ML19275C328

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Tech Specs 3.15 & 4.12 for Air Treatment Sys
ML19275C328
Person / Time
Site: Crane 
Issue date: 02/28/1980
From:
METROPOLITAN EDISON CO.
To:
Shared Package
ML111090060 List: ... further results
References
FOIA-80-515, FOIA-80-555 NUDOCS 8003200260
Download: ML19275C328 (13)
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Text

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E4 CLOSURE I 3.15 AIR TREATMENf SYSTEMS 3.15.I OERGENCY CONTROL ROCM AIR TREATf'ENT SYSTEM Yplimbility Applies to the emergency control room air treatment system and its associated filters.

Objective To specify minimum availability and ef ficiency for the emergency control room air treatcent system and its associated filters.

%ecifirations 3.15.1.1 Except as specified in Specification 3.15.1.3 below, both emergency treatment systems, AH-E18A fan and associated filter AH-F3A and

,H-ElEB fan and associated filter AH-F3B shall be operable at all

'...es, per the requirements of Specification 3.15.1.2 below, when containment integrity is required and when irradiated fuel handling operations are in progress.

3.15.1.2 a.

The results of the in place 00P and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal adsorber banks shall show <0.05% DOP penetration and <0.05% halogenated hydrocarbon penetration, except that the DOP test will be conducted with prefilters installed.

b.

The results of laboratory carbon sample analyses shali show

>90% radioactive methyl iodide decontamination efficiency when tested at 125 F, 95% R.H.

c.

The fans AH-E18A and B shall each be shown to operate within i 4000 CFM of design flow (40,000 CFM).

3.15.1.3 From and after the date that one control room air treatment syt tem is made or found to be inoperable for any reason, reactor operation or irradiated fuel handling operations are permissible only during the succeeding 7 days provided the redundant system is demonstrated to be operable per 4.12.1.1 and 4.12.1.3 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and daily thereafter.

3.15.1.4 Frnq the date that both control room air treatment systems are made or found to be incperable or if the inoperable system of 3.15.1.3 cannot be cade operable in 7 days, irradiated fuel handling operations shall be terminated in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reactor shutdown shall be initiated and the reactor shall be in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

b S008300

. Bases The emer gency control room air treatment syct _is AH-EISA and leB and their as soci at ?d filter s are t..o f rer..* A r.t y. '

Ssig.:d to filter the control roc atro phere for intale air 3ri/o'- f ar
i calitica during control room isolation conditions.

The control building is c:digned to be automatically pinced in the recirculation mode upun an R.'4-Al high radiation alarm, air tunnel device actuation, FSAS actuation or st ation blackout condition.

The emergency control room air treatment fan and filter AH-E18A or B and AH-F3A or B is designed to be ".anually startad by the cparator if a high radiation alarm from RM-Al is indicated.

Profilters and high efficiency pirticulate absolute (hEPA) filters are installed before the charcoal ibicrbars to pr-2nt c!o m.; of tue iodine adsorbers and remove part.iculate activity.

The chucral s c r: 3rs :re installed to reduce the potential intake of radiciodine to tne cat. col rocm.

If the ef ficiencies of the HEPA filters and charcoal adsorbers ure as :pecified, the resulting doses will be less than the allc.oble levels :tated in Crit 2rion 19 of the General Design Criteria for "uclear Po..ar Plants, % :ndix A to 10 CFR Part 50.

Cperation of the f ans significutly dif fecent f.';.a the

.2 sign flow will change the re oval ef ficiency of the PLPA filters and : 3 rec il adsar bers.

If one system is found to be inc;,_ cable, there 13 no

.~.ediate threat to the control roca and reactor operation or refueling my continue for a limited period of ti:ne <.hile i epiirs o re be: :g made.

If we :jstum cunact be repaired within 7 days, the r:3ctor is shut ic..n and brou;ht to cc id shut...a.vi thin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or irradiited fuel handling cparations are t o..icited

' thin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

If both systems are found to be inoperable, reactor 6 e " :n shall be initiatod and the reactor will be b ought to cold shut ~.vn in ~5

..;o.s and irradiated fuel handling operations will be stcpped within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The in pl'ce DOP and halcginated hydrocarbon t ts of Se filter banks and the laboratory tests of the caroon sa nples v ill

_2

ane in
3 i r.a r '.. n i c h wets the guidelines of Degulatory Guide 1.52 (Re.

