~- ./~*

ani major .modification or r_epair of the system.

2. The system exhaust flow cate th!'otigh eachfilt2r train shall be determined for the LOCA mode of operation by aligning Unit l or Dnit 2 Safeguards room exhaust and the exhaust from three chargi~g pli!llp cubicles through the filters~

• The method for determining the system air flow rate shall be in accordance with Section 9 of ACGIH

• Industrial Ventil.1tion.

TS 4.20-2

3. An air distribution test acro~s the HEPA filter bank shall be performed initially and after any major modification or major repair of the air cleaning system.

4. The air distribution test shall be performed with an anemometer located at the upstream side and at the center of each HEPA filter cell.*

5. In-place cold DOP tests for HEPA filter banks shall be performed:

a. Initially,

b. At least once'per refueling cycle,* i.e., approximately eighteen months.

c. Follo~.;ing significant... painting, fire, or chemical release in any ventilation zone ccmrnunicating with t:1.e system,

d. After each complete or partial replac_er:ient of the HEPA filter cells, and

e. After any structural maintenance on the filter housing.

6. The proc~du~e fo~ in-place cold DOP tests shall be in accordance with .\.,.~SI NSl0-1975, Section 10.5 or 11.4.

7. In-place halogenated hydrocarbon leakage tests for the charcoal adsorbe~ b2nk sh2ll be pe~forxed:

b. At le~st once per refueling cycle, .i.e., approxi~a~ely eighteen months.

c. Foll0~ing significant painting, fir~, or chesic2l releJse in J.ny vc>ntilJ.c.ion zone coiru11unicatirrg ,:ith the system,

e ** TS 4.20-3

d. After each complete or p~a.rtial replacement of charcoal adsorber trays,and

e. After any structual maintenance on the filter housing.

8. The procedure for in-place halogenated hydrocarbon leakage tests shall be in accordance with A.t'-iSI-NSl0-1975, Section 12.S.

9. Laboratory analysis on charcoal samples shall be performed:

a. Initially, whenever a new batch of charcoal is used to f:tll adso rbe rs trays,

b. At least onca,per refueling cycle or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, and

c. Following significant paint, fire, or chemical release in any ventilation zone corrununicating with the syste!il.

10. The procedure f6r iodine removal efficiency tests shall follow RDT Standard n-16-lT. Charcoal samples for retest shall be taken*

from the test canisters.

11. The pressure drop across t~e E:1:PA filter and adsorQer banks shall be checked:

a. Initially,

b. At least once pe~ refueling cycle thereaf~er for systems

~aintained in a st2~dby s~atus o~ after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, ;rnd

c. After each c.:implete or partial repld<;e!llent of filters or adsorbers.

e e . TS 4. 20-4

12. Each redundant filter train eircuit shall be operated every month if it has not alr~ady been in operation.

13. At least once pe~ refueling cycle, the operability of .the entire s~fety-r~lated portion ~f the a~xiii~ry v~ritilation system ~hall be demonstrated.

14. wben one circuit of the filter trains system becomes inoperable, the operability of the other train shall b_e demon~trated immediate-.

ly and daily thereafter; B. Acceptarfce Criteria

,.... The exhaust air fl;;,w rate deter;:nined in Specifications 4.20.A.1 and-4.20.A.2 shall be within the limits specified in Specification 3.22.A. L The ventilation system shall" be adjusted until the *1I I

specified limits are met.

2. The results of air distribu~ion tests described in Specifications 4.20.A.3 and 4.20~A.4 shall be_ within the specif2ed limits of Specification 3.22.A.2. The ventilation system shall be .adjusted until the specified limits are met.

3. The results of in-plat~ DOP test described in Specifications 4.20:A.5 and 4.~0.A.6 shall be ~i~hin ihe limits of Specifi~atio~*i.t2.A.3.

Leakage sour.ces shall be i*dentified, repaired, and retested*. Any HEPA filt~rs found defoctive sh.:ill be replaced.

e TS 4.20-5

4. The results of in-place halogenated hydrocarbon leak test described in Specifications 4.20.A.7 and 4.20.A.8 shall be .within the limits of Specification 3.22.A.4. Leakage sources shall be identified, repaired, and retested.

5. The results of laboratory analysis of charcoal samples described in Specifications 4.20.A.9 and 4.20.A.10 shall be within the limits of Specification 3.22.A.S. If test results are unacceptable, all adsorbent in the system shall be replaced with new adsorbent.

6. Pressure drop across the HEPA filters and charcoal adsorber banks

~ .

measured in Specification 4.20.A.ll shall be within the limits of Specification 3.22.A.6. If this condition cannot be met, new filter t

cells shall be install~d:~

7* The minimum period of air flow through the filters will be 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />

. per month.

8. System operability test of Specification 4.20.A.13 shall demonstrate automatic start-up, shutdown and flow path alignment.

9. The filter train operability test of Specification 4.20.A.14 shall d~monstrate proper equipment start-up and shutdown and flow path alig!UJient.

'.."\.

e TS 4.20-6 Basis Ventilation system filter components are not subject to rapid deterioration, having lifetimes of many years~ even under continuous flow.conditions. The te;ts outline~ above provide aisurance of filter reliability and wiil ensure timely detection of conditions which could cause filter degradation.

Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 7 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.

Operation of the filtration ~ystem for a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a month prevents moisture buildup in the filters and adsorbers.

The frequency-of tests and sample analysis of the degradable components of the.

system, i.e., the HEPA filter and charcoal adsorbers, is based on actual hours of operation to ensure that they perform as evaluated~ System flow rates and air distribution do not change unless the ventilation system is radically altered. Consequently, less frequent testing has been specified for.the system.

flow rate and air distributio~.

If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal. adsorber could become con.t2minated from the fumes, chemical, 0r foreign material, the same tests lnd sample analysis are performed as r,~i;ui::-~d for oper2ti0n3l use. The dererr:J.i.n.1tion of "significant" is made by the *JE1erator on duty at the time of the incident. Ki.1m.;ledgeable staff members

~ould be consulted pri9r t6 making this determination.

e e SAFETY ANALYSIS TECHNICAL SPECIFICATION CHANGE REQUEST ~O.

SURRY POWER STATION UNITS 1 ~~D 2

}!edifications to the auxiliary ventilation system do not create an "unreviewed safety question" as defined in 10CFR50.59. The :nodified 3ystem adds redundancy to safety-related ventilation components in order to meet single-failure criteria.

The design is essentially the same as the original design. The differences in design consist principally in the reassignment and dedication of the system com-ponents to specific functions:

1. The new QC II filter will reduce the use of the QC I filters during norillal station ooeration.

• 2. The new QC I fans are dedicated to exhaust air withdrawal through the QC I filters.

3. The QC I filters are a~si~?ed the additional duty of mitigating the consequences of a refueling accident inside the containment in the same nanner as the original design mitigated the consequences of an accident in the fuel building.*

• The illodifications do ~ot f0r the reasons stated abova:*

a . . Increase the probability of occurrence> or the car.sequences of an accident, or :nalfunction of equi?sent isportant to safety previously evaluated in the Final Safety A::alysis Re?ort.

b. Cr~ate the possi~ility for an accident or malfunc~ion of a type different than .:my e\*. lu3.ted previously in the Fir.al Safety Analysis Report.

c. Reduce the margin of safety as defined 'in the basis for any techn!cal specification.