ML20034B734

Proposed Tech Specs Re Limiting Condition for Operation & Surveillance Requirements for Annulus Ventilation Sys

ML20034B734
Person / Time
Site:	Catawba
Issue date:	04/23/1990
From:	DUKE POWER CO.
To:
Shared Package
ML20034B733	List: ML20034B732 ML20034B734
References
NUDOCS 9004300266
Download: ML20034B734 (7)

Text

_-

n CONTAINMENT SYSTEMS ANNULUS VENTILATION SYSTEM:

LIMITING CON 0! TION FOR OPERATION 3.6.1.8 Two independent Annulus Ventilation Systems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With one Annulus Ventilation System > inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS

4. 6.1. 8 Each Annulus Ventilation System shall be' demonstrated OPERABLE:-

a.

At least once per 31 days on a STAGGERED TEST. BASIS by initiating,-

8 from the control room, flow through the HEPA_ filters and-activated carbon adsorbers and verifying that the system' operates for at least l

10 continuous hours with the pre-heaters operating; b.

At least once per 18 months or (1) af ter any structural maintenance on the HEPA filter or activated carbon adsorber housings, or (2) fol-I lowing painting, fire, or chemical release in any. ventilation zone communicating with the system by:

1)

Verifying that the cleanup system satisfies the in place pene-tration and bypass leakage testing acceptance criteria of less than 1% (Unit 1), 0.05% (Unit 2) and uses the. test procedure guidance in Regulatory Positions C.S.a C.S.c, and C.S.d* of Regulatory Guide 1.52, Revision 2,' March 1978, and the system flow rate is 9000 cfm i 10%;

2)

Verifying, within 31 days after removal, that a. laboratory-analysis of a representative activated carbon sample obtained l

in accordance with Regulatory Position C.6.b of Regulatory-Guide 1.52, Revision 2, March 1978, meets the' laboratory testing criteria of R:gul:t:ry P :ition C.S.: Of R:gul:t:ry Cuid: 1.52, Ra isien 2, " rch 107 % for a methyl iodide penetration of less than M, and IA5Trq D3BoS-1bj T~est m.e.%ed Y o.7t*/o 3)

Verifying a system flow rate of 9000 cfm i 10% during system operation when tested in accordance with ANSI N510-1980.

J

• The requirement for reducing refrigerant concentration to 0.01 ppm may be satisfied by operating the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with heaters on and operating.

CATAWBA - UNITS 1 & 2 3/4 6-14 Amendment No. 37 (Unit 1) 9004300266 900423 Amendment No. 29 (Unit 2)

PDR ADOCK 05000413 P

PDC

c CONTAINMENT SYSTEMS-SURVEILLANCE' REQUIREMENTS (Continued) c.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of activated carbon-adsorber operation, by

'l verifying within 31 days after removal, that a laboratory analysis.

of a-representative activated carbon sample obtained in accordance-l' with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria-of "c; m tery Peet-4ien C.L a-;f hgeletery Ouide 1.50, iievi ive 2, " erd 1978 for.a methyl iodide penetration of less tha g

g d.

At least once per 18 months by:

TCst Mt McfRI'.

1)

Verifying that the pressure drop across the combined HEPA fil-ters, activated carbon adsorber banks, and moisture separators,

l.-

is less than 8 inches Water Gauge while' operating tho' system -

at a flow rate of 9000 cfm i 10%;

"F ee "A" Verifying that the system starts automatically on any MFET\\/

2) 1 sci-tirtytsignal,**

kr ySg that, the' filter cooling electric motor-operated-bypass-3) valves can be manually opened, 4)

Verifying that each system produces a negative pressure of-greater than or equal to 0.5 inch Water Gauge in the annulus within l' minute after a start signal, and 5)

Verifying that the pre-heaters dissipate 45 i 6.7 kW.

e.

After each complete or partial replacement of a HEPA filter bank,. by verifying that the cleanup system satisfies the in place penetra-tion and bypass leakage testing acceptance criteria of less than 1%

(Unit 1), 0.05% (Unit 2)'in accordance with ANSI-N510-1980 for a 00P test aerosol while operating the system at a ' flow rate of.9000 cfm i 10%; and f.

After each complete or partial replacement of an activated carbon l

adsorber bank, by verifying that the cleanup system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% (Unit 1), 0.05% (Unit 2) in'accordance with ANSI H510-1980 for a halogenated hydrocarbon refrigerant-test gas while operating the system at a flow rate of 9000 cfm i 10%.