2).

.R. e f e re n c e s (1) FSAR Section 9.3 (2) FSAR Figure 3-21 h

3.15.2 REACTOR EUILDING ? URGE AIR TREATMENT SYSTEM 321 i c ab i_l i_t_y Applies to the reactor building purge air treatment system and its associated filters.

OQjective To specify minimum availability and ef ficiency for the reactor building purge air treatment system and its associated filters.

jpe_c i fi ca t i_on 3.15.2.1 Except as specified in Specification 3.15.2.3 below, the Reactor Building Purge Air Treatment System filter AH-Fl and fans AH-E7A and B shall be operable as defined by the Specification below at all tir.es when containment integrity is required.

3.15.2.2 a.

The results of the in place DOP and halogenated hydrocarbon tests at design flows on HEPA filters and charcoal absorber banks for AH-Fl shall show <0.05% 00P penetration and :0.05%

halogenated hydrocarbon penetration, except that the DOP test will be conducted with prefilters installed.

b.

The results of laboratory carbon sample analysis from the reactor building purge system filter carbon shall show 190%

radioactive rethyl iodide decontamination efficiency when tested at 250 F, 95% R.H.

Fans AH-E7A and B shall each be shown to operate within 2,500 CFM c.

of design flow (25,000 CFM).

3.15.2.3 a.

From and af ter the date that the filter AH-Fl in the reactor building purge system is made or found to be inoperable as defined by Specification 3.15.2.2 above, or both fans AH-E7A and B are found to be inoperable, reactor operation is permissible only during the succeeding 30 days, unless such filter and at least one fan is sooner made operable.

b.

If the required conditions for the reactor building purge filter and fan cannot be met after 30 days, operations shall be terminated immediately and the reactor placed in cold shutdown within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Cases The Reactor Building Purge Exhaust system filter AH-F1 while normally used to filter all reactor building exhaust air, serves also as the post-accident purge filter when used in conjunction with the Hydrogen Purge System to reduce hydrogen gas concentrations in the reactor building following a LOCA.

It is necessary to demonstrate operability of these filters to assure readiness for service if required, approximately thirty (30) days following a hypothetical LOCA.

_4 44 5 r'fici

-) ' articulate absoltte (NEPA) filters are installed before the

.,_ al c bers to prevent clogging of the iodine absorbers for all emergency air ti e s t :nt s, stems.

The charcoal absorbers are installed to reduce the ratential release of radiciodine to the environment.

If the efficiencies of t. CFA filters and charcoal adsorbers are as specified, the resulting doses will be less than the 10 CFR 100 guidelines for the accident analyzed in FSAR S: ypl'~ent I Part III, which assumes 90% efficiency.

The flew through AH-F1 by design can vary from 0 CFM to 50,000 CFM, the maximum purge flow rate, with makeup air being provided between the filter AH-Fl and the fans AH-E7A and 8 to maintain a constant reactor building purge exhaust stack flow rate of 50,000 CFM regardless of the actual purge flow.

The in place DOP and halogenated hydrocarbon tests of the filter banks and the laboratory tests of the carbon samples will be done in a manner which meets the guidelines of Regulatory Guide 1.52 (Rev. 2), except that DOP and Freon tests will be performed at maximum available flow considering physical restrictions, i.e., purge valve position, and gaseous radioactive release criteria.

R e f e re.nc e s (1) FSAR 5ection 5.3.3 (2) FSAR Section 5.6 (3) FSAR Section 9.8

. 5-3.15.3 AUXILIARY AND FUEL HA',DLING E HAUST AIR i.EAirENT SYSTEM i

Aoplicability Applies to the auxiliary and fuel handling exhaust air treitrent system.

Objective To specify the minimum availability and ef ficiency for the auxiliary and fuel handling exhaust air treat ent system.

