ML19263A706
| ML19263A706 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/19/1978 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7901020114 | |
| Download: ML19263A706 (21) | |
Text
Commonwealth Edison one F?.st National Plata. Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 December 19, 1978 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Zion Station Units 1 and 2 Revision to. Proposed Change to Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 References (a) :
January 10, 1975 letter from Robert A.
Purple to Byron Lee, Jr.
(b) :
March 21, 1975 letter from R. L. Bolger to Edson G.
Case
Dear Mr. Denton:
Per Reference (a), the NRC Staff requested Commonwealth Edison Company to provide additional Limiting Conditions for Operation and Surveillance Requirements in the Zicn Station Technical Specifications for installed filter systems, specifically Sections 3.17, 4.17, 3.8.8.A, 4.8.8.A, 3.13.2, and 4.13.2.
Reference (b) contained Commonwealth Edison's proposed changes in accordance with Reference (a).
Subsequent to this submittal, numerous meetings and discussions have been held with the NRC Staff with regard to this issue.
As a result of these discussions, Commonwealth Edison has revised the proposed amend-ment change contained in Reference (b) to include the updates requested by the NRC Staff and also the bases for variations from the NRC "Model Technical Specifications" contained in Reference (a). to this letter contains the revised Zion Station Technical Specifications for filter testing.
The "Model Technical Specifications" of Reference (a) were followed as closely as possible.
However, since these Technical Specifications were 730102eu4 f
NRC Docket Nos. 50-295/304 Mr. Harold R.
Denton December 19, 1978 not prepared explicitly for Zion Station, some changes were necessary to aaapt them to the Zion design and nomenclature.
contains a summary of the changes and the differences from the NRC "Model Technical Specifications."
The overall changes proposed in Attachment 1 provide uniformity and justification for an eighteen (18) month surveillance schedule.
This submittal references ANSI N510 as the basic reference and guiding document for filter testing.
The revised change of Attachment 1 has been reviewed by the Commonwealth Edison On-Site and Off-Site Review with the conclusion that there are no unreviewed safety questions.
Please address any additional questions that you might have to this office.
Three (3) signed originals and thirty-seven (37) copies of this letter are provided for your use.
Very truly yours, l
N(
Cordell Reed Assistant Vice-President attachments SUBSCRIBED and SWO to befor9 me this day of ldff(nltf!L, 1978.
)lawnNl dice Mu o dotaryPublic h
Zion Station Units 1 and 2 NRC Docket Nos. 50-295 and 50-304 Proposed Technical Specification Changes The following pages have been revised:
iv 281 180 282 181 284 244 The following pages have been added:
180A 244A 244B 244C
Table of Contents (Continued)
SURVEILLANCE LIMITING CONDITION FOR OPERATION REQUIREMENT PAGE 3.13 Refueling Operations 4.13 243 3.13.1 Core Reactivity 4.13.1 243 3.13.2 Protection From Damaged Spent Fuel 4.13.2 244 3.13.3 Containment Status 4.13.3 245 3.13.4 Radiation Monitoring Bases 4.13.4 246 3.13.5 Refueling Equipment Checkout 246 3.13.6 Refueling Equipment Operability 246 3.13.7 Spent Fuel Pit Cooling Systems 246 3.13.8 Fuel Inspection Program 247 3.14 Plant Radiation Monitoring 4.14 250 3.15 Auxiliary Electrical Power System 4.15 255 3.16 Environmental Radiological Monitoring Program 4.16 275 Bases 3.17.1 Ventilation Bases 4.17.1 281 3.17.2 Aircraft Fire Detection 4.17.2 283 4.18 289 3.18 Steam Generayor Bases 3.19 Failed Fuel Monitoring 4.19 292 3.21 Fire Protection 4.21 295D 5.0 Design Features 296 5.1 Site 296 5.2 Reactor Coolant System 296 5.3 Reactor Core 296 5.4 Containment System 296 5.5 Fuel Storage 298 5.6 Seismic Design 299 iv
LIMITING CONDITION ROR OPERATION SURVEILLANCE REQUIR191ENT 3.8 8
Hydrogen control systems 4.8 8.