• • This surveillance need not be performed until prior to entering HOT SHUTDOWN following the Unit 1 first refueling.

I CATAWBA - UNITS 1 & 2 3/4 6-15 Amendment No.37(Unit 1)

Amendment No.29(Unit 2)

)

' k.W

..--.f:$

ONTAINMENT SYSTEMS ddb BASES

~ ' ph

'l S

tv o 3,9 P/4.6.1.8 ANNULUS VENTILATION SYSTEM

g

.sgy 9

The OPERABILITY-of the Annulus Ventilation System ensures that during LOCA L~

onditions, containment vessel leakage into the' annulus'will be filtered through v0 ;he HEPA filters and activatedcarbon adsorber trains prior to discharge to the.

l-g C S ]E J.itmosphere.

o'g Operation of the system with the heaters operating to maintain low

,c humidity using automatic control for at least-10 continuous hours in a 31-day

-p b b p period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA N

N 4

w. - Efilters.

This requirement is necessary to meet the assumptions used 'in the safety 4

Q )'*b ^

~C analyses and limit the SITE BOUNDARY radiation doses.to-within the dose' guide-1ine values of 10 CFR Part 100 during LOCA conditions.

ANSI N510-1980 will be 9.

> h psed as a procedural guide for surveillance. testing.7 JdGC w

/4.6.1.9 CONTAINMENT PURGE SYSTEMS

'.y The containment purge supply and exhaust isolation valves.for the lower de-d :ompartment and the upper compartment (24-inch).and instrument room (12-inch),

7' Oo t, I

-f nnd the Hydrogen Purge System (4-inch) are required to be~ sealed closed during m y) h.c$ slant operation since these valves have not been demonstrated capable of closing 0

O yg1 during a LOCA.

Maintaining these valves sealed closed during plant operations P

N ansures that excessive quantities of radioactive materials will not be released O % *C w w 0

d via the Containment Purge System.

To provide assurance that these containment Fcralves cannot be. inadvertently opened, the valves are sealed closed in accord-

].3.-

o?ance with Standard Review Plan 6.2.4 which includes mechanical' devices to seal i

.2 6' mr lock the valve closed, or prevents power from being_ supplied.to the valve gG-p[>Qperator.

0 m

C.1 The use of the containment purge lines-is restricted to the 4-inch Con :

tainment Air Release and Addition System valves since, unlike the lower compart-ment and the upper compartment, instrument room, and the Hydrogen Purge System valves, these 4-inch valves are capable of closing during a LOCA.

Therefore, the SITE BOUNDARY dose guideline values of 10 CFR Part 100 would not be exceeded in the event of an accident during containment purging operation. Operation with the line open will be limited to 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> during a calendar year for the I

4-inch valves.

The total time the containment purge (vent) system isolation j

valves may be open during MODES 1, 2, 3, and 4 in a calendar year is a function of anticipated need and operating experience.

Only safety-related reasons; e.g., containment pressure control or the reduction of airborne radioactivity i

to facilitate personnel access for surveillance and maintenance activities, may L

be used to justify the opening of these isolation valves.

l-Leakage integrity tests with a maximum allowable leakage rate for contain-ment purge supply and exhaust valves will provide early indication of resilient material seal dagradation and will allow opportunity for repair before gross leakage failures could develop; The 0.60 L, leakage limit of Specification 3.6.1.2b. shall not be exceeded when the leakage rates determined by the leakage integrity tests of these valves are added to the previously determined total for all valves and penetrations subject to Type B and C tests.

CATAWBA - UNITS 1 & 2 B 3/4 6-3 Amendment No. 37 (Unit 1)

Amendment No. 29 (Unit 2) i 4

maggy,,- r,n

~c n nn,,

nn, -,~_,__,,,

,,,.g.__

,_g,,,_.,

d 3

4

-a

)

f 1

i

-.e

- a 2

0 t

?t 1

L l

1 9

t-

)

4 a

t]

1 s

1 ea

'l ATTACHMENT II-

-u 1

1 Y

Y

- t

.e F

l,

\\

1 4r 1

{

I t

i Y

vt 4

h s

i

?

. fi

?

' f.

.?

q-t E[

1 F

.$:e

.f

i TECHNICAL SