ML19098B462

Provide Additional Information Re Containment Spray System-Iodine Removal, Questions 14, 16-18, LOCA Dose Analysis, & Recirculation Spray System, Including Proposed Tech Spec Changes

ML19098B462
Person / Time
Site:	Surry
Issue date:	05/09/1977
From:	Stallings C Virginia Electric & Power Co (VEPCO)
To:	Case E, Reid R Office of Nuclear Reactor Regulation
References
Serial No. 045A/020177
Download: ML19098B462 (65)

Text

{{#Wiki_filter:\\ e VIRGINIA ELECTRIC AND POWER COMPANY RIO~MOND, VIRGINIA 23261 May 9,. 1977:, _REGULATORY DOCKIT foLE CIJPJ Mr. Edson G. Case Acting Director of Nuclear Reactor Regulation U. s. Nuclear Regulatory Commission Washington, D. c. 20555 Serial No. 045A/020177 PO&M/ALH:dgt Docket Nos. 50-280 50-281 Attention: Mr. Robert W. Reid, Chief Operating Reactors Branch 4 License Nos. DPR-32 DPR-37

Dear Mr. Case:

The attached report entitled, "Response to Request for Additional Infonnation" is provided to address the 18 questions posed in your letter of February 1, 1977. The report is.self-explanatory and we believe that it thoroughly addresses the staff's concerns. You will notice that "Proposed Technical Specification Changes" are included as requested by your staff. It is emphasized that these changes are preliminary and are not being submitted for your approval and issue. These changes are included for information only. When our station and system safety committees have completed there review of these changes, they will be submitted in the nonnal fashion. The schedule for implementing the equipment modification associated with this report was presented in our April 6, 1977 letter. Progress to date indicates that design work is proceeding on schedule. We will keep you infonned as to our progress in this matter. Attachment Very truly yours, to.J?1. y//att~ ;r

c. M. Stallings Vice President-Power Supply and Production Operations

RESPONSE TO REQUEST FOR ADDITIONAL DIB'ORMATION Section 1 Containment Spray System - Iodine Removal Section 2 Response to Questions 14, 16, 17, and 18 Section 3 LOCA Dose Analyses Section 4 Recirculation Spray System p1 J' ! l I ! l t

SECTION 1 CONTAINMENT SPRAY SYSTEM - IODINE REMJVAL 1.1 Design Considerations 1.2 System Design 1.J Design Evaluation 1.4 Tests and Inspections 1.5 Proposed Technical Specification Changes Section 1 includes responses to the following questions which are indicated in the margin of the page: Questions 2; 3; 4; 6; 7; 8; 9; 10; 11; *tl; and 15 p2

• \\,,

JI

I. Q4 Q6 SURRY 1 & 2 e 1.0 Containment Spray System - Iodine Removal The containment. spray system provides water spray to the containment during the unlikely event of a loss-of-coolant accident (LOCA) to depressurize the containment and to minimize tlle release of radioactive iodine to the environment. This section describes the iodine removal capability of the containment spray system. No credit is taken for iodine removal by the recirculation spray system. The recirculation spray system is discussed in Section 4.0 of this report. 1.1

• Design considerations The design considerations for the design modifications of the containment spray system*as follows:
• \\ I 11/,

L

1.

The system is capable of functioning e*ffectively with the sil').gle failure of an active component in* the spray system,* any of its subsystems, or any of its support systems. /

2.

The amount of radioactive iodine in the containment following a LOCA ** * (using T;[D-:-14 8 44 source terms) is reduced so that the outleakage results in a thyroid dose below*the*recommended Limits of 10CFR100.

3.

The spray system is designed to obtain adequate coverage of the**containment volume in order to limit the site boundary dose following a LOC..~ to a value.less than that established by 10CFR100.

4.

The spray nozzles are designed to possibility of.clogging while producing effective for iodine absorption. minimize the droplet sizes S. The containment spray system removes iodine from the sprayed portion of the containment atmosphere with an

6.

7.

8.

• elemental removal coefficient of at least 10 hr-1 and a particulate removal coefficient of at least 0.45 hr-1 assuming the worst single active failure.

The spray solution is a mixture of sodium hydroxide and boric acid with a pH range of 8.5 to 11.0 for all postulated operating modes of the system. Sufficient caustic is added to the sump during system operation such that the long term pH of the sump water is greater than 7.0. Facilities are provided for the long-term storage of NaOH in a state of continu~l readiness. 1-1 pJ

Q3 Q4 Q10 Q11 Q3 I I e SURRY 1 & 2

9.

The system* is initiated automatically by an appropriate accident signal and is capable of continuous operation

• until the design objectives of the system have been achieved, after which system operation is terminated and containment isolation is effected *.

1 *.2 system Design The containment spray system is shown in Figure 1-1. It consists of three $pray ring headers; two headers are located in the containm~nt dome and one header is located on the outside of the crane wall. These headers are supplied. by two pumps which take a suction. on the refueling water storage tank (RWST)

• Each pump supplies one dome header and the common crane wall header.

Each pump is equipped with an eductor which draws caustic solution from the-chemical addition tank (CAT) and discharges to the spray pump suct;:ion line. Component data i.s given in Table 1-1

• The containment spray system is initiated by the consequence limit.ing-safeguards (CLS) signal and becomes effective at*

approximately 66 sec following *the DBA. This total start-up delay is~made up of the following delays: Standby diesel generator startup 10 sec . -_;_Pump acceleration 10 sec _--.Piping fill time 46 sec

..**'fetal delay 66 sec The containment spray system draws borated water from the RWST.

When the RWST is emptied, containment spray operation is terminated and containment isolation effected. The borated water in the RWST has a maximum temperature of 45 F., Sodium hydroxide (NaOH) solution from the refueling water chemical addition tank (CAT) is added by means of the chemical addition system to the containment spray solution to improve its iodine removal capability. The chemical addition syste.~ uses eductors to add caustic (NaOH) into the containment spray pwrq;> suction pipes as shown in F:Lg. 1..;..1. Upon receiving a CLS signal, redundant valves between the CAT and the eductors open to allow caustic flow into the spray pump suction lines. These valves are closed during normal operation to prevent mixing of the NaOH with the boric acid in the containment spray piping. The eductor draws the NaOH at an essentially constant rate into the containment spray pump suction. This action ensures proper metering of the NaOH solution into the RWST fluid. Mixing takes place in the fully developed turbulent flow of the eductor, spray pu..~p and piping before reaching the spray nozzles. Since the caustic flow rate from the C~..T does not depend on the rate of 1-2* p4

Q2 Q8 Q8 Q7 Q4 ii->' ,

• I I

SORRY t & 2 I decrease in RWST level, the caustic flow rate is affected only by the nu.°'Uber of containment spray pumps operating and is independent of the flow rates of the ECCS pumps. The number of spray nozzles for each ring header is given in Table 1-1. A schematic of the headers which *u1ustrates the nozzle orientations is given in Fig. 1--2. All nozzles are inte:mal moving clogging while absorption. The of the SPRACO 1713A type. These nozzles have no parts and are of a design which minimizes producing droplet sizes effective for iodine orifice size is 3/8 in. in diameter. The mean droplet diarneter used in the iodine removal analysis is 10.00 microns. This is shown to be con.servatively. large by an extensive analysis by the, nozz!e manu£acturer {Ref. 1),. Histograms of the.observed drop size frequency distribution are included in the nozzle manufacturer's analysis. The spray coverage for each spray header is determined from the Typical coverage Charts from the nozzle manufacturer for the SPRACO 1713A nozzle at 40 psid across each nozzle. During system operation, the pressure drop accross ti~e nozzle will vary between 29 psid and 58 psid. Experimental data indicates that coverage remains the same in this range of nozzle pressure differential.

• ::tn orde.r to account for the increased density of the containment atmosphere following a LOCA, the distance travelled by the spray droplets shown in the manufacturer's coverage charts is multiplied by a correction factor to.account for increased drag on the droplets.

The dependence of the correction factor on the containment at."llosphere temperature is shown in Fig. 1-3. The total volume of the containment that is covered by the containment:, spray system is given in Table 1-2. The spray uniformly covers approximately 90 percent of the containment cross sectional area at the operating deck elevation and ~pproximately 73 percent of the total containment free volume. The system meets.the redundancy requirements of an engineered safety feature and will satisfy the system per£orrnance requirements despite the II'.ost limiting single active failure. System operation is not required in the long terma 1.3 Design Evaluation 1.3.1 Range of Spray pH In order to ensure compatibility of the materials inside the maintained between 8.5 adeq-uate iodine removal effectiveness cu""ld spray solution with the safety-related contairunent,,. the pH of the ~'"P.ray is and 11.0. 1-3 p5

,i ' I: ,o.t't.;;.~~..::..::...*,.rA..,.,...1,*

.5 "11 e

stJRRy-1 & 2- -

4, The conditions_ utilized in ca1cu1atirig-the minimum and_max

immn expected spray pH for the system-are given in Table 1-3.

The spray pH, will remain in the pH ~ange given in the table for all operati..'lg modes of the system. The values of the parameters used in calculating the limiting pH's are those proposed technical specification limits which tend.to minimize or maximize pH-as appropriate. The proposed changes to the technical specification limits are gi.ven in Section 1.S.. 1.3.2 Oltiniate.. Sump pH 'l'he minimuio: expected-ultimate sump pH_isgiveri iri Table 1-4 along with the boric acid and sodium hydroxide sources considered in the analysis.-- The-values of the parameters listed in this table are consistent with the appropriate proposed technical specification-limits which minimize the pH. 1.. 4 Tests_.. arid Inspections '!he tests performed on-the containment-spray system and the frequency of each test are* given in Chapter 16 (Technical Specifications) of the FSAR.* In addition,- the chemical addition subsystem L~ tested as follows: A preoperationai test with the chemical addition tank {CAT) filled with borated water will be perfo~d to ensure the proper operation of the eductors. This test will eonfinn the f-low rates for the containment spray pumps and the rate of NaOH additiona The results of this preoperational test with borated water will be compared with data from manufacturers* tests correlating the eductor flO'R rates for borated water with those for NaOH to confirm that system operation with caustic is as intended. Reference for Section 1

1.