Ilydrogen control systems (Table 4.8-7)
A.
Ifydrogen purge fans A.
Hydrogen purge fans 1.
The two hydrogen purge fan systems 1.
The hydrogen purge fans shall be shall be operable whenever the started manually from the control reactor is critical except as room every three months.
Perfor-specified in 3.8.8.A.2.
mance will be acceptable if the fan starts upon actuation and operates 2.
From and after the date that one for 15 minutes.
of the hydrogen purge fan systems is made or found to be inoperable 2.
When it is determined that one of for any reason, reactor operation the two hydrogen purge fan systems including recovery from an in-is inoperable, the renaining advertent trip is permissible only systems shall be demonstrated to during the succeeding 15 days pro-be operable immediately and daily vided that during those 15 days the thereafter.
one remaining system shall be operable.
3.
Once every 18 months, or (1) after each complete or partial replace-3.
If these conditions cannot be met, ment of a HEPA filter or charcoal the reactor shall be brought to the adsorber banN or (2) after any hot shutdown condition within four structural maintenance on the HEPA hours. After a maximum of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> filter or charcoal adsorber in the hot shutdown condition, if housing surveillance will be the system is not operable, the performed by:
reactor shall be brought to the cold shutdown condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
a.
Verifying that the charcoal adsorbers remove 1 99 percent of a halogenated hydrocarbon refrigerant test gas when they are tested in place.
b.
Verifying that the HERA filter banks remove h 99 percent of the DOP when they are tested in place.
I 180
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT
- 4. 8.8. A. 3 c.
Subjecting at least two carbon samples removed from one of the charcoal adsorbers to a labo-ratory carbon sample analysis and verifying a removal effi.
ciency of > 90 percent for radioactive methyl iodine at 2 1900F and )95 percent rela-tive humidity. The carbon samples shall be prepared by emptying one bed from a re-moved adsorber tray, mixing the adsorbent thoroughly and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.
d.
Instrumentation, equipment, and procedures for the above testing shall generally con-form to the recommendations in ANSI H510.
W e.
Verifying that the system flow rate is 360 CFM + 10 percent during system operation.
f.
Verifying that the pressure drop across the combined IEPA filters and charcoal adnorber banks is six inches Water Gauge while operating the ventilation system at a flow rate of 360 CFM + 10 percent.
180A e
LIMITING CONDITION FDR OPERATION SURVEILLANCE REQUIR141ENT 4.8.8 3.8.8 B.
Hydrogen recombiners*
B.
Hydrogen recombiners*
1.
The two hydrogen recombiner systems 1.
The hydrogen recombiner systems shall be operable whenever the shall be functionally tested every reactor is critical except as six months.
Performance will be specified in 3.8.8.B.2.
acceptable if the heaters energize and bring the system to operating 2.
From and after the date that one temperature, the blower works, and of the hydrogen recombiner systems the instruments indicate proper is made or found to be inoperable operation.
for any reason, reactor operation, including recovery from an in-2.
When it is detennined that one of advertent trip, is permissible only the two hydrogen recombiner systems during the succeeding 15 days is inoperable, the remaining system provided that during those 15 days, shall be demonstrated to be operable the one remaining system shall be immediately.
- These requirements become applicable following the pre-operational test of the hydrogen recombiner systems.
181 8
SURVEILLANCE REQUIREMENT LIMITING CONDITION FOR OPERATION 3.13.1.B fuel is in the reactor, neutron flux 4.13.1 shall be monitored continuously by at least one source range neutron monitor with both visual and audible indication.
C.
The movement of an irradiated fuel C.
Not applicable.
assembly in the reactor core shall not begin until the reactor has been sub-critical for a period of at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.
D.
At least one RHR pump and heat ex-D.
The operation of at least one RHR pump changer shall be in operation during a and heat exchanger shall be verified refueling operation.
once a shift.
E.
Direct communication between the E.
Communication between the control room control room and containment shall be and the containment shall be verified operable.
before any alteration of the reactor core begins.
F.
