ML19296B038

Tech Spec Change Request 58.Moves Surveillance Requirement for Testing of High Radiation Initiation of Control Room Emergency Vent Sys from Spec 3/4.7.7.1 to Spec 3/4.3.3.1. Tech Spec Pages Encl

ML19296B038
Person / Time
Site:	Crystal River
Issue date:	02/15/1980
From:	FLORIDA POWER CORP.
To:
Shared Package
ML19296B035	List: ML19296B034 ML19296B038
References
TAC-46970, NUDOCS 8002190734
Download: ML19296B038 (5)

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Technical Specification Change Request No._58 (Appendix A)

Replace pages 3/4 3-23, 3/4 3-24, 3/4 3-25, and 3/4 7-21 with the attached revised pages 3/4 3-23, 3/4 3-24, 3/4 3-25, and 3/4 7-21.

Proposed Change This change will move the surveillance requirement for testing the hign ra-diation initiation of the control room emergency ventilation system from Specification 3/4.7.7.1 to Specification 3/4.3.3.1.

Reason for Proposed Change Specification 4.7.7.1.e.2 presently requires the control room emergency ventilation system to automatically switch into a recirculation mode of op-eration with either an ESFAS test signal or a high radiation test signal.

In ordec to comply with the high radiation portion of this specification, RM-A5 must be operable. There is no redundancy built into RM-AS. There-fore, each time RM-A5 f ails both ventilation systems should technically be declared inoperable, since we cannot meet the surveillance requirements unich demonst' rate system operability. This will envoke the requirements of Specification 3.0.3 which dictates a one-hour shutdown.

This surveillance requirement is poorly structured to fit the requirements of system operability. Failure of the systems' ability to automatically shift to recirculation upon a high radiation test signal does not conpromise the system operability, especially if the system is manually placed in the recirculation mode when the automatic function is deactivated. The system will still circulate, filter, and cool the air in the control room.

What we are really addressing in this specification is the function of a process radiation monitor. Therefore, the surveillance requirements of RM-A5 would be more appropriately located under Specification 3.3.3.1, Radiation Monitoring Instrumentation. By this action, the interlock functions of RM-A5 will be properly addressed and tested, and the appropriate action taken upon a f ailure. These changes are consistent with the Babcock and Wilcox Standard Technical Specifications, Rev. 3, July 1979 (page 3/4 3-26, 3-27, and 7-16) as well.

Safety Analysis of Proposed Change There are no additional safety concerns involved with these changes. The control complex emergency ventilation system will be adec,uately tested so that it will perform its intended function. Additionally, the operability of RM-A5 will be tested such that it will provide the interlock function to the control complex ventilation system when required. Therefore, both systems will function as designed and no unreviewed safety question is involved.

TSCRh58(DN-93) 800219073%

TABLE 3.3-6 9

g RADIAT10ti MUNITORIf4G liiSTRUMElil AT10t4 5

r- MINIMUM

$ CHAtitlE LS APPLICABLE ALARM / TRIP MEASURLMENT INSTRUMEliT SETPOINT ACTION g OPERABLE MODES RANGE

' l. AREA MONITORS E

q a. Fuel Storage Pool Area m i. Criticality Monitor 1 $15 mr/hr 10 104 mr/hr 14

2. PROCESS M0lilTORS

a. Fuel Storage Pool Area

i. Gaseous Activity -

w Ventilation 3 System Isolation 1

• • 12 x background 101 - 106cpm 16

[ b. Reactor Building w i. Gaseous Activity -

a) Purge Exhaust Duct isolation 1 6 101 - 103cpm 17 b) RCS Leakage Detection 1 1, 2, 3 a 4 flot Applicable 101 - 100cpm 15 ti. Iodine Activity -

RCS Leakage Detection 1 1, 2, 3 a 4 Not Applicable 101 - 100 cpm 15

c. Control Room

i. Iodine Activity -

Ventilation System Isolation /

Recirculation 1 All Modes 12 x background 101 - 106cpm 18

• With fuel in the storage pool or building

• • With irradiated fuel in the storage pool

• • • Determined by requirements of Appendix "B", Tech. Specs., Section 2.4.2 - Crystal River 3 Operating License No. DPR-72.

TABLE 3.3-6 (Continued)

TABLE NOTATION ACTION 14 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

ACTION 15 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the action requirements of Specification 3.4.6.1.

ACTI0tl 16 - With the number of channels OPERABLE less thar, required by the Minimum Channels OPERABLE requirement, comply with the ACTION requir ements of Specification 3.9.12.

ACTION 17 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTI0fi requirements of Specification 3.9.9.

ACTION 18 - With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control roan emergency ventilation system in the recirculation mode of operation.

CRYSTAL RIVER - UNIT 3 3/4 3-24

~.

TABLE 4.3-3 9

iy, RADIATIOfl MONITORING INSTRUMEf4 TAT 10N SURVEILLANCE REQUIREMEf4TS C

r-CHANilEl MUDLS IN WillCli

$ CitANNEL CilANNEL FUfiCTIONAL SURVEILLANCE g If4STRUMENT CitECK CALIBRATION TEST REQUIRED

l. AREA MONITORS E *

1 a. Fuel Storage Pool Area w i. Criticality Monitor S R M

2. PROCESS MONITORS

a. Fuel Storage Pool Area

i. Gaseous Activity -

w Ventilation **

2 System Isolation S R M w

a b. Reactor Building ,

• i. Gaseous Activity -

a) Purge Exhaust .

Duct Isolation S Q M 6 b) RCS Leakage Detection S R M 1, 2, 3, a 4 ii. Iodi ne Activi ty -

RCS Leakage Detection S R M 1, 2, 3, a 4

c. Control Room

i. Iodine Activity -

Ventilation System Isolation /

Recirculation S R M All Modes

• With fuel in the storage pool or building

• • With irradiated fuel in the storage pool

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying that, with the system operatino at a flow rate of 43,500 cfm +10%, and exhausting through the HEPA filters and charcoal adsorbers, the total bypass flow of the system to the facility vent, including leakage through the system di-verting valves, is 11% when the system is tested by admit-ting cold DOP at the system intake.

2. Verifying that the ventilation system satisfies the in-place testing acceptance criteria, and uses the test procedures of Regulatory Positions C.S.a, C.5.c*, and C.S.d* of Regulatory Guide 1.52, Revision 1, July 1976, and the system flow rate is 43,500 cfm 1.10%.

3. Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample, obtained in ac-cordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 1976, meets the laboratory testing criteria of Regulatory Position C.6.1 of Regulatory Guide 1.52, Revision 1, July 1976.

4. Verifying a system flow rate of 43,500 cfm 110% during sys-tem operation, when tested in accordance L;th ANSI N10-1975.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal absorber operation, by verify-ing, within 31 days after removal, that a laboratory analysis of a representative carbon sample, obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 1976, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1, July 1976.

e. At least once per 18 months, by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is <6 inches Water Gauge while operating the system at a flow rate of 43,500 cfm 1.10%.

2. Verifying that on a containment isolation test signal, the l system automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks.

CRYSTAL RIVER - UNIT 3 3/4 7-21