Spray Analysis on SPRACO Model 1713A Nozzle by Spray Engineering Company, Burlington, Ma. 1 p6 I \\' ~- l-i

SURRY. 1. &. 2

• e TABLE 1-1 CONTAifil.IBNT SPRAY SYSTEM COMPONENT DATA Containment Spray Pump Number Type Rated flow,, gpm Rated head, ft Horsepower Sea1 Design. press~e,. psig Material Pump casing Shaft_

Impeller Containment Spray Pump Motor Number Horsepower Electrical characteristics Service factor Insulation Refueling Water Storage Tank Number* Type Usable volume, gal Boron Concentration, ppm 1 of* 3

• p?

2 H_orizontal centrifugal 3200 225 250 M~_<?..hanical 250 A351-CF8 A216-F316 A3~1-CF8 2 250 460 volt 3 phase 60 cycle* 1.15 Class 3 1 Vertical cyl~drical 350,000-388,000 2,000-2,500 " i I ~ I l*

SURRY 1 & 2 TABLE 1-1 (CONT'D} Design pressure, psig Design temperature, F Operating pressure, psig Operating temperature, F Material Design code Refueling Water Chemical Addition Tanlc Nwnber Type Usab1e volume, gal Design pressure, psig Design temperature, F Operating pressure, psig Operating temperature, F NaOH concentration, wti Material Design code Spray Headers Header Quantity Azimuth coverage, degrees Diameter, ft Pipe J:D, in *. No. of nozzles per header 2*of 3 p8 .*e Hydraulic head 150 Hydraulic head 45 ASTM-A240-Type 304 stainless steel* API STD-650 1 Vertical cylindrical 4130-4340 25 150 Hydraulic head <95 18-26 304 ss ASME Section VIII Dome 2 360 67 8 73 Crane wall .1 360 114 8 88

• SURRY 1 6 2 TABLE--1-1 -cCONT 1 D)

Mean diameter of spray droplets, microns Maximum spherical diameter th.at will pass through nozzles, in. Fn.uctors Number .Des1gn pressure, psig Design temperature, F Rated capacity, gpm. Operating pressure, psig Mat:er..ial 3 of 3 p9 <1,000 3/8 2 Water jet 250 150 34 104 A351-cF8 <1,000 3/8 . I I l t l l ! l i {, t ' f ~-

-*~~---.* SURRY 1 & 2 TABLE 1-2 CONTAINMEh'T VOLUMES COVERED BY SPRAYS ContaL11ment Subvol.ume Dome Operating floor to bend line (inside crane wall)

• Operating floor to bend line (outside crane wall)

Annulus outside crane wall. SG cubicle 1 SG cubicle 2 SG cubicle 3 Pressurizer cubicl.e Reactor Head Storage Hatch Pressurizer Relief Tank CUbicl.e Elevation Above 92 1 6 11, 47,4n-92 16n (-) 27*7n-47,4n (-) 316n-4714n (-) 3 16n-47,.4n

• (-) 3~6n-4714n 18 14"-47 1 4" 1a*4n-47,4n

(-) 3 1 6 9 -18 1 4" Total 1 of 1 p10 . Volume (ft3) 459,168 304,019 159,678 180,153 46,226 40,003

• 15,454 24,294 13,667 18,549 1,261,211

~ I I t 1 I I ' i I

SURRY 1 & 2 TABLE 1-3 PARAMETERS FOR CALCOLA'l'ING.MINIMUM AND MAXIMUM CONTAINMENT SPR'Z\\.Y pH Max pH=10.5 Min pH=8.5 No. of containment spray pumps operating 2 Spray flow from RWST, gpm per pump 1820 Boron Concentration in RWST, ppm 2000 Flow from CAT, gpm per eductor 34 Na.OH Concentration in CAT, wtX. 26 1 of 1 p11 1 2460 2500 30 18

StmR~---1.& 2 TABLE 4 PA.RAJ."'1ETERS FOR ULT~.ATE SUMP -- * *..

• pH CALCULATION RWST Volume Boron concentration in RWST Boron Injection Tank Volume Bo.ric. Acid. Concentration in BIT Reactor Coolant System Volume Boric. Aci:l Concentration in RCS SI Accumulator Volume Boric. Acid Concentration Vol.ume of: CAT.

NaOH Concentration in.CAT Minimum Ultimate S~p p~ 1 of 1 p12 388,000 gal 2,500 pprJ 1,000 gal 13 wti 48,700 gal 3,000 ppm 2~,400 gal '2,5QQ ppmY 4,130 gal 18 wt~. 7.6

f.

~-r u l t 1 I I & i I I I f I

3 4 6 1 II 9 l 11 l 611111 .. *-.Ff..~: _______________ ;K __ -___ .F\\._. ____ ~' r.**r*Jt.LrU. WAnt: s,-o,.~'lir.: TI\\N~ To s..,..,., .. 7,ur~*cr,~d A B C l D C1*Pl1<.AL A...,. 'TAl'Jlt ,l!2£;GAL E F - ' ) l ) \\ ) ( \\ ) ( 1-t~*i'-.3 C.11.1'. C.1HC. PU/.IP ) GI H J ..... t 7oRw.tr \\ K

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8'*C$** R *1'5:l ~--.; 73 A/Oll:-Z.L£~ PRE.LWIII\\JAI:.. y FIGURE 1-1 c....,,.,.,.,\\11*(11 '..,~Cl 1'.. r,*..... '2 I 1 ( ~"'T"' ,. I ". '-, 0 . "* I 1 T u I v .e. r

S NE E. WEBSTER ENGINEERING COP.?ORATION ~---'**--------1 Dome Headers Crane Wall Header TOWARD CONTAINMENT CENTERLINE --~-~.----!--~. (19) (31) (23) V (48) Note: Numbers in parentheses denote the number of nozzles supplied at this orientation on the header. CORRECT I I GON'l'A.f.W,i:2:i.\\T S.:-'P--\\I SY3'1Sd' N(,;;:,ZLS GR.EN'IA'i'IC:: ' J APPROVED . l I SURRY FOWS]. STATICN - T.,T}E'IS 1 &. 2 Figure l-2 OATE I ----~-----~~*-*~----------~ l ~EVl3il'.;,~S ~-~ ,__~~~~~~~~~-i

---

*--.-..----------**}-*----

JOO 275 250 r::... f Q) 225

I ~

+" (I) Qj..s::: ~ Ac (I)~ ~s .p ~< (.) 'O ..-1 Q) r-t.p Q) ~ 200 -§.~ rn ~ $ fJ) 175 150 CHECi<EO CORRECT 0.4 E.. W~BSTER EHSIN.EE:RING CORPOR TlON o.6 SPRAYCO 1713A NOZZLE Design Condition: 40 psi 0.8 LO CONTAill}lEH'l' SPRAY COVERAGE HULTI?LIER 1.2 "ONTAINIBNT SPRAY COV~R.AGE 1:*fuLTIFLIER Figur8 1-'.3 SU?..R.Y FOWER STA'I'ION - UNITS 1 t 2 1~ J .c i------------: I~ ;: \\' I S. C NS L-*----***-*-------

• • -* ---* ----*-""**--*- _______,_J_ __

Q1J Q15 1.5 Prooose~ Technical Snecification Changes The propos~d changes to the station technical specifications which involve the containment spray system, the chemical addition system, and ECCS leakage are given on the following pages. The proposed changes are indicated in the margin by an asterisk ( * ). The affected pages are:. TS J.3-1 TS 3.3-3 TS 3.4-1 TS 3.4-2 TS 4.5-2 TS 4.5-3 Table 4.5.1 TS 4.ll-3 Table 4.11.1 (Page 1) Table 4.ll.l (Page 2) p16

3. 3 S~""ETY INJECTION SYSTEM Applicability e

TS 3 *.3-1 11-26-76 Applies to the operating status of the Safety Injection System. Objective To define those limiting conditions f~r operation that are necessary to provide sufficient borated cooiing water to remove decay heat from the core in emergency situations. Specifications A. A reactor shall not be made critical unless the following conditions are met:

l. The refueling water tank contains not le~s than 350,000 gal. and not

2.

greater than 388,000 gal of borated water with a boron concentration of at least 2,000 ppm and not greater than 2,500 ppm. Each accumulator system is pressurized to at least 600 psia and con-tains a minimum of 1075 ft 3 and a maximum of 1089 ft 3 of borated I water with a boron concentration of at 'least 1950 ppm and not greater I* than 2,500 ppm.

3.

• The boron injection tank and_isolated portion of the inlet and outlet.

piping contains no less than 900 gallons and not greater than 1,000 gal I it' o:f.' water with a borer... 1 Amendment ~o. 26

• Proposed Change p17
  • .'<:~-- -#--.

~ ~-... - ---*. -* -- l I i I t I. 40 I~ t

1 J I~ j,j-j 1-6-77

9.

During P~"'er operat_ron the A.C. power shall be remove_d from the following motor operated valves with the valve in. the open. position: Unit No * . MOV 1890C Un It No. 2 MOV 2890C

10.

During power operation the A.C. power shall b:e removed from' the following.motor operated valves with the vahe in the closed position: Unit No. MOV 1869A MOV 1869B MOV i89QA HOV 189GB Unit No. *2 MOV* 286.9A MOV 2869B MOV 2890A HOV 28908

11.

,The accumulator discharge valves 1 Jsted below in non-Isolated loops . I shall ~e blocked open by de-enirgizing the valve moto~ operator when the reactor coolant system pressure is greater than 1000 psig. Unit No. 1 HOV 1865A HOV 18658 MOV 1865C Unit No *. 2

• MOV 2865A
• HOV 2865B HOV 2865C

12.

Power operation with less than three loops In service Is prohibited.

13.

The following loop isolation valves shall ~ave AC power removed and be locked in open position during power operation.

• "cJn it No. 1 Unit No. 2 MOV 1590 HOV 2590 HOV 1591

, HOV 2591 MOV 1592 HOV 2592 MOV 1593 HOV 2593 MOV 1594 HOV 2594 HOV 1595 HOV 2595 The total system uncollected 16 akage from valves, fla.'1ges, and pumps located outside containi'":lemt sr..all not e:cceed the li:m.i t shmm in T. S. T bl 4 11 1 . '-"..:lb ~ 0 tion M11r*i..,O' ~~r~tom tp5f:1. 0 T10' a e as ver:t..1.J.elt .V l!J,_-r.>.~C,_

• • *. **"u 0 -.;,.,*_.:...