A licensed fuel handling foreman or licensed senior reactor operator shall F.
Not applicable.
be present at the reactor cavity during any movement of fuel within the contaimnent.
s 3.13 2.
Protection from Damaged Spent Fuel 4.13 2.
Protection from Damaged Spent Fuel A.
During irradiated fuel movement or The charcoal filter mode of operation crane operation with loads over of auxiliary building ventilation system irradiated fuel in the fuel building, shall be demonstrated to be operable:
the fuel building exhaust system shall be:
A.
When operability is required by Specification 3.13.2.A.1,by observing 1.
Operating with ventilation flow and documenting at least once per through the HEPA and charcoal shift, that the ventilation system filters if there is any irradiated is operating as required by fuel stored in the pool with less Specification 3.13.2.A.
than 60 days decay time.
244
SURVEILLANCE REQUIH141ENT LIMITING CONDITION FOR OPERATION 3.13.2.A 2.
Operable with automatic initiation it.13.2 B.
When operability is required by of flow through the IIEPA and Specification 3.13.2.A.2 at least once cha rcoal filters upon detection per 30 days by manually initiating, of high radiation at tha fuel pool from the control room, flow through if all irradiated fuel stored in the IIEPA filter and charcoal adsorber the pool has 60 days or greater train and verifying that the train decay time since irradiation ceased maintains the building at a negative If automatic actuation is in-pressure of 1 (h) inches Water Gauge operable, the system shall be relative to the atmosphere. The manually placed in the " charcoal system shall be operated for at least filter mode".
15 minutes.
B.
I f requirements of Specification C.
Once every 18 months, or (1) after 3.13.2.A, above, cannot be met, each complete or partial replacement irradiated fuel movements or crane of a !! EPA filter or charcoal adsorber operation with loads over irradiated bank, or (2) 6fter any structural fuel shall be terminated, after first, maintenance on the !! EPA filter or if applicable, placing loads in a safe charcoal adsorber housing by:
condition.
1.
Verifying that bypass flow of the system operating in the " charcoal filter mode" is prevented, in-cluding Icakage through the ventilation system diverting valves, by verifying that the measured concentration of a halogenated hydrocarbon refrigerant test gas when measured upstream and downstream of all system bypasses indicates total system bypass to be f,1 percent.
2.
Verifying that the charcoal adsorbers remove 199 percent of a halogenated hydrocarbon refrig-erant test gas when they are tested in place.
2'4tlA e
LIMITING CONDITION FDR OPERATION SURVEILLANCE REQUIREMENT 4.13.2.C 3.
Verifying that the HEPA filter banks remove ) 99 percent of the DOP when they are tested in place.
4.
Subjecting at least two carbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of ) 90 percent for radioactive methyliodine at
) 125 F and it95 percent relative T1umidity.
The carbon samples shall be prepared by emptying one bed from a removed adsorbent tray, mixing the adsorbent thoroughly, and obtaining samples at lea,t two inches in diameter and with a length equal to the thickness of the bed.
5.
Instrumentation, equipment, and procedures for the above testing shall generally conform to the recommendations in ANSI N510.
6.
Verifying that fuel building ex-haust ventilation flow in the
" charcoal filter mode" is within
+ 10 percent of the design flow rate of 16,500 CFM.
7.
Verifying that ;he pressure drop across the combined HERA filters and charcoal adsorber banks is
<6 inches Water Gauge while operating the ventilation system at a flow rate of 16,500 CFM + 10 percent.
244B
SURVEILLANCE REQUIREMENT LIMITING CONDITION FOR OPERATION 4.13.2.C 8.
Verifying that on a High Radiation Signal, the system automatically directs its exhaust flow through the HEPA filters and charcoal adsorber banks.
If automatic actuation is inoperable, the system shall be manually placed in the " charcoal filter mode".
\\
f 244C e
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.17 Ventilation 4.17 Ventilation 3.17.1 Applicability 4.17.1 Applicability Applies to the testing of particulate and Applies to the testing of particulate and charcoal filters in safety-related air charcoal filters in safety-related air filtration systems.
filtration systems.
Obj ective Objective To verify that leakage efficiency and iodine To verify that leakage efficiency and iodine removal efficiency are within acceptable removal efficiency are wit hin acceptable limita.
limits.
Specification Specification Safety-related ventilation filters shall be 1.
The charcoal filter banks specified in periodically tested.
Table 4.17-1 shall be tested for leakage l
efficiency at least once every 18 months using an in-place Freon-112 (or equivalent) method.
Removal of 2 99.0 percent of the Freon-112 (or equivalent) shall constitute acceptable performance.
2.
A carbon sample shall be removed from one of the filter banks specified in l
Table 4.17-1 once every 18 months and subjected to a chemical analysis to determine the iodine removal capability.
Verification of methyl iodine renoval efficiency of jk 90.0 percent shall con-stitute acceptable performance.
281
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 4.17.1 3.
The particulate filter banks specified in Table 4.17-2 shall be leak tested for leakage efficiency at least once very 18 n.anths, using an in-place DOP test method.
Removal of ) 99. percent of the DOP shall constitute acceptable perfornance.
4.
Instrumentation, equipment, and procedures for the above testing shall generally conform to the i
recommendations in ANSI N510.
282
\\
Filter No. of Elements Filter Description Bank No.
Filter l ocation Per Bank Aux. Bldg. Charcoal OAV040 642' Fan Room 91 Aux. Bldg. Charcoal OAV041 642' Fan Room 91 Drumming Station OAV043 592' Col. K-24 12 Control Room Makeup Air OPV005 617' Fan Room 12 i
Hydrogen Purge RV020 Purge Room 1, 617' 2
Hydrogen Purge RV021 Purge Room 1, 617' 2
Miscellaneous Vents OAV069 642' Fan Room 6
Charcoal Filters TABLE 4.17-1 284 4
Zion Station Units 1 and 2 NRC Docket Nos. 50-295 and 50-304 Summary of Changes and Differences From NRC Model Technical Specifications Section 4.8.8.A.3 The testing frequency has been changed to a uniform 18 month interval for all filter testing.
The 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> limit has been deleted.
On other plant ventilation systems in essentially continuous use, an 18 month testing interval has been sufficient to keep track of filter efficiency.
The hydrogen purge system has only a post-LoCA function, and is only used during testing for 15 minutes every three months.
In light of the performance record of the other plant filter systems and the very low frequency of operation of the hydrogen purge system, more frequent testing or sampling is not considered necessary.
Section 4.8.8.A.3.a The model specification has been followed,except that the reference to US AEC Report DP-1082 has been deleted.
All references to standards have been consolidated into proposed Section 4.8.8.A.3.d, which states that the testu will generally conform to ANSI N510.
Section 4.8.8.A.3.b The model specification has been followed,except that the reference '.o ANSI N101.1-1972 has been deleted.
Sectica 4.8.8.A.3.c The model specification has been followed, except that US AEC RDT Staadard M-16-lT, June 1972, has not been referenced.
Proposed Section 4.13.2.C.5 references ANSI N510, which in turn references RDT Standard M-16-lT.
Sections 4.8.8.A.3.d and 4.8.8.A.4.a The model specification has been followed in both of these sections.
Section 4.8.8.A.4.b This section has been deleted.
The hydrogen purge filter assembly is only a single filter element wide.
Therefore, a distribution measurement across filter elements is not appropriate.
Section 4.8.8.A.4.c This section has been deleted.
The Zion Station filters have no cooling function.
Section 3.13.2 The model specification has been followed, except that the flow at which the system must be operating as a limiting condition for operation has not been specified.
Zion Station does not have continuous flow monitoring capability in this system; and therefore, such a measurement is difficult to obtain.
It is not anticipated that this flow will change, unless structural modifications are made.
Therefore, Commonwealth Edison proposes that system flow be measured and verified to be within limits during the 18 month periodic testing program.
(See proposed Section 4.13.2.c.6).
Section 4.13.2.A The model specification has been followed with an added requirement from Section 4.13.2 of the current Zion Station Technical Specifications.
This addition is to require observation and documentation, once per shift, that the ventilation system is operating in the chsrcoal filter mode during irradiated fuel movements.
Section 4.13.2.B The testing frequency has been changed to a uniform 18 month interval for all filter testing.
The 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> limit has been deleted.
In the past, an 18 month testing interval has been sufficient to keep track of filter efficiency and to anticipate when a given bank w d need to be replaced.
Zion Station has been through several re.uelings and has experienced many auxiliary building gas leaks without exhausting the capacity of the auxiliary building charcoal filters.
In light of this performance record, more frequent testing or sampling is not considered necessary.
Section 4.13.2.B.1 The method of verifying that flow is not bypassing the charcoal filters has been changed.
The NRC proposed method of injecting DOP at the spent fuel pool can not yield valid test results at Zion, where there are multiple inle+a at the pool.
Flow from the other inlets would result in dilution of the initial DOP concentration.
Therefore, an alternate method of verifying no bypass flow has been proposed.
(See Figure 1 attached).
Section 4.13.2.B.2 The model specification has been followed, except that the reference to US AEC Report DP-1082 has been deleted.
The Zion Station tests will generally conform to the guidance set forth in ANSI N510, as specified in the proposed Section 4.13.2.C.5.
. Section 4.13.2.B.3 The model specification has been followed, except that the reference to ANSI N101.1-1972 has been deleted.
Section-4.13.2.B.4 The model specification has been followed, except that US AEC RDT Standard M-16-lT, June 1972, has not been referenced.
All references to standards have been consolidated into proposed Section 4.13.2.C.5, which states that the tests will generally conform to ANSI N510.
ANSI N510,in turn, references the US AEC RDT Standard M-16-lT, June 1972.
Sections 4.13.2.B.5 and 4.13.2.C.1 The model specification >; have been followed in both of these sections.
Section 4.13.2.C.2 This section has been deleted, since Zion Station has performed measurements that indicate that the flow distribution meets the i20% requirement.
(See attached Appendix A).
In addition, Zion Station does not anticipate making any major structural modifications that might affect this distribution.
Section 4.13.2.C.3 The model specification has been followed.
Section 4.13.2.C.4 This section has been deleted.
Zion Station filt.ers have no cooling function.
Section 4.17 The proposed changes in Sections 4.8.8.A and 4.13.2 of the Lion Station Technical Specifications also necessitate changes to Section 4.17.
These changes are summarized as follows:
1.
Change the test frequencies specified in 4.17.1.1, 4.17.1.2, and 4.17.1.3 to the uniform 18 month test interval, to be compatible with Sections 4.8.8. A.3 and 4.13.2.C.
, 2.
Revise 4.17.1.4 to reference ANSI N510, to be compatible with Section 4.13.2.c.5.
3.
Remove containment charcoal filters RV032 and RV033 from Table 4.17-1.
These filters are free-standing units on the 617' containment floor that are used to recirculate the containment atmosphere to facilitate They are not part of any release path to the access.
environment.
A crop in filter efficiency would only mean that additional running time would be required to reduce the containment activity to the level desired for access.
While it is to Zion Station's benefit to keep these filters in good operating condition from the standpoint of time savings for containment access, these filters have no effect on Zion Station's gaseous releases.
Therefore, a Technical Specification is not considered necessary for these filters.
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APPENDIX A Flow distribution tests were performed at the discharge of the Aux. Building Charcoal Filter Banks A & D.
Each charcoal bank was divided into 9 flow zones and measurements were taken in the center of each zone while two charcoal booster fans were in operation.
The flow was integrated in cach zone for a period of one minuto using a Taylor Air Flow Meter.
The average flow velocity for the 9 zones and the normalized flow distribution was as follows:
.967
.981
.989 1.089
.808
.841 1.120 1.071 1.036 1.062 1.093 1.035
.924
.984
.927 1.064 1.088
.916 e
Filtor Dank A Filter Bank B Average Velocity 6.13 Ft/ Soc Average Velocity 8.60 Ft/Sec The above data indicates the air flow distribution to each charcoal adsorber is within + 20 percent of the average flow per unit.
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