Specification 3,15.3.1 The auxili,ry 2nd ' "

-7 i ;3 evhaust air treatment system shall be or

..e at a.i

.i s

,en fuel handling operations are in progenss.-

3 R.al a j;

, ~

iding and whenever irradiated fuel is in the storage pool.

This :pplies to the exhaust filters AH-F2A, 28, 2C, and 20 as

.4 ell as the exhaust fans AH-E14A, 148, 14C, and 140.

From and af ter the date that the auxiliary and fuel handling exhaust air treatment system is cade or found to be inoperable, that is the filters AH-F 2A, 28, 2C, and 2D and/or both sets of fans AH-E 14A and 14C and AH-E 14B and 100, are inoper3ble, fuel handling operations shall be ter"1inated in 2diately until the coiponents are returned to se rv i ce.

Any fuel assembly movement in progress may be completed.

3.15.3.2 a.

The results of the in place DOP snd halogenated hydrocarbon tests at design flc.ss on HEPA filters and charcoal adsorber banks shall shcw <0.05% CDP par,etration and <0.05% halogenated hydrocarbon,; etration, e.< cept that the CCP test will be conJucted with prefilters ins talled.

b.

n.a,2:.lts of laboratory carbon aarple analysis shall show

>901 radic3ctive ethyl iodide decontamination efficiency when

...'F, 95% R.H.

te aed at c.

Each set of fans AH-E14 A & C and AH-E14 8 & D shall each be sho.in to have the capacity of cperating within + 11,881 CFM of design ficw (118,810 CFM).

3.15.3.3 'iith one auxiliary and fuel handling exhaust air treatment system inoperable, fuel movement within the storage pool may proceed provided the OPERABLE auxiliary and fuel handling exhaust air treatment system is in operation and discharging through at least ore train of HEPA filters and charcoal adsorbers.

Eases Tna Auxil'ary and Fuel " ndling Building Exhavet System consists primarily of the exhaust filters AH-F2A, B, C, and D and t'..o sets of redundant exhaust fans AH-E14A 2:d C or AH-El4B and D '<hich take the exhaust air from both the Auxiliary Euilding and the Fuel Handling Building and discharge it to the Auxiliary and Fuel Handling building exhaust stack.

All the air passes through the exhaust filters AH-F2A, B, C, and D 100% of the time prior to being discharged to the stack.

High ef ficiency particulate absolute (HEPA) filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorbers for all emergency air treatment systems.

The charcoal adsorbers are installed to reduce the potential release of radioicdine to the environment.

If the efficiencies of the HEPA filters ind charcoal adsorbers are as specified, the resulting do;es will be less than the 10 CFR 100 guidelines for the accidents analyzed in Chapter 14 of the FSAR,.shich assumes 90% ef ficiency.

If the auxiliary and fuel handling exhaust air system is fcund to be inoperable, all fuel handling and fuel movement operations will be terminated until the system is made operable.

The inplace CDP and halogenated hydrocarbon tests of the filter banks and the laboratory tests of the carbon samples will meet the guidelines of Regulatory Guide 1.52 (Rev. 2).

References (1) FSAR Caction 9.8 (2) F5AR Figure 9-20 IABLE 4.1-2 MINIMUM EQUIPMENT TEST FREQUENCY Item Test frequency 1.

Control Rods Rod drop time of all Each refueling shutdown full length rods 2.

Control Rod Movement of each rod Every two neeks, when Movement reactor is critical 3.

Pressurizer Setpoint 50% each refueling Safety Valves period 4.

Main Steam Setpoint 25% each refueling Safety Valves period 5.

Refueling System Functional Start of each Interlocks refueling period 6.

Main Steam (See Section 4.8)

Isolation Valves 7.

Reactor Coolant Evaluate Daily, when reactor System Leakage coolant system temperature is greater than 525 F 8.

Air Treatment See Section 3.15 See Section 4.12 Systems 9.

Spent Fuel Functional Each refu;1ing period Cooling System prior to fual handling 10.

Intake fump (a) Silt Accumulation-Each refueling period House Floor Visual inspection (Elevation of Intake Pump 262 ft. 6 in.)

House Floor (b) Silt Accumulation Quarterly Measurement of Pump House Flow

3-4.12 AIR TREAij'Ef4T SYST EMS 4.12.1 EMERGEhCY CCNTROL ROCM AIR TREAT :ENT SYSTEM Applicabili,tv

'pplies to the emergency control room air treatment system and associated conponents.

C.bjgctiyg To verif, that this system and associated ccmponents will be able to perform its design functions.

Scecification 4.12.1.1 At least every refueling interval or once every 18 months whichever ccms first, the pressure drop across the cc,Tbined HEPA filters and chircoal adsorber banks of AH-F3A and 38 shall be demonstrated to be less than 6 inches of water at system design flow rate (110%).

4.12.1.2 a.

The tests and sample analysis required by Specification 3.15.1.2 shall be performed initially and at least once per year for standby service or af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and following significant painting, fire or chemical release in any ventilation zone coi.7,unicating with the system that could contaminate the HEPA filters or charcoal adsorbers.

b.

00P testing shall be performed after each complete oc partial replacement of the HEPA filter bank or after any structural maintenance on the syste-i housing which could affect the HEPA filter bank bypass leakage.

c.

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

d.

Each AH-E18A and B (AH-F3A and B) fan / filter circuit shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month.

4.12.1.3 At least once per refueling interval or once every 18 months whichever comes first, automatic initiation of the Control Building isolation and recirculation Dampers AH-028, 37, 39, and 36 shall be demonstrated as operable.

4.12.1.4 An air distribution test shall be performed on the HEPA filter bank initially, and after any maintenance or testing that could affect the air distribution within the system.

The air distribution across the HEPA filter bank shall be uniform within +20%.

The test shall be performed at 40,000 cfm (110%) flow rate.

.c.

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

Pressure drop should be determined at least once per refueling cycle to show

>/ sten performance capability.

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

Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with approved test procedures.

Replacement adsorbent should be qualified according to Regulatory Guide 1.52 lhrch 1978.

The charcoal adsorber efficiency test procedures should allow for the raoval of one adsorber tray, emptying of one bed frcm the tray, mixing the adsorbant thoroughly and obtaining at least two sc.ples.

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

If test results are unacceptable all adsorbent in the system shall be replaced.

Tests of the HEPA filters with DOP aerosol shall also be perfor.ned in accordance with approved test procedures.

Af'y HEPA filters found defective should be replaced with filters qualified according to Regulatory Guide 1.52 Ma ch 1978.

Operation of the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month will demonstrate operability of the filters and adsorber system and remove excessive moisture built up on the :bscrber.

If significant painting, fire or chemical release occurs such t_ hat the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use.

The determination of significance shall be made by the Unit Superintendent.

Denonstration of the auto atic initiation of the recirculation mode of operation is necessary to assure system performance capability.

4.12.2 REACIOR BUILDItKi PURGE AIR iREAT!:ENT SisiEM Apolicability Applies to the reactor building purge air treatment system and associated ccaponents.

CM ective To verify that this system and associated ccr.ponents will be able to perform its design functions.

Specification 4.12.2.1 At least once per refueling intarval or c-ce per 18 c cnths, whichever comes first. it shall be &anstrated LMt the pressure drop across the combined HEPA filters and charccal d orber banks is loss than 6 inches of water at system design flow rate (110%).

4.12.2.2 a.

The tests and sacple analysis required by Specification 3.15.2.2, shall be performed initially, once per refueling interval or 18 months, whichever comes first, or after each 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation and following significant painting, fire, or chemical release in any ventilation zone c=municating with the system that could contaminate the HEPA filters or charcoat adsorbers.

b.

00P testing shall be performed af ter n ach ccTplete or partial replacement of a HEPA filter bank or af ter any structural maintenance on the system housing which could affect BEPA frame bypass leakage.

c.

Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of a charcoal adsorber bank or after any structural caintenance on the system housing which could af fect the charccal adsorber bank bypass leakage, d.

The DOP and halogenated hydrocarbon testing shall be performed at the maximum available flow considering physical restrictions, i.e., purge valve position, and gasecus radioactive release criteria.

e.

The Reactor Building purge exhaust fans AH-87A and B shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every month, either during actual purging or using makeup air.