.,~ --:,4 Individual component leakage may exceed the design value given in T.S. Table 4. 11. 1 provided that the total allo~1able system uncollected leakage is not exceeded. p18 41

3.4 SPRAY ~YSTEMS Applicability 9.rs 3.4-1 -a-1a-12 Applies to the operational status of the Spray Systems. Objective To define those conditions of the Spray Systems necessary to assure safe unit operation. i"!.~: C.: ~ -: :*.. Specification A. A unit's Reactor Coolant System temperature or pressure shall not be made to exceed 350°F or 450 psig, respectively, or the reactor shall not be made critical unless the following Spray System conditions in that unit are met:. I

1.

Two Containment Spray Subsystems, 1ncluding containment spray pumps and motor drives, piping, and valves shall be operable.

2.

Four Recirculation Spray Subsystems, including recirculation spray pumps, coolers, piping, and vglves shall be operable.

3.

The refueling water storage tank shall contain not less than 350,000 gal and not greater than 388,000 gal cf borated water at a ma::dmum temperature as shown in T.S. Figure 3.8-1. p19 I I.* I I

4.

6.

-'S: 3.4-2 3-17-72 If thi~ volume of water cannot be mainta.ined by makeup, or the temperature maintained below that specified in TS Fig. 3.8-1, the reactor shall be shutdOTNll until repairs can be made. The water shall be borated to a boron concentration not less than 2.000 ppm and not. greater than 2,500 ppm which will assure tha.t the reactor is in the refueling shutdown condition when all control rod assemblies are inserted. The refueling water chemical addition* tank shall". contain not less than 4,1.30 gal of solution and not great*er. than 4,.340 gal with a sodium hydroxide concentration of not less thanl8 percent by weight and not greater than 26 percent by weight. All valves., piping, and interlocks associated with the above components uhich are required to operate under accident conditions shall be operable. The ~otal unc?llectad system. leakage r.rom ya?-ves, fl~ges, and pu.'nps locate*µ outside containment-shall not. exceed tne li::n:i.t shown in T.S. Table 4.5.1 asl

• verified by inspec~ion during_ syst~m testing *. Indivinual c?,mponent leakage1.*:t may exceed the design value given 1.n T.S. Table 4.11.l provided that the total allowed syste::n uncollected leakage is not exceeded.

B. During power operation the requirements of specification 3.4-A may be modified to allow th.e following components to be inoperable. If the com-ponents are not restored to meet the requirement of Specification 3.4-A within the time period specified below, the ~eactor shall be placed in the hot shutdown condition. If the requirements. of Specification 3.4-A are not satisfied within an additional 48 hours the reactor sha*ll be placed in the cold shutdown condition using normal operating procedures.

1.

One Containment Spray Subsystem may be out of service, provided immediate attention is directed to making repairs and the subsystem can be restored to operable status within 24 hours. The other Con-tainment Spray Subsystem shall be tested as specified in Specificatipn 4.5-A to demonstrate operability prior to initiating _repair of the inoperable system. p20 ' r t

B. e TS 4.5-2 3-17-72

4.

The weight loaded check valves within the containment in the various subsystems shall be tested by pressurizing the pump dis- !,:harge lines with air at least once each refueling period. Verifi-I cation*of* seatin~ the check valves shall be accomplished by ap.p.lying_ a: vacuum upstream of. the* val.vee. 5., A'll motor op-erated valves in,the containment spray and recircula-t:::t'otr spray* flow* path shall. be.- t.ested' by stroking them at least once per month. 6.. T.he. contaimnent:. spray nozzles and.. contaimnent. recirculation spray no:zz!es shall be checked for proper functioning at least every five years.. r... The spray nozzles in the refueling water storage shall be checked for proper functioning at least monthly.

8.

The pressure containing components outside containment shall be* inspected for leaks from pump see.ls, valve packing and flanged joints during system testing.

• Aeceptable Criteria

1.

A dry-test of a recirculation spray pump shall be considered satis-factory tf the motor and pump shaft rotates, starts on signal, and the ammeter readi,ngs for the motor are comparable to the original dry test ammeter readings.

2.

A flow-test of a containment spray pump or an outside recirculation spray pump shall be considered satisfactory if the pump starts, and the discharge pressure and flow rate detennine a point on the head curve. A check will be: uia<le Lo determine that no particulate p21

e TS'

4. 5-3 3-17-72 material from the*refueling*water storage tank clogs the test spray nozzles located in the refueling water storage tank.

3.

The test of each of th~ w~ight loaded check valves shall be considered sat~sfac~ory if air_flows through the check valve, and if sealing is achieved.

4.

A-test of a motor operated valve shall be considered satis-factory if its limit switch operates a light on the main control board demonst~a.~~ng that the valve has stroked,

5.

The test of the containment spray nozzles shall be considered satisfactory~~ the measured air flow through the nozzles indicates that the nozzles are not plugged.

6.

The test of the spray nozzles in the !'efueling water storage tank shall be considered satisfactory if the monitored flow rate.to the nozzles, when compared to the previously established flow rate obtained with the new nozzles, indicates no appreciable reduction in flow rate,

7.

The inspection for system leakage shall be considered satisfactorJ if~ ~ the total system uncollected leakage is less than the allowablo given on T*.s. Table 4.5.1. The flow testing of each containment spray pump is performed by opening the nonnally ~losed valve in the containment spray pump recirculation line re-turning water to the refueling water storage tank. The containment spray p22

\\ I I 'I I; I, I, I, No. TECIIl{ICAL SPECIFICATIONS TABLE 4.5.1 RECIRCULATION SUBSYSTEM LEAKAGE* Design Leakage to Uncollected Vent and of Type of Leakage Control and Unit

Leakage, Drain System, Item Units Leakage Rate cc per htlf*

cc per hr Recirculation 2 No leakage of spray water due to tandem o* 0 spray pumps seal arrangement Flanges: 40 drops per min per f'lange

a.

Pump 4 480 o-b~ Valves - 4 460 0 bonnet to body (larger than 2 in.) Valves - Stem 4 Back.seated, double packing with leakoff 0 16 le~offs 4 cc per hr per in. stem diameter Mis ce lla.11eous 2 Flanged body, packed stem - 4 drop per min 24 0 small valves Total 964 16

• Based on two subsystems in operation under DBA conditions.

Total Allowed System Uncollected Leakage is 964.cc/hr

• • Individual component uncollected leakage may exceed the design value provided that the total
• a11owable system uncollected leakage is not exceeded.

p23 p24 ) ) ) e

o--:::;o;-,?",:~..-*-****-***'"******* -**** Valves TS 4.11-3 J-17-72

1. The.refueling water storage tank outlet valves shall be tested in p*erforming the pump tests.

• 2., The* accumulator check valves shall be checked. for operability during each refueling shutdown.

j.. All valves required to operate on a safety injection signal shall 'be: tested for operability each refueling shutdown. Pressure Boundary i.- The p*ressure-containing components are inspected for leakage from pump seals, fi!I.Ilged joints, and valve packing during system testing.,t

• 2r The acceptable total system uncollected leakage is as sho'W?l on T.,S., Table 4.11.1.

Coniple:t:e s*yste:m tests cannot be performed when the reactor is operating be-. cause a safety injection signal causes containment isolation. The method of assuring operability of these systems is therefore to combine systems tests to be performed during refueling shutdowns, with more frequent component tests, which can be performed during reactor operation. / The systems tests demonstrate proper automatic operation of the Safety Injection Sys~em. With the pumps blocked from starting, a test signal is applied to initiate automatic action and verification is made that the components receive the safety injection signal in the proper sequence. The test demonstrates the operation of the valves, pump circuit breakers, and automatic circuitry. During reactor operatton, the instrumentation which is depended on to initiate safety injection is checked periodically and the icitiating circuits are te$ted in accordance with Specification 4.1. In addition, the active components (pump p25

Items Low Head Safety Injection Pumps Safety Injection Charging Flanges:

a.

PlDnp

b. Valves Bonnet to Body (larger than 2 inches)

-- -*- __._.. *-*-~-- -.

• -. 'T*-. -

... "7'. - TECHNICAL SPECIFICATIONS TABLE 4.11.1 Page 1 o:f 2 EXTERNAL RECIRCULATION LOOP LEAKAGE (Safety Injection System only) No. of Units 10 54 2 3 / ;' Type of Leakage Control and Unit Leakage Rate Mechanical Seal with leakoff ~ 4 drop per min Mechanical Seal with leakoff ~ 4 drop per min Gasket - adjusted to zer~ leakage following any test - 40 drops* per min, per flange p26. Design Leakage to Design Leakage to Atmosphere Waste Disposal cc per hrirn Tank I cc per hr 0 0 1,200 2,240. 36 0 0

Items Valves - Stem Leakoffs Misc. Valves No.,of Units 27 33 TECHNICAL SPECIFICATIONS Table 4.* :ll.1 (Cont 1cl) 1Leakage Rate Ba.ckseat~d,,C',1Qt,1J;,J..e ~,;1.c.k;l.I.l$ with leakoff - 4 cc per hr per in. stem diameter j* 1,:,,I,.t.,.,** Flanged body packed stems '1,,.

• '1

,. j 11 4 drop per min TOTALS Total Allowed System Uncollected Leakage is.3,8.36 cc/hr l'ngo 2 of 2 rDesign j(.. eakage,to ,Atmospoe,re Design Leakage to Waste Disposal ,c.c.per h.r ** Tank, cc per hr ,0 108 n .396 0 168

• • Individual component uncollected leakage may exceed the design value provided that the total allowable system uncollected leakage is not exceeded.

p27 . '.:~ *~~....

• • '" ***-;q-..,_.,..__, ___.

