ML20002C918

Proposed Tech Specs Sections 4.3.10 & 5.5.3 Re Boiler Feed Snubbers & Reactor Bldg Exhaust Filter Surveillance Requirements,Respectively

ML20002C918
Person / Time
Site:	Fort Saint Vrain
Issue date:	12/31/1980
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20002C917	List: ML20002C916 ML20002C918
References
NUDOCS 8101120427
Download: ML20002C918 (11)

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O ATTACle!ENT 1 PROPOSED CHANGE TO LCO 4.3.10, TABLE 4.3.10-1 AND REASON FOR CHANGE

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- 4.3-11 D)i'lD 9 ]D 3~

cJduM cJM JD..' ea AIII 4.3.10-1 (centi =uedl CLASS I ETDRAI'IC SNUE3 IRS (continuedl .

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_3eiler Teed Scubbers Genere.ters i

3?S-32-1 375-32-4 3T5-31-1 3 FS-31-4 375-31-5 3FS-32-2 375-32-5 3?S-31-2 3?S-32-6 375-11-3 3FS-31-6 375-32-3 3 oiler 7eed Snubbers

'rS-326 375-577 375-54 3 FS-49 '

3FS-328 375-614 3FS-133 . 3FS-422 375-425 3FS-529 375-641 3?S-129 3FS-679 3F5-142 375-434-1 3?S-530 3FS-149 3'?S-434-2 3FS-532 3.75-711 3 FERN 34-3 375-534 , 375-763 3 FS-152 375-764 375-153 375-435 3FS-536 3FS-337 373-796 37S-297 375-437 375-451 3?S-55}-1 3FS-520 375- 352 375-823 173-397 3FS-477 3FS-55 3-2 375-479 375-556 3?S-824 3FS-398 375-843 375-400 3FS-498 375-563 3FS-500 375-564 3?S-844 l 375-402 375-870 l 375-412 375-501 3FS-565 375 's16 375-572 3?S-871 ,

375-416 BFS-166 3FS-420 375-523 375-573 l 3eiler Teed $=ubbers - I=ertene-l 3?S-89I 3FS-219I 375-399I 3FS-14I 3?S-405I STS-ISI 3?S-122I 3FS-223I 3?S-141I 3?S-229I 375-414I 3?S-16I 3?S-417I 3FS-26I 3?S-142I 3FS-243I 375-143I 3FS-244I 3?S-419I 3FS-29I 3FS-421I c

375-20I 3FS-15EI 2PS-245I 375-167I 3FS-257I 3FS-422I s' 3?S-31I 3?S-423I 3FS-47I 175-181I 375-260I 375-197I 3?S-263I 3?S-430I 3?S-53I 3FS-431I 375-56I 3FS-203I 3FS-264I 3?S-26EI 3FS-4 32I 3FS-57I 3?S-204I 375-210I ., 3?S-269I 3FS-442I 3FS- 74I 3?S-444I 3FS-762 3?S-216I 3?S-21&I 375-39SI BFSr154E i 375-77I

REASON FOR CHANGE Audit program f or 2 1/2" and larger piping has identified BFS-166 and BFS-154E, which are located on Class I piping as defined by SR 6-1, but not included in Table 4.3.10-1. Snubbers were apparently omitted f rom the list of Class I snubbers due to an oversight on the part of personnel who per-formed *he initial analysis of piping supports. This change corrects that error and fulfills the requirements of LCO 4.3.10(e).

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l ATTACIDfENT 2 l PROPOSED CHANGE TO SR 5.5.3a)

AND BASIS AND REASON FOR CHANGE i

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Fort St. Vrain #1 Technical Specifications Amendment Page 5.5-3 Basis for Specification SR 5.5.2 The reactor building pressure relief device is designed to protect the building in the event that pressure in the Reactor Building exceeds the turbine building pressure by 3 inches of water. The device consists of louvers installed in a number of individual modules operated by mechanical linkages to pneumatic actuators (see FSAR Section 6.1.3.4). The specified test frequency shall ensure the operability of the reactor building relief system.

Specification SR 5.5.3 - Reactor Building Exhaust Filters, Surveillance The exhaust filters in the reactor building ventilation system shall be tested as follows:

a) A laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shall be perfor=ed af ter each 4400 hours0.0509 days <br />1.222 hours <br />0.00728 weeks <br />0.00167 months <br /> of operation of the unit, or following painting, fire, or chemical

• release in any ventilation zone communicating with the unit. The results of laboratory carbon sample analysis from the unit shall show > 90% radioactive methyl iodide removed when tested in ac-cordance with ANSI N510-1975 (130*C, 95% R.H.).