4.12.2.3 An air distribution test shall be performed on the HEPA filter bank initially and after any maintenance or testing that could affect the air distribution within the system.

The air distribution across the HEPA filter bank shall be uniform within 120%.

The test shall be performed at 25,000 cfm (110%) flow rate.

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

Pressure drop should be determined at least once every refueling interval to show system performance capability.

T!e fim,c ocy of ts sts and s rple v 31ysis are necessary to shcw that the HEPA filt;rs :.nd c! arccal adsor bers can prform as evaluated.

Tests of the charcoal adsorbers with halogenated hydrocarbsn refrigerant shall be performed in acccedance with approved test procedures.

The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed f rom the tray, mixing the adsorbent thoroughly and obtaining at least t..o

._ ples.

Each sample should be at least two inches in diameter and a length equal

  • .o the thickness of the bed.

If test results are ur,ccant.=hlo.

all adsorbant in the system should be replaced with an adsorbent qualified according to Regulatary Guide 1.52, " arch 1978.

Tests of the liEPA filters with DOP aerosol shall also be performed in accordance with approved test procedures.

Any liEPA filters found defective should be replaced with filters qualified according to Regulatory Guide 1.52, March 1978.

Operation of the emergency air treatment system each monto for at least ten (10) hours will deronstrate operability of the fans and when operated in the purge mode will tend to cause the filter and adscrber system to remove excessive noisture built up on the adsorber.

If significant painting, fire, or chemical.alaase occurs such that the HEPA filter or charcoal adsorber could become contaminated f rom the fumes, chemicals or foreign material, the same tests and suple analysis shall be performed as required for operational use.

The a ter.,ination of signifF ant shall be made by the Unit Superintendent.

4.12.3

_ It IMY AND FUEL HANDLING E WUS T Alfi T-s 1ENT Si S T E'1 BPlicjbility Applies to the auxiliary and fuel handling building exhaust air treatment system and associated components.

Cbjective To verify that this system and associated components will be able to perform its design functions.

Speci_fication 4.12.3.1 At least once per refueling interval or once per 18 months, whichever ceaes first, it shall be datanstrated that the pressure drop across the cc bined HEPA filter and adsorber banks is less than 6 inches of oater at system design flow rate (110%).

4.12.3.2 a.

The tests and sample analysis required by Specification 3.15.3.2 shall be performed initially, once

.c refueling interval or 18 months, whichever comes first, or within 30 days prior to the movemeat of irradiated fuel and following significant painting, fire, or chemical release in any ventilation zone con.nunicating with the system that could contaminate the HEPA filters or chircoal adsorbers, b.

DCP testing shall be perforned af ter each cmplete or partial replacement of a HEPA filter bank or after any structural maintenance on the system housing that could 3f fect the HEPA filter bank bypass leakara c.

Halogenated hydrocarbon testing shall te performed af ter each ccaplete or partial replacement of a charcoal adsorber bank or af ter any structural maintenance on the AH-F 2A, 8, C, or 0 housing that could affect charcoal 3dsorber bank bypass leauge.

d.

Tha fan combination AH-E 14A and C ana AP-f 148 and D shall be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every fronth.

4.12.3.3 An air distribution test shall be perforned on the HEPA filter bink initially and af ter any maintenance or testing that could affect the air distribution within the system.

The air distribution across the HEPA filter bank shall be uniform within +209.

The test shall be performed at 118,810 cfm (110% flow rate)7 Eases Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 6 inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

Pressure drap should be determined at least once every refueling interval to shcw system performance capabiiity.

The ti' 3.mnq of tests ind s-ple inalysis are nec 2s sary to show that the !?A filters and chircoal lort 3rs can perform as evalt.ated.

Tests of the ch3tcoal adsorbers with halogenated hydrocarbon refrigerant shall be perforired in accur.fance with apprcsed test procedures.

The ch3rccal adsorber efficiency test procedur es should allos for the removal of one adsorber tray, emptying of one bed frcm the tr3y, mixing the adsorbent thoroughly and obtaining at le3st two samples.

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

If test results are unacceptable, all adsorbent in the system should be replaced with an adsorbent qualified according to Regulatory Guide 1.52,riarch 1978.