... -~- ****-**'":"' ****1*"~.--,.**.....,....,,_..,.... . *t-

~~-..;... *. s:. ,..* *.~,---..i."""":;,,...,. __ -.,. __________ ~--,=c-~.._ ~ *--***~.... ~-*"-*-*--.-~,*...,,f~--.,.**.,..,._,,, ___......, _____ ~>-u:.-.... e SECTION 2 This s~ction contains the responses to Questions 14, 16, 17, and 18. \\ I I I p28

e Your res?onsa to Question 6 did not provid~ a list of nonconformances of the filter trains used on the exhaust system for the engineered safety features araa to the positions of Regulatory Guide 1.52 (R~v. 1). Provide this list and a flow dia3ram of the filter train systam including all dampers and any interfaces to normal o~erating ventilation systems. The systems should be capable of withstanding single failures. Propose technical specifications which are in agreement with the testing requirements of Regulatory Guida 1.52 (Rev. 1) and the assumed adsorption and filtration efficiencies of the filter train in the LOCA dose analysis. The model Technical Spcc*ifications enclosed in our December 12, 1974 letter represent an accaptable means of meeting our requirements. RESPOHSE Attachaent 14-A provid~s the list of major nonconformances of the auxiliary building filters to the positions of Ragulatory Guide 1.52 Revision 1. The safeguards area ventilation systam including the auxiliary building filt~r trains with interfaces to normal oparating ventilation systems are shown on Figure 14-1. Att~chhlent 14-B is the technical spacification for the auxiliary building filters revised in accordance with the intent of the Hodel Technical Specification enclosed in your D~cer:ibGr 12, 1974 letter and is in agreement with the intent of the testing requirements of Regulatory Guide 1.52 Revision l. p29

~ 2 3 4 s 6 7 tO PARTICULATE l GU MONI TONS 1/R!AOOUIS IN CONTROL ROOM (TYP Of l) FROA run BUllOING FRO~ DICONTA*r NAT I ON J* BUllDING f hllll V[hlllAI 1011 i SUPPLY UNIT 1-VHIV-4 L;.- -*~ ~ I J I *- SlFIGUIIIUS z- ~ (;; ,... ~A.. C Bil I lO ING I :r.-n. VJ ..... - :a 2! Uhll 2 . ~E~ ~~~ J ~A. I.. I""'" . -~ s~~. ~::~ 1-~!::-n1*-... ~--r r-... r ~~-- SMIGUAIIOS BUllDING ~~a.. ~ a.. UNll I I~=~ "":1 ,~~ vi,:.1 a,~~ ~Ct-Z~ 00.... I~ .;,o1,,. ~-- ll 0...*1-"'-

a

--g,_ uu..v, _._a. ~-CL z-0~

Z:f-"'-

~~>> "~~ ~~; fl~~ Ii~~ Ji~~ ~~ ;~i _.,.... _ --11',-- -*tr-t...- 1 ~ ? "t t 8 t ROM I t t t t t i[NIILATION SUl'Pl ! Ut,11 ____.._ __ __,_+-----t---"---- H-, c; 10 1-,S-~V-4. L-.----------~--

---

~

fRP" r!Nlkll ARI I

• AUllllAR! O~ILOING rHO~ CDNIAl~MENl UNI! 2 fRO~ tONIAINMENT LNIT I f ROM r.fNl HAL ARI A -

A'lllLIAltl H*JllOlhG I I LIGIHO fO fO Fcl t.* I \\ \\*"*'..... --ll'-----ff-----11'-----,lf--~-+-----ff---.---fl'-<Htl fC FROM CONTROL SIIICH ON J----------Nrr-lJJ VENI.PANH IN CONTROL ROOM l!SHftiJ D N f{f) N H r'JD----~---------------u-- NO TO UNAUST FAN SYSFEM tO EIHIUSl "IAN SISH* IRON CONTROL rnTCH ON J----------*-fr.J V[NI.P!N[l IN CONIROL ROOM A/Sf-#- ' TO VENTILATION Y[Nf fH uN:~nn 11lc~1 0~ I ~r~~'. mi ~SI ~'8J---* -----~1-f SJ jl;1 CONIROL ROOM A/S f-H.* Jilj_ r,';0---H/}---,;.i._ H------N---*--11 2 -- P'-<Jl~rn 1_.f._* ____ ic-i@ D TI" NE _ . ~E UNI I ii, (RAIN 'D' CLS di-HI UNIT 11,TRAI~ 'A' CLS HI-HI f*-----f.J] 1-;f fS,}-1;--* "'/ SIGllAL OR CONIROL SIIICH.. SIGNAL OR COll!ROL Sll!CH ON VENT.PANEL IN CONIROL RDOII c * -/t*-UJ*nfA/S ON VIN!.PINH IN C0111110l ROOM FO 4 " 'lillH~~;;l:J;.t-'-f0'------1 UNll 12,!RIIN 'A' ClS Ill-HI AUi. BLOG, flLHR !RAINS UNIT 12,IRAIN '8' CLS HI-HI SIGNAL OR CONIROL SIIICH OH/*--***,fjl fi]* --------j SIGNAL OR CONIROl SIIICH OH VIiii,11111 Ill r:ri*,11*111 llfi<IU A*! i 1* !.I.I Li.) 1~ ~. VINI PAHII I~ rr1111~QI ffOOII NI HI ro £ I-VS-fl-JO ro re @1----------**---------------..- r,:11:..--11------'9-* -H-----l'f----H--- ---N-1* --~-H(ld fO urn,1 ClS hi-HI SIGNAL(!RAINS UBlf-------*-*iiJNE FO tom~~O~o~:ITCH ON Vm.PAIIIL IN l/Sf-#UJ N H II fROII tONlROL SWITCH ON f---*-** ****,SJm Vl~l.PAN~~ IN CONIROL ROOM A~S H-t!.?:*J IC SIHGUAROS ARIA EIIIAUST FANS I-VS-f-4011 IA H-(1~

---

f

• ._RO_N_C_O_II-IR-Ol_S_fl_T_CH-ON--f----------.-.---. ---j-S-J-NO __ _.__ ----;;o. :~N i:;:m YEHi.PANEL IN CONTROL ROOM A/S Hf-1£J h re ro 11----if---*--H----lf---=-t-ll (JJt

---

f

'"oM-CO-N-IR_O_L _S_I_I :-rn-011--,----.--------. ---------r-~-N-0 __ _.__ ---- :~lmm YENI.PANIL IN CONIRUL ROOM A/S f-lr-~ J*'j

---....----H-----H------t{/-------1;-----11-------- **-*ti*** (l't fC --; 1------------------------------.._ ___ .. :~NE~;~m N Lt ro II ~ If n ro fl 01 nlAf.R.UI el I 10 PARIICULAIE & GA; MUNI TORS I 'll!AOU~I S ANO 1.LAr,.11S l~ CO'alHOl ROOM I (:) ISOKINEIIC SAVfllHG NOUL( RAOIAIIOH SUPLING LINES HOl[S: I, FOR NOTES AUD AOOIIIONAL l(GE~O. SU 11449-fKS-e sui,11 ru,[R SUIION - UNIIS I l 2 Slll1.t1:1111s AUfl V[NIILIIIOH --+-+- 12 E;j A B C D E F G I H J K 5 T u V p30 Figure 14-1

e ATTAClE IEIIT 14-A AUXILIARY BUILD!lrG FILTERS LIST OF NONCm,rFor.:L\\:*ICES TO THE POSITimrn OF REGULATORY GUIDE 1. 52, REVISIO:-r 1

1.

C.2.a The filter trains do not include (a) demisters, (b) HEPA filters after adsorber banks, and (c) heaters. Fans,provide partial re_dundant exhaust capacity for safaguards area.

2.

C.2.b The filter trains are not protected from missiles generated by natural phenomt?non (tornado)

• 3~

C.2.f Each filter train is 36,000 scf1:1. However, the filter banks* are 3 HEPA filters high.

4.

C.2.g The filter trains are not instrumented to signal, alarm and

• record in the control room.

5.

C.2.h Actuation signal to divart the Safeguards Area e."<haust influent throu3h the nornally isolatzd charcoal filtar banks is in accordance with the requirements of IEEE-279. Dampers, damper actuators, and power supplies are not redundant. However, separation of redundant channel signals are maintained through isolation relays.

6.

C.2.i The filter trains are not (and need not be) designed for re~lace-ment as an intact unit nor in a minimum number of segmented sections without removal of individual components.

7.

C.2.k Filtnr ductwork was designed to exhibit on test a leakage rate of approximately one percent of system flow.

s.

C.3.c Pr.efilters neither meet the UL Class 1 requirements nor have a minimum efficiency of 40 percent dust spot.

9.

C.3.i Iopregnated activated carbon* used in the adsorber cells were hot tested to d,atermina thair compliance with the qualifications and batch test results of Table 2 of Regulatory Guide 1.52, Ravision 1. lQ. C.3.j Adsorber tray detail design, dimension, tolerances are not strictly in accordance ~vith AACC CS-ST, Tentative Standard for High Efficiency Gas-Phase Adsorber Cells.

11.

C.3.k The adsorber section design does not include an active cooling mechanism to remove radioactive decay heat.

12. C.3.o Filter Train housings do not and nP-ed not have mechanisms which could be used to provide uniform air flow distribution through cleanup components.

13. c.4.c No space is provided bet.;,een upstream HEPA filter and adsorber mounting frames for personnel access.

p.31

_-_i

14. C.5.a The station technical specifications pres~ntly require in-place testing of filter housing once per operating cycle, 12-18 months.

15. C.5.c The station technical specifications presently require in-place DO:i:' tests on HEPA filter banks to have 99.5 percent efficiency.

16. C.5.d The station technical sp,ecifications presently require in-place halogen tests on adsorber banks to have 99.0 percent efficiency.

17. C.6.a.3 The station technical specifications presently require laboratory testing of samples of used activated carbon to.. have elemental iodine

• removal efficiency of 99.0 percent.

p32 l i I ! I I I [ I ' f ! [ i r - r f* i~ f t ; I f I l 1 J I I

e TS 3.21-1 ATTACHMENT 14-B PROPOSED CHA!1GES TO TECHNICAL SPECIFICATIONS

3. 21 VEUTILA.TION FILTER TESTS Applicability Applies to safety-related filtration systems' abilities to remove particulate matter and gaseous iodine.

Objective To specify requirements to ensure the proper function of the safety-related filtration system. Specification A. Safeguards Area Ventilation and Au.~iliary Building Filter Trains l.a. In-place cold DOP tests at design flows on HEPA filters shall show~ 99 percent DOP removal.

b.

In-place halogenated hydrocarbon leakage tests at design flows on. charcoal adsorber banks shall show -?- 99 percent halogenated hydrocarbon removal.

c. Laboratory analysis on charcoal samples shall show~ 95 percent radioactive methyl iodide removal at a velocity within 20 percent of actual system design, 0.5 to 1.5 mg/m3 inlet methyl iodide concentration, ~ 70 percent R.H. and:;::..190 F.

d.

The maximum exhaust flow rate from the safeguards ar~a through the filter train shall not e..~ceed 36,000 cfm, the design flow rate capacity of the filter bank.

e. The maximum axhaust flow rate of Section 3.21.A.l.d shall not

.produce face velocities in excess of the design values of 1,200 cfm and 600 cfm through HEPA filter cells and charcoal' adsorbers, respectively.

f.

The minimum exhaust flow rate from the safeguards area shall not be less than 6,000 cfm.

2.

From and after the date that one circuit of the filter system is made or found to be inoperable for any reason, fuel handling is permissible only during the succeeding saven days unless such circuit is sooner made operable, provided that during such seven days all active components of the oth~r filter circuit sh~l be operable.

3. If these conditiona cannot be met, fuel handling operations shall be terminated.

p33

e TS 3.21-2 Bltsis A. Safeguards Ar~a Ventilation and Au.~iliary Building Filter Trains The purpose of the filter trains located in the auxiliary building is to provide standby capability for removal of particulate and iodine contaminants from any of the ventilation systems in the auxiliary building, fual building, decontamination building, safeguards area adjacent to the containments, and the reactor c-on:tainments (during shutdown) which discha.:-ge through the

• ven~ilation vent and could require filtering prior to release *

. During normal plant operation, the exhaust. from any one of the above systems can be diverted, if raquired, through the auxiliary building filter trains remotely from the control room. The safeguards area exhaust is automatically diverted through the filter trains in ehe event of a lOCA (diverted on higq-high containment pressure). 'the-fuel building exhaust air is aligned to continuously pass through the filters during spent fuel handling in the spent fuel pool. lligh 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 release of radioiodine to the environment. The in-place test results should indicate a system leaktightness 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 safeguards equipment limits the relative humidity of the exhaust air to less than 70 percent even when outdoor air is assumed to be 100 percent R.H. and all ECCS leakage evaporates into the exhaust air strear.i. The labot*atory carbon sample tests are required to indicate a radioactive methyl iodide removal efficiency of at least 95 percent at a relative humidity~ 70 percent. Because the filter trains located in the auxiliary building are used during various modes of plant operation, their capacity is not detennined by, and is far in excess of, the flow rate exhausted from the safeguards area during a LOCA. If the efficiencies of the HEPA filters and charcoal adsorbers are as specified, at flow rates, velocities and relative humidities ~hich are less than the design values of the filter banks, the resulting doses will be less than 10CFRlOO guidelines for the accidents analyzed. The offsite dose calculations for LOCA and fuel handling accidents, assume only 90 percent iodine removal efficiency for the air passing through the charcoal filters. Therefore, the demonstration of 99 percent efficiency will assure the required capability of the filters is met or exceeded. If the exhaust flow rate from the safeguards area~ 6,000 cfm, then adequate air flow is available for cooling the equipment in the safeguards area. p34 /

~-. 4.12 e -* TS 4.12-1 VENTILATION FILTER TESTS Application Applies to the testing of safety-related air filtration systems. Objective To verify that leakage efficiency and iodine removal efficiency are within acceptable limits. Specifica'tion I. Tests and Freausncies A. Safeguards Area Ventilation and Auxiliary Building Filter Trains l.a.(1) In-place cold DOP tests for HEPA filter banks shall be performed (1) initially (2) at least once per operating cycle (3) following significant painting, fire, or chemical release in any ventilation zone conununicating with the system (4) after each complete or partial replacement of the HEPA filter cells and (5) after any structural maintenance on the filter housing. l.a.(2) The procedure for in-place cold DOP tests shall be in accordance with lu'1SI li5l0-1975 Section 10.5 or 11.4. The flow rate during this tast shall be at the value established below in Section 4.12.I.A.l.d. l.b.* (1) In-place halogenated hydrocarbon leakage tests for the charcoal adsorber bank shall be performed (1) initially (2) at least once per operating cycle (3) following significant painting, fire, or chemical release in any ventilation zone communicating w"lth the system (4) after each complete or partial replace-ment of charcoal adsorber trays and (5) after any structural maintenance on the filter housing. l.b. (2) The procedure for in--place halogenated hydrocarbon leakage tests shall be in accordance with AllSI NSl0-1975 Section 12.5. TI1e flow rate during this test shall be at the value established below in Section 4.12.I.A.l.d. l.c. (1) Laboratory.analysis on charcoal samples shall be performed (1) initially whenever a new batch of charcoal is used to fill adsorber trays (2) at least once per operating cycl3 and (3) following significant painting, firs, or chemical release in any ventilation zone communicating with the system. p35

e TS 4.12-2 l.c.(2) The procedure for iodine removal efficiency tests shall follow RDT Standard M-16-lT. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptyins of one bed from the tray, mi.~ing the adsorbent thoroughly and obtaining at lea.st two samples. Each sample should be at least 2 in. in diameter and a length equal to the thickness of the bed. l.d. (1) Ma.. "Cimum air flow rate from the safeguards area exhaust through tho filter trains shall be determined (1) initially and (2) after any major modification or repair of the air cleaning system. l.d.(2) The method for determining the maximum airflow rate of Section 4.12.I.A.l.d.(l) shall be in accordance with Section 9 of the ACGIH Industrial Ventilation document. Iha filter calls during this test shall be. clean. A record of the corabined pressure drop across the HEPA filter and adsorber banks during this test shall be made. l.e.(1) Air distribution test across HEPA filter bank shall be tested (1) initially and (2) after any major modification or repair of the air cleaning system. 1.e.(2) The air distribution test of Section 4.12.I.A.l.e(l) shall be performed at the flow rate established in Section 4.l2.I.A.l.d(2) with an anemometer located at the upstream side and at the center of each HEPA filter cell. l.f.(l) Hin:imum air flow rate from the safeguards area through the filter bank shall be determined at the same frequency specified in Section 4.12.I.A.1.d(l.). l.f. (2) The method for detemining the air flew rate of . Section 4.12.I.A.l.f.(1) shall be in accordance with Section 9 of the ACGIH Industrial Ventilation document. The pressure drop across the HEPA filter and adsorber section shall be 50 percent in excess of that recorded 1n Specification 4.12.I.A.1.d.(2). This artificial pressure drop may be produced by blanking off the faces of some of the HEPA filters. 2.a. The pressure drop across the combined UEP.A filter and adsorber banks shall be checked (1) initially, (2) at least once per op.era ting cycle thereafter for systems maintained in a standbv status or after 720 hr of - system operation and (3) after each complete or partial replacement of filtars er adsorbers. p36

F' I I ~- -TS 4.12-3 2*.b. Each radundant filter train circuit shall be operated eveey month if it has not alraady been in operation. 2.c. At least once per operation cycle, automatic alignment for directing air flow through each filter train upon actuation of the manual switch in the control room

• shall be demonstrated.

2.d. When one circuit of the filter trains system becomes inoperable, the operability of the other train shall be demonstrated immediately and daily thereafter by tests of Sections 4.12.I.A.2.a and 4.12.I.A.2.c. II. Acceotance Criteria A. Safeguards Area Ventilation.and Auxiliary Building Filter Trains 1.a. The results of in-place DOP test describ~d in Section 4.12.I.A.l.a shall be within the limits of Specification 3.21.A.l.a. Leakage sources shall be identified, repaired, and retested. Any HEPA filters found defective shall be replaced with filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52. I l.b. The results of in-place halogenated hydrocarbon leak test. described in Section 4.12.I.A.l.b shall be within the limits of Specification 3.21.A.l.b. Leakage sources shall be identified., repaired, and retested. l.c. The results of laporatory analysis of charcoal samples described in Section 4.12.I.A.l.c shall be within the limits of Specification 3.21.A.l.c. If test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified according to Table 1 of Regulatory Guide 1.52. The replacament tray for the adsorber tray removed for the test should meet the same adsorbent quality. l.d. The maximum air flow rate determined in Section 4.12.I.A.l.d shall be less than the limits specified in Section 3.21.A.l.d. The ventilation system shall be adJus.tad by addition of flow resistance until the specified limit is met. 1.e. The results of* air distribution tests described in Section 4.12.I.A.1.e shall be within the specified limits of Section 3.21.A.l.e. The ventilation system shall be adjusted by addition of flow resistance until the specified limits are met. 1.f. The minimum air flo"t-1 rate detennined as described in Section 4.12.I.A.l.f shall exceed the specified limit of Section 3.21.A.l.f. If test results are unacceptable, refer to Specification 3.21.A.2 and 3.21.A.3. 2.a. Pr.assur~ drop across tha combined HEPA filters and charcoru. adsorber banks shall be l:::ss th.in 5 i:i.. cf w:it~?: at the filter bank design flow rate. If thi.s condition cannot be met, new filter cells shall be installed. p3'7

e e TS 4.12-4 2.b. The minimum period of air flow through filters is 10 hr per month. 2.c. The automatic initiation test of Section 4.12.I.A.2.c shall demonstrate proper closure of filter bypas,s damper and opening of filter irilet and outlet dampers. III. Basis A. Safeguards Area Ventilation and Auxiliar, Building Filter Trains Ventilation system filter components are not subject to rapid deterioration, having lifetimes of many years, even under continuo~s flow conditions. The tests outlined above provide assurance of filter reliability and will ensure timely detection of conditions which could cause filter degradation. Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 5 in. of water at the system design flow Tate uill indicate that.the filters and adsorbers are not clogged by excessive amounts of foreign matter~ Operation of the filtration system for a minimum of 10 hr a month prevents moistu{e buildup in the filters and adsorbers. The frequency of tests and sample analysis of the deBradable components of the system, i.e., the HEPA filter and charcoal adsorbers, is based on actual hours of operation to ensure thnt 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 distribution. If significant painting,* firec, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the ~umes, chamicals ~r foreign material, the same casts and sample analysis are performed as required for operaticnal use. The detennination of "significant" is mada by the operato.r on duty at the time of the,incident. Knowledgeable S'taff members would be consulted prior to making this determination. DemonstTation of the automatic initiation capacity is "ecessary to assure system performance capability. If one system is inoperable, the other system is tested daily. This substantiates the availability of the operable system and thus refueling operation can continue for a limited period of time. pJ8 (

e Question 16 Your response to Question 6 did not include a calculation of the doses to control room personnel. Calculate the 1ose to control room personnel due to ECCS leakage for 30 days after the LOCA.