• Defined as any material which could reasonably be expected to interfere with the charcoal to adsorb methyl iodide.

Fort St. Vrain #1 Technical Specifications Amendmert Page 5.5-4 b) A halogenated hydrocarbon test shall be performed once per calendar year or af ter each replacement of a charcoal adsorber bank or af ter structural maintenance on the filter housing. Halogenated hydro- '

carbon re= oval by the charcoal filters shall be 2; 99% when conducted

at normal flow conditions in accordance with the applicable portions of ANSI N510-1975.

c) The HEPA filters shall be leak tested in place once per calendar year, af ter each complete or partial replacement of a HEPA filter bank, or af ter any structural =aintenance on the filter housing, using cold DOP. Cold DOP re= oval by the HEPA filters shall be 2; 99% when tested in cccordance with the applicable portions of ANSI N510-1975.

d) Flow distribution across the HEPA and charcoal filters will be ,

tested with initial operation of the systen and following any struc-

tural modification to the filter housings. Air distribution shall be demonstrated within j- 20% across the HEPA and charcoal filters when tested in accordance with ANSI N510-1973.

e) Total pressure drop across the combined HEPA filter and charcoal adsorber banks shall be less than 6" 2H O at filter design ficw

- 10%.

Fort St. Vrain 11 Technical Specifications Amendment Page 5.5-5 Basis for Specification SR 5.5.3 The reactor building exhaust filter system is designed to filter the reactor building atmosphere prior to release to the facility vent stack during both normal and accident conditions of operation. The system consists of three 50* capacity units, two of which are in continuous operation, with the third on c:andby.

High ef ficiency particulate air (HEPA) filters at a installed bef ore the char-coal adsorbers to remove particulate =atter f rom the air stream to prevent clogging of the iodine adsorbers. The charcoal adsorbers are installed to reduce the potential release of radiciodine to the atmosphere. Bypass leakage for the charcoal adsorbers and particulate removal efficiency for HEPA fil-ters are determined by halogenated hydrocarbon and DOP respectively. The laboratory carbon sa=ple test results indicate a radioactive methyl iodide removal efficiency f or expected accident conditions. The surveillance tast frequencies specified establishes system performance capabilities. If system i

conditions are specified, the calculated doses will be less than the guide-l l

lines stated in 10 CFR 100 for the accidents analyzed, as indicated in Sec-tions 14.8 and 14.12 of the FSAR. Pressure drop acrcss the combined HEPA fil-ter and charcoal adsorber of less than 6 inches of water at the filter de-sign flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign =atter.

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. . Fort St. Vrain #1 Technical Specifications Amendment Page 5.5-6 e

The activated carbon adsorber in the affected unit should be replaced if a representative sample f ails to pass the iodine removal efficiency test. Any HEPA filters found defective should be replaced.

i If painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated f rom the fumes, chemicals, or f oreign materials, the same tests and sample analysis should be perf ormed, l as required, for operational surveillance.

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REASON FOR CHr'GE Public Service Co=pany Change Notice No. 868 added external carbon sample canisters across the charcoal adsorbers in the reactor building ventilation system exhaust filters to allow pertadit aegih g of charcoal effectiveness without affecting the integrity of th>i acaetoer beds.

This change reflects the NRC staff practice described in Regulatory Guide 1.52, i Revision 2, March 1978 l

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4 STATE OF COLORADO )

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CITY AND COUNTY OF DENVER)

O. R. Lee, being first duly sworn, deposes and says; That he is Vice President of Production of Public Service

! Company of Colorado, the Licensee herein; that he has read the f oregoing Application for Amendment to Appendix A of Facility Operating License and knows the contents thereof, and that the statements and matters set forth therein are true and correct to the best of his knowledge, inf ormation and belief.

S/0. R. Lee O. R. Lee Subscribed and sworn to before me this day of Witness my hand and official seal.

My commission expires: .

i Notary Public

BEFmE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of the Facility Operating License)

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of ) Docket No. 50-267

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PUBLIC SERVICE COMPANY OF COLORADO )

Application for Amendment to Appendix A of Facility Operating License License No. DPR-34 0F THE PUBLIC SERVICE COMPANY OF COLORADO FOR THE FORT ST. VRAIN NUCLEAR GENERATING STATION This application for Amendment to Appendix A of Facility Operating License, License No. DPR-34, is submitted for NRC review and approval.

Respectfully submitted, PUBLIC SERVICE COMPANY OF COLORADO By S/0. R. Lee O. R. Lee, Vice President

. KELLY, STANSFiEID & 0'DONNELL Bryant O'Donnell Robert E. Thompson Public Service Company Building Denver, Colorado 80202 Attorneys for Applicant