Tests of the HEPA filters with 00P aerosol shall be perforced in accordance with approved procedures.

Any HEPA filters found defective should be replaced with filters qualified according to Regulatory Guide 1.52,fiarch 1978.

Operation of the Auxiliary and Fuel Handling Building Exhaust Fans each month for at least ten (10) hours will

-?-

3nstrate cparability of the fans.

If significant painting, fire, or cheinical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, cheT,icals or foreign material, the same tests and sample analysis shall be performed as required for operational use.

The determination of significant shall be made by the Unit Superintendent.

E*, CLOSURE I!

EAFETY E'/At UATICN BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUWuR i LNG A",E N';"EN T N0.

TO LICENSE N0. CFR-50 METPOPOLITAN EDISON CC"PANY THREE MILE ISLAND NUCLEAR SiATICN, UNIT NO. 1 00CKET NO. 50-289 Introduction In a letter from G. Lear, dated Cecc'ber 6, 1974, NRC r.wuested Metropolitan Edicon Cc, pany to st! ait an ipplication for a license rend:ent to change the Technical Specifications related to installed filter systems so as to be in conformance with model Technical Specifications on air treatment systems considered in the accident analyses.

By letters dated January 30, 1975 and October 28, 1975, l'etrcpolitan Edison Company prcposed changes to Appendix A of the Facility Operating License CFR-50 for the Three "ile Islind "uclear Station, Unit No. 1.

These chinges included new Technical 4:cifications for the emergency control recm, re actor building purge, and auxiliary and fuel handling exhaust air treatment systems within new Section 3.15, entitled Air Treatment Systems; revised surveillance requirements for these three systems in Section 4.12, retitled Air Treatment Systems, replacing Section 4.12 and d3leting Coction 4.14 of the existing Technical Specificaticns; and necessary changes to the index and Table 4.2-1.

The changes proposed in the January 30, 1975 letter are superceded by the changes proposcd in the October 28, 1975 letter.

The preposed change would modify the limiting conditions of operation and the surveillance requirements in the Technical Specifications for the engineered safety features (ESF) ventilation filter systems at Three Mile Island "oclear Station, Unit No.

1.

Evaluation We have reviewed and evaluated the proposed changes to the Technical Specifica-tions for the Three Mile Island Nuclear Station, Unit No. 1, as submitted by the licensee in his October 28, 1975 letter.

For our evaluation we used model Technical Specifications as applicable to each engineered safety feature (ESF) ventilation filter system.

At the Three Mile Island Nuclear Station, Unit No.

1, the ESi filter systems are the emergency control room air treatment system, the reactor building purge air treatment system, and the auxiliary and fuel hand!ing exhaust air treatment system which are described in the staf f's Safety Evaluation report, June 1973.

Since the proposed change was submitted, October 28, 1975, we and the licensee have recommended clarification and edit changes, and agreement was reached by negotiations with the licensee's repre-sentatives.

These changes are included in the Technical Specifications as written.

In Sectiv 3,15.1, it was intended that the emergency control room air treatment system be operated when the reactor is operating and when irradiated fuel handling operations are in progress and that such operations be terminated in

-MM gnaw:

e

2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when-ver the redundant emergency control roca air treatment system is inoperative or whenever either system is inoperative for more than 7 days.

The licensee provided clarification to Specifications 3.15.1.1, 3.15.1.3, 3.15.i.4 and the bases which we find to be acceptable and these changes are included in the Technical Specifications as written.

In Section 3.15.2, the licensee intends to perform the DOP and halogenated bydrocarbon test on the reactor building purge air tr;atment system at the Tavimum available flow considering physical restrictions, i.e., purge valve position, and gaseous radioactive release criteria.

The flow through the

' urge air treatment system is '.ariable frcm 0 to 50,000 cfm since a cakeup air duper is located between the filter bank and the 50,000 cfm fan.

The interim fix on containment purge butterfly vahes of limiting the valve to be no rore than 30 to 50 upen and the containment radioactivity level will limit the ficw through the filter bank.

Cper3 tion of the filter system at maximum available flov during in place testing is aceptable.