• Refer to Standard Review Plans 6~4, "Habitability Systems,"

and 15.6.5, Appendix B, "Radiological Consequences of a Design Basis Loss-of-Coolant Accident:. Leakage from Engineered Safety Features Components Outside Containment," for guidance in your analysis. See also the Proceedings of the 13th AEC Air Cleaning Conference, August 1974, for the paper, "Nuclear Power Plant Control Room Ventila-tion Sys ten Design for Meeting General Design Criterion 19," by K. G. Murphy and K. M. Campe. Your response should include the following information:

1.

Elemental, organic, and particulate iodine removal efficiencies assumed for filters in *the Control Room Ventilation System and in the Auxiliary Building Filter Banks.

2.

Rate of unfiltered inleakage to the control room while it is pressurized with bottled air and after bottled air is exhausted and filtered air intake has begun. 3o Time to isolate and time to pressurize the control room after the LOCA occurs. 4a Location of control rqom ventilation system intake vent relative to the exhaust vent from the Auxiliary Building standby ventilation system.

5.

The 5-, 10-, 20-, and 40-percentile windspeeds (see Murphy & Campe, pp. 411-414) and the wind direction frequencies and building wake factors used in determining the control room intake vent X/Q.

6.

The X/Q values used for the control room intake vent and a discussion of the assi.Imptions made and the source used to obtain these X/Q values.

7.

The volume of the control room and other rooms served by the control room ventilation system.

8.

Intake air flow during normal operation and recirculation modes of the control room ventilation system.

RESPONSE

The control room dose calculations provided in Section 3.2 are based on the following assumptions and information:

1.

Elemental, organic and particulate iodine filter efficiencies for the control room ventilation system and auxiliary building filter banks are assumed to be 90 percent.

2.

The rate of unfiltered leakage into the control room while it is pressurized with bottled air and after bottled air is depleted and filtered air intake has begun is zero. However, in accordance with Standard Review Plan 6. 4 the control room dose calculations asswne a 10 cfm unfiltered inleakage for the duration of the accident. p'fl

e

3.

Thirty seconds are required to isolate the control room following a LOCA. An additional 20 seconds are required to raise the control room ~ressure from zero to design pressure. The dose calculations take credit for a pressurized control room from time equal to zero following the accident.

4.

The location of the auxiliary building ventilation filter vent and the control room intake vent are shown on Fig. 16-1. The ventilation filter vent will be relocated to the position shown on Fig. 16-1. The control room "intake" shown as a single opening at the center of, and through the ceiling of the control room represents a volume receptor for the control room into which infiltration occur at oany locations across its pressure envelope. The loca-tion of this receptor has been conservatively selected to account for the cable penetrations through the ceiling of the control room and for the doors located at the west and south walls of the pressure envelope at the control room floor level. Filtered makeup air is also assumed to be drawn through this "intake" even though the actual filtered air intakes~ as shown on Fig. 16-1 are further away from the ventilation vent and the containment structures.

5.

Accident X/Q values for the Surry l & 2 control room were detet'I:lined for diffuse and point sources in conjunction with the control room air intake as ciefined in item 4 above. Table 16-1 presents each case, type of source, the receptor location, and the distance of the source to the receptor. Table 16-2 presents the 5-, 10-, 20-, and 40-p~rcentile wind speeds and the wind direction frequencies used in determining the control room vent X/Q values for each case, based on on-site 35-ft wind data for the conbined periods of Harch 3, 1974 - Ha.rch 2, 1975

• and Hay 1, 1975 - April 30, 1976.

Calms are defined as wind speeds less than O. 75 mph and were distributed proportional to the frequency of occurrence of winds in the 0.75 eph to 3.5 mph class. Building wake factors, wind speeds and wind direction frequencies were all calculated in accordance with K. G. Murphy and K. M. Campe, "Nuclear Power Plant Control Room Ventilation System Design for Neeting General Design Criterion 19," 13th AEC Air Cleaning Conferance, August 1974.

6.

The estimated control room X/Q values for 0-8 hr, 8-24 hr, 1-4 days, and 4-30 days for the control room air intake are presented in Table 16-4 for each case. The equation used to calculate these values was taken from Hurphy and Campe (their Equation 6): X/Q = l u f 1;6; + a ] K+2 where X/Q relati3e concentration at the plume centerline (sec/m ) s, and ~ = horizontal a..,d vertical dispersion parameters (m) u = wind speed at 35 ft elevation (m/sec) p40

K = s = d = a = 3

t., ) 1.4

\\S/J e distance between containment surface and receptor location (m) diameter o~ containment (41.2 m) projected area of containment building (1416 m2) Only those wind directions and associated wind speeds which affected the receptor sector in question were used in computing the fifth percentile X/Q and the develop-ment of adjustment factors for long term X/Q values. Table 16-3 presents adjustment factors based on wind speed and wind direction which were used to reduce the fifth percentile X/Q to account for long term meteorological averaging. There was no adjustment factor applied to the long term X/Q values for operator occupancy in the control room. The fifth percentile X./Q value was computed for F stability conditions and the fifth percentile wind speed.

7.

The volmne of the control room and other rooms located within the pressure envelope which are served by the control room emergency ventilation system is 223,000 cu ft.

8.

The intake air flow rate into the control room during normal station operation is 2,500 cfII!. The intake air flow rate during the first hour following a LOCA when bottled air is used to maintain design pressure in the control room is zero. The intake air flow rate after the first hour following a LOCA is: 2,000 cfm if an emergency electric bus failure is assumed 3,000 cfm if an emergency filter-fan train failure is assUI:1ed 4,000 cfm if no single failure is assumed There is no recirculation mode of operation for the control room emergency ventilation filter system. p41

TABLE 16-1 CASES EXAMINED FOR CONTROL ROOM X/Q VALUES_ Distance Case Source Receptor Source to Receptor {m) 1 Diffuse Source Control Room Volume 38.3 Containment i. Receptor 2 Diffuse Source Control Room Vohlille 46.5 Containment 2 Receptor .'.l Point Source Control Room Volume 44.11 Safety Related Receptor Filter Vent p42

I.

• TABLE l6-2 WIND SPEEDS, WIND DIRECTION FREQUENCIES,. AND BUll.DING WAKE FACTORS USED IN ESTIMATING SHORT TERM AND LONG TERM CONTROL ROOM X/Q VALUES Building Wind Speeds (m/sec)

Wind Direction Frequencies Wake for Used for Time After Factor 5-10-20-40-Accident a Case Percentile 0-8 hr 8-24 hr 1-4 day 4-30 day ill 1 0.7 1.1 1.5 2.2 1 0.81 0.62 0.24 270 2 o.6 1.0 1.4 1.9 l 0.81 0.61 0.22 311 3 0.6 1.0 1.4 1.9 1 0.81 0.61 0.22 306 p4J

TABLE 16-3 ADJUSTMENT FACTORS USED TO CALCULATE EFFECTIVE XJ'Q V.Al.lJ,ES: Time Intervals Case 0-8 hrs 8-24 hrs 1-4 dais 4-30 days 1 1 0.54 0.30 0.08 2 1 0.51 0.27 0.01 3 1 0.51 0.27 0.01 p44

l j }, j l j l i l I l i l 1 l l I l Case 1 ').. 3 TABLE 16-4 CONTROL ROOM X/Q VALUES {sec/m3) FOR TIME AFTER THE ACCIDENT 0-8 hr 8-24 hrs 1-4 days 4-30 dax:s 5.2 X 10-3 2.8 X 10-J 1.6 X 10-3 4.2 X 10-'* 5.2 X 10-3

2. 7 X 10-J 1.4 X 10-3 3.6 X 10-4 5.3 X 10-3 2.7x-10 -3 1.4 X 10 -3 3.7 X 10-4 p45

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t* QUESTI0:1 i7-Describe past and present surveillance programs to determine control room integrity. Discuss the results or tests of control room infiltration or exfiltrat::lon rates, including. the results found before repairs to defective weatherstripping, gaskets, etc., were effected~ RESP.ONSE I The control room integrity surveillance program consists of an air leakage test conducted once every 12 to 18 months. The test is conducted. normally during the refueling period of Unit No. 1 when the reactor is in a cold shutdown condition. The test is conducted using one of the four 1,000 cfm capacity £~-filter trains rather than the bottled compressed air system. This is to prevent depletion of air from the bottles. Before starting the test, an orifice plate to reduce the capacity,of the emergency ventilation fan filter system to 300 cfm is installed in the supply duct of the fan. The 300 cfm corres-ponds to the discharge capacity of the bottled air system. Differential pressure indicators installed to measure the pressur.e difference across the*pressure envelope of the control room areas are calibrated. To start the leakage test, all doors located at the pressure envelope of the control room ate closed and all those interconnecting the vatious spaces within the pressure envelope are opened. Isolation dampers on the normal air-conditioning supply and exhaust air ducts are closed, and the normal exhaust .fan is stopped. The_lealcage test is started by operating one of the emergency ventilation fans and opening its isolation damper to allow the flow of air to pressurize the control room. The pressure in the control room is allowed to stabilize and verified to be equal to or in e.~cess of.as in. W.G. as read on the differential pressure indicators. This condition is maintained for one hour and differential pressure indicators are checked again. Failure to maintain the 0.05 in. W.G. design positive pressure is immediately reported to the shift supervisor and procedures for rem.dial action are initiated in accordance with Technical Specification 3.19. After the successful completion of the leakage test, the orifice plate is removed from the supply duct of the emergency ventilation fan filter system and all isolation dampers, doors, a_nd equipment are restored to their normal condition. No records have been kept of past tests and air leakage rates while repairs lv-ere being made to defects in control room pressure envelope integrity. p47 -.**-*i~--.:7.. **--**.**u****- l.,.. r-r

. ~. . r e QUESTION 18 Compare the design features and surv2illance testing requirements of the control room and the relay room emergency filter banks to the guidelines of.Regulatory Guid~ 1.52. n-:;cuss your conparison and indicate which guidelines of Regulatory Guide 1.52 these filt~rs or their surveillance requiraments do not I!leat *. Provide a flow diagram of these filter train systet!ls including all dampers and any interfaces with normal ope.rating ventilation systel!lS. These systems shoul!d be capable of wfthstanding a single failure. Pro'!)ose technical sp~cifications which are in agreement with the testing requirements of r.2gulatory Guide 1.52 (r..Gv. 1) and the assumed adsorption and filtration efficiencies of the filter train in tha LOCA dose analysis. RESPOHSE 8-A provides the list of major nonconfonnances of the control room emargency v~ntilation filters to the positions of Regulatory Guide 1.52 '\\ Revision 1. The control room ~~ergency ventilation system including its filter trains ~s shown on Figure 18-1.

• 8-B is the technical specification for the control and relay rooms emergency ventilation, revised in accordance with the intent of the Hodel Technical Specification enclosed i.~ your December 12, 1974, letter and is in agreement,i-ith the intent of* the testing requiran:!;nts of Regulatory Guida 1.52 Revis.ion 1.

p48

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ATTACHME~ 18-A CONTROL AfID RELAY ROOHS FILTERS e LIST OF NONCONFOR."1AUCES. TO THE POSITIONS OF REGULATORY ~UIDE 1.52, REVISION l

l.

C.2.a The filter trains do not include (1) d.e.misters, (2) HEPA filters after absorber banks, and (3) heaters.

2.

C.2.b The filter trains are not protected from missiles generated by natural phenomenon (tornado).

3.

C.2.g. The filter trains are not instrumented to signal, alarm and record 1n the control room.

4.

C.2.h Dampers, damper actuators, and power supplies required for control room isolation are not redundant. During testing of filters, the signal for isolating the control roor.i does not automatically close the discharge valve of th.e emergency ventilation filter system.

5.

C.2.k Filter ductwork was designed to exhibit on test a leakage rate of approximately one percent of system flow. 60 C.3.c Prefilters do not meet UL Class 1 requireir.ents nor have a minimum efficiency of 40 percent dust spot.

7.

C.3.1 Impregnat~d activated carbon used in the adsorber cells was not tested to det,ermine its compliance with the qualifications and batch test results of Table 2 of Regulatory Guide 1.52, Revision 1. Also, the absorbers provide 1/8 sec residence time.

8.

C.3.j Adsorber tray detail design, dimensiQns, and tolerances are not strictly in accordance with the CS-ST, Tentative Standard for High Efficiency Gas-Phase Adsorber Cells.

9.

C.3.k The adsorber section design neither includes nor requires an active cooling mechanism to remove radioact~ve decay heat.

10. c.4.c No space is provided beo1een upstream HEPA filter and adsorber -

mounting frames for access.

11. C.5.c The Station. technical specifications presently require in-place DOP tests on HEPA filter banks to have. 99.5 percent efficiency.

12.

C.5.d The station technical specifications presently require in-place halogen tests on adsorber banks to have 99.0 percent efficiency.

13. C.6.a.3 Plant technical specifications presently require laboratory testing of samples of used activated carbon to have elemental iodine removal efficiency of 99.0 percent.

p50

I I I e TS 3.21-1

• f ATTACHHENT 18-B PROPOS.ED TECHNICAL SPECIFICATION CHANGES 3.21 VENTILATION FILTER TESTS Applicability Applies to safety-related filtration systems' abilities to remove particulate matter and gaseous iodine.

Objective To specify requirements to ensure the proper function of the safety-related filtration system. Specification B~ Control and Relay Rooms.:M.r Treatment System Filter Trains

l. a.

In-place cold*DOP.tests at design flows on HEPA filters shall shou ~ 99 perc*ent DOP removal.

b.

In-place halogenated hydrocarbon leakage tests at design flows on charcoal adsorber banks shall show~ 99 percent halogenatE:d hydrocarbon removal.

c. Laboratory analysis on charcoal samples shall show 90 percent radioactive methyl iodide removal at a veljcity within 20 percent of actual system design, 0.05 to 0.15 mg/m inlet methyl iodide concentration,,~ 95 percent R.H. and~ 125 F.

d.

Fans shall be shown to operate within tlO percent design flow of 1,000 cfm.

2.

From and after the date that one circuit of the filter system is made or found to be inoperable for any reason, reactor operation or fuel handling is'permissible only during the suceeding seven days unless such circuit is sooner made operable.

3. If these conditions cannot be met, reactor shutdown shall be initiated and the reactor shall be in cold shutdo~-m within 24 hr and fuel handliilg operations shall be terminated immediately.

• Basis

. B. Control Room and Relay Room Air Treatmel"t System Filter Trains The control room and relay room air treatment system is designed to filter the intake air to the control room pressure envelope which consists of the control room, relay rooms and emergency switchgear rooms during a LOCA. The isolation and pressurization ~rlth bottled air of the areas within the pressure envelope are p51 i,, i i t t

TS 3.21-2 covered in Technical Specifiation 3.19. When the supply of compressed bottled air is depleted, the control room and relay room air treatment system is manually started to continue to maintain. the control room pressu;e at the design positive pressure so tha~ all leakage is outleakage. High efficiency particulate absolute (HEPA) filters are installed before the charcoal a.dsorbers 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 leaktightness 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 rem.oval efficiency of at least 90 percent for expected accident conditions. If the efficiencies of the HEPA filters and charcoal adsorbers are as specified, at flow rates 'and velocities within the design values of the filter banks, the 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 SO. The control room dose calculations assume only 90 percent iodine removal efficiency for the air passing through the charcoal fil,.ters. Therefore, the demonstration of 99 percent efficiency will assure the required capabilit;y of the filters is met or exceeded. If the system is found to be inoperable, there is no immediate threat to the control room and reactor operation or refueling opera*tion may continue for a limited period of time while repairs are being made. If the system cannot be repaired ltlthin the specified time, procedures are initiated to establish condition.s for which the filter system is not required. p52

• l i

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"I"*. e TS 4.12-1. 4.12 VENTILATION FILTER TESTS Application

• Applies to the testing of safety-related air filtration'systems.

Objective To verify that leakage efficiency and iodine removal efficiency are wi.thin acceptable limits. Speci~ication !~ Tests and FreauP..ncies B. Control Room and Relay Room Air Treatment Svstem l._a,(l) In-place cold DOP tests for HEPA filter banks shall be performed (1) initially (2) at least once per opel;'ating cycle (3) following significant painting, ttre, or chemical release in any ventilation zone communicating with the system (4) after each complete Qt' partial replacement of the HEPA filter cells and (~) after any structural maintenance on the filter

housing, l.a.(2)

The procedure for in-place cold DOP tests shall be in accordance with ANSI NSl0-1975 Section 10.5 or 11.4. The flow rate during this test shall be at the value established below in Section 4.12.I.B.l.d. l.b.(l) In-place halogenated hydrocarbon leakage tests for the charcoal adsorber bank shall be performed (1) initially (2) at least once per operating cycle (3) following significant painting, fire, or chemical release in any ventilation zone communicating \\ri.th the system (4) after each complete-or partial replace-ment of charcoal adsorber trays and (S) after any structural maintenance on the filter housing. l.b.(2) The procedura for in-place halogenated hydrocarbon leakage tests shall be in accordance with ~rnI N510-1975 Section 12.5. The flow rate during this test shall be at the value established below in Section 4.1'2.I.B.l.d.

l. c. (1)

Laboratory analysis en charcoal sa!!lples shall be performed (1)

• initially whenever a nei-1 batch of charcoal is used to fill adsorber trays (2) at le3st once per operating cycle and (3) following significant painting, firE:!, or chemical release in any ventilation zone communicating tri.th the system.

p53

or.,

e TS 4.12-2 l.-c-.-(2) The procedure for iodine removal efficiency tests shall follow RDT Standard M-16-lT. The charcoal adso~ber 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 2 in. in diameter and a length, equal to the thickness of the bed. i.. ct. (i)* Air flow rate test shall be determined (1) in*itially and (2) after any major modification or repair of the air cieaning system. I i.ci.(2)' The procedure for determining the air flow rate of Section 4.12.I.B.l.d.(l) shall be in accordance with Section 9 of the ACGlH Industrial Ventilation document. The filter cells during this test shall 'be clean. 2.a The pressure drop across the combined HEPA filter and. adsorber banks shall be checked (1) initially, (2)

• at ieast once per operating cycle therafter and (3) after each complete or partial replacement of iiiters or adsorbers.

2.b. Each redundant filter train shall be operated every month. II.

• Acceptance Criteria

n.

Controi Room and Relay Room Air Treatment System i.a. The results of in-place DOP test described in Section 4.12.I.B.l.a shall be within the limits of Specification 3.21.B.l.a. Leakage sources shall be identified, repaired, and retested.. HEPA filters found defective shall be replaced with-filters qualified pursuant to Regulatory Position C.3.d of Regulatory Guide 1.52. i.b The results of in-place halogenated hydrocarbon leak test described in Section 4.12.I.B.l.b shall be within the limits of Specification 3.21.B.l.b. Lel:!,kage sources shall be identified, repaired, and retested. l.c. The results of laboratory analysis of charcoal samples described in Section.~.12.I.B.l.c shall be within the limits of Specification 3.21.B.1.c. If test results are unacceptable, all adsorbent in the system shal! be replaced with an adsorbent qualified according to Table I of Regulatory Guide 1.52. The replacement tray for the adsorber tray removed for the test should meet the same adsorbent quality. p54

I l.I:I.. Basis e e TS 4.12-3 The air flow rate determined as described in Section 4.12.~.B.l.d shall be within the limits specified in Section 3.21.B.l.d. The ventilation system shall be adjusted until the specified limit is met. 2.a. Pressure drop across the combined HEPA filters and _charcoal adsorber banks shall be less than 5 in. of

• ~~_ter at the filter bank design flow rate. If this

~.ondidon cannot be met_, new filter cells shall be installed. 2;b~

Pie minimum period of air flow through filters is 10 hr per month.