In Specification 3.15.3.1, it was intended that the auxiliary and fuel handling exhaust air treatment system be eperated whenever irradiated fuel is in the storage pool.

The licensee provided proposed clarification to Specification 3.15.3.1 which we find acceptable and this change is included in the Technical Specific 3tions as written.

The licensee has comitted to modify the high ef ficiency particulate air (HEPA) filter and chartcal adsorbers on the t".ree air treatment systoms to r.cet the guidelines of Regulatory Guide 1.52 (Rev. 2), " Design, Testing and "aintenance Criteria for Post-Accident Engineered-safety-Feature Atr.ospheric Cleanup System Air Filtration and Adsorption Units of Light-l.'ater-Cooled Nuclear Power Plants," March 19 R These moaifications and the initial testing requirements for the installed HEPA filter and charcoal adsorbers hu e been reviewed by the staff and the Technical Specifications 3.15.1, 3.15.2 and 3.15.3 have been changed to reflect the licensee's ccamitment.

In s peci fications 3.15.1. 2a, 3.15. 2.2a and 3.15. 3. 2a, the penetration limit of < l%

for D07 and halogenated hydrocarbon tests has been raduced to <0.05% in agreeTent with Regulatory Guide 1.52 (Rev. 2).

The modifications to the housings will permit air distribution tests to be perforned across the HEPA filters bank and c7ples of charcoal adsorber to be raioved for lloratory testing as addressed in the surveillance Specifications 4.12.1, 4.12.2 and 4.12.3 in agreement with Regulatory Guide 1.52 (Rev. 2).

In addition, agreement was made that testing and sample analysis would be conducted following conditions that could contaminate the HEPA filters or charcoal filters and that tests be performed af ter maintenance on the system housing that could af fect bypass leakage.

The licensee provided proposed clarification to Specifications 4.12.1.2, 4.12.2.2 and 4.12.3.2 which we find acceptable and this change is included in the Technical Specifications as written.

In Specifications 4.12.1.1, 4.12.1.3, 4.12.2.1 and 4.12.3.1, we recc m nced a minimum interval of 18 months for demonstrating operability.

By negotiation, the licensee agreed to add the phrase "or once every 18 months, whichever

. ccmes first" follcwing "ref t.el i ng interval. " We find this change for clarifica-tion accept 3ble ind included the phrase in the appropriate fechnical Specifica-tions as written.

The liconsee has rwoested that the f an numbers "AN-lSA and ISB" in Specification 3.15.1.2c be replaced by "AH-E18A and 8," and that the filter nu;t;ers " AH-E3A and B" in the Cases for Speci fications 3.15.1 be replaced by "AH-F3A and B".

These proposed changes are to correct typographical errors.

We conclude the proposed edit changes are acceptable, and included the changes in the Technical Specificatinns as written.

Based on our re<uw,

..e al;o conclude that the proposed ch anges as written agree with the re;uirr.ents of our model Technical Specifications for ESF ventilation filter systnas for operating reactors and of Positions C.5 (in place testing criteria) ind C.6 (laboratory testing criteria for activated charcoal) of Regulatory Guide 1.52, Revision 2, " Design, Testing and Maintenance Criteria for Post Accident Engineered-Safety-Feature Ainospheric Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants."

Environmental Cansideration We have determined that the n endmonts do not authorize a change in effluent types, an increase in total ents of effluents or an increase in power level and will not result in any significant environmental impact.

Having made this determination, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and pursuant to 10 CFR 51.5(d)(4), that an envirannental inpact appraisal need not be prepared in connoction with the ircu ance of these amndments.

Conclusion We conclude, based on the consir 3 rations given above, that the proposed changes to Appendix A, Technical Specifications for Three Nile Island Nuclear Station, Unit No. 1, on the ESF ventilation filter systems are acceptable.

We also conclude that (1) because the inend. ents do not involve a significant increase in the picbability or consequences of accidents previously considered and do not involve a significant decrease in a safety margin, the amendments do not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will nct be endangered by operation in the proposed manner; and (3) such activities will be conducted in ccmpliance with the Commission's regulation and the issuance of these amendments will not be inimical to the common defense and security or to the health and Safety of the public.

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