~ B. Control Roomand.Relay Room Air Treatment System Vent~lation system filter components are not subject to rapid deterioration, haying lifetimes of many years. '-nle tests outl~ned above provide assurance of filter reliability and will ensure timely detection of conditions which could cause filter degradation. Pressure drop across the combined HEPA filters and charcoal . adsorbers of less than 5 in. of water at the system design flow rat~_will indicate that the filters and adsorbers are not clogged by excessive amount~ of foreign matter. Operation of the filtration system for a minimum of 10 hr a month prevents moisture buildup in the filters and adsorbers. The frequency of tests and sample analysis are necessary to show that the HEPA filters ~nd charcoal adsorbers, can perform as evaluateu. System flow rates do not change unless the ventilation syst~ is radically altered. Co,nsequently, less frequent testing has been specified for system flow rate. If significant painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated *from fumes, chemicals or foreign material, the same tests and sample analysis are performed as required for operational use. The determination of "significant" is made by the operator on duty at the time of the incident. Knowledgeable staff members would be consulted prior to making this determination. p55

i.

j I j

e Section 3 LOCA Dose Analvses 3.1 Site Boundary and LPZ Doses 3.2 Control Room Dose from ECCS Leakage 3.3 Proposed Technical Specification Changes This section gives the dose results in response to Questions 12; 13; and 16. p.56

3.1 Site Boundary and LPZ Doses Doses from a postulated LOCA have been calculated in accordance with the regulatory guidance contained in Regulatory Guide 1.4 and Standard Re-view Plan 15.6.5. Assumptions used in the containment leak to atmosphere portion of the accident are listed in Table 3-1, and those used in the ECCS leakage are listed in Table J-2. Most of the parameters listed in Tables 3-1 and 3-2 are in current use by the NRG staff. The power level is 102 percent of licensed power, and the containment leak rates are, respectively, the design leak rate during the period of pressurization and one-half the design leak rate after the con-tainment pressure has decayed to one-half the peak pressure. The assumed ECCS leakages are twice those to be incorporated into the station tech-nical specifications as proposed in Sectio~ 3.3. Table 3-3 presents the doses calculated at the exclusion boundary and low population zone outer boundary. 3.2 Control Room Dose from ECCS Leakage The dose to control room personnel from ECCS leakage is given in Tables 3-5 in accordance with the assumptions listed in Tables 3-2 and 3-4. The method of analysis is based on Standard Review Plans 6.4 and 15.6.5, Appendix B. After a LOCA, iodine activity released to the containment enters the water in the containment sumps. It is mixed and recirculated through the engineered safety features (ESF) areas during the ECCS re-circulation phase. Equipment in the ESF area is assumed to leak at twice the values to be incorporated into the station technical specifications as given in Section 3.3 below. A fraction of the iodine that leaks into the ESF area is released to the ESF area atmosphere. It is assumed that it is all collected by the ESF area ventilation system and processed through the auxiliary building filters prior to release through the venti-lation vent. The releases from the ventilation vent are combined with the atmospheric dispersion factors in Table 3-4 to determine airborne concen-trations o~tside the control room. The derivation of these factors is discussed in Section 2 (response to question 16) above. The control room is initially isolated and pressurized by the bottled air system within 60 sec from the LOCA. 'Thus, there is no normal intake during the period when the bottled air system is functional. After the bottled air supply is exhausted, control room pressurization is maintained by the introduction of outside air through the filtered control room air intakes. Air infiltration results in some unfiltered air inleakage as shown in Table 3-4. Doses are calculated on the basis of a 30-day air intake for the control room0 An adjustment factor is applied to account for long-term operator occupancy in the control room. p57

,i e 3.3 Proposed Technical Specification Changes The proposed technicaJ specification changes regarding ECCS leak.age outside containment a.re included with other proposed changes to the station technical specifications given in Sec.tion l above. The pages of the proposed tecbnicaJ. specification changes pertaining to ECCS leakage are: Page 3.3-3 Page 3.4-2 Page 4.5-2 Paga 4.5-3 Table 4.5.1 Page 4.ll-3 Table 4.ll.l p;8 ,,..... ~.. ~'!',..,.,..... ~ .. ~\\--::W*... '11-... --.. - .. _*~-------**-----~-

e TABLE 3-1 Assunrotions Used in the LOCA Dose Analysis Power Level Operating Time Fraction of Core Inventory Available for Leakage Iodines liobla Gases Initial Iodine Composition in Contaimnent Elemental Organic Particulate Containmant Leak Rate O..J.390 sec 390 sec-1 hr After l hr Containment Volume Sprayed Fraction Unsprayed Fraction Conta.i!l!llent Mixing Rate Between Sprayed and Unsprayed VolUI:1e Containment Spray System Maximum Elemental Iodine Decontamination Factor Removal Coefficients Elemental Iodine Particulate Iodine Organic I.odine X/Q Values (seconds per cubic meter) Exclusion Boundary 0-1 hr I.ow Population Zone 0-1 hr o-8 hr 8-24 hr 24-96 hr 96-720 hr Effective Caustic Spray Initiation Delay Time p59 2,490 Mwt 3 yr 25 percent 100 percent 91 percent 4 percent 5 percent O.l percent per day 0.05 percent par day O percent per day 0.73 0.27 2.0 unsprayed volumes per hour 100 10 per hour o.45 per hour 0 2.l X 10-3 l.8 X 10-4 7.5 X lo-55 4.8 X 10-l -5 l.9 X O 6 4.8 X 10-0 seconds

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e TABLE 3-2 Assumptions Used in the ECCS Leakage Analysis Pover Level Operating Time Fraction of Core Iodine Inventory in Containment Sump Volume of Contaim:J.ant Sump Water Sump Water Temperature Fraction of Iodine Released to Building Atmosphere from Recirculation Leakage Filter Efficiency for Safeguards Area 2,490 Mwt 3 yr 5_o percent 1~65 x 106 liters __ < 212 F .l 90 percent Technical Specification Lea.k Rates as Function of Time Value in cc/hr 0-5 min 5-20 min 20 I!lin-30 days 0 964 4,800 Nota: Twice technical specification leak rates were used. p60

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ECCS Leakage Thyroid Whole Body Containment Lea.r..age . Thyroid Whole Body e TABLE 3-3 Exclusion Bounda.rJ and LPZ Doses p61 Exclusion Boundary 6.o rem NA 242. rem 5.0 rem LPZ 2.64 rem NA 20.7 rem o.43 rem

.,J e TABLE 3-4 Assumotions Used in Control Room Doses Volume Filter Efficiency 2.23 X 105 CU ft 90 percent Breathing rate for entire 30 days 3.47 x 10-4 m3/sec Unfiltered and filtered inleakage as a function of time 0-1 hr

1. hr-30 days Filtered 0

2,000 ci'm Unfiltered 10 ci'm 10 ci'm Atmospheric dispersion factors (seconds per cubic meters) Unit 1 containment to 1 control room intake Unit 2 containment to control room intake Ventilation vent to \\c control room intake Operator occupancy factors Factor 0-8 hr 5.2 X 10-3 5.2 X 10-3 5.3 X 10-3 0-8 hr l p62 8-24 hr 2.8 X 10-3 2.7 X 10-3 2.7 X 10-3 8-24 hr

1.

l-4 davs 1.6 X 10-3 1.4 X 10 -3 1.4 ~c 10-3 1-4 days o.6 .,...,~,..,r,-*--*-*--.***** ***. ********

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\\) Thyroid Whole Body TABLE 3-5 Control Room Doses 18.8 rem NA p63 e

-:*:*.. :::.::r.. Section 4 RECIRCULATION SPRAY SYSTEM 4.1 Sump Screens 4.2 Spray Nozzles 4.3 Recirculation Spray pH e

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.... :r*.., 4.0 Recirculation Spray Syste! This section addresses question numbers 1, 2, and 5, as they pertain to the recirculation spray system. The recirculation spray system is described in Surry Power Station FSAR Section 6.3, and the containment transient analysis is u.escrib(::ld in FSAR Section 15.5.5. 4.1 Sumn Screens (Question No. 1) The finest mesh containment sump screen is made of 1/16 in. thick 316 S.S. interwoven wire with a 3/16 in. square mesh. 4.2 Spray Nozzles (Question No. 2) The ma.xi.mum. diameter of a* spherical particle that could pa~s through a.~y _nozzle in the recirculation spray system is 1/4 in. The now and pressure drop through each nozzle a.re shown below: Subsystem Nozzle Type Flow (gpni) Dirr. Press. (psi) inside recirc spray llllI30100 7.6 24.3 1/~ B_60 9.l 24.3 outside recirc spray 1HH30100 8.1 26.5 1/2 B_60 9.6 26.5 The recirculation sprat system nozzles are constructed of free cutting brass per ASTM Bl6. The nozzle orifice is expected to increase due to rlow erosion over a period of time. Thus, the mean spray droplet size 'Will increase and the spray heat removal capability will decrease. In the long term, the only source of heat to the containment atmosphere is core decay heat which is decreasing 'With time such tra t a large reduction in spray heat removal rate would be tolerable. Since no credit is taken for iodine removal by the recirculation spray system, the erosion of the recirculation spray nozzles -has no effect on the overall removal cf iodine from the containment. 4.3 Recirculation Spray PH (Question No. 5) The water in the containment sump reaches a pH of 7.0 in a maximum of 19 minutes after the accident. The mininrum long-term.recirculation spray pH is 7.6 which occurs with failure of one cont'1inment spray pump, maximum boric acid con.centrations from all sources, and minimum NaOH concen-tration in the chemical addition tank. This is discussed in Section 1 above and the parameters are presented in Table 1-4. p65 i' r,,. I ~= i ' I ' l I l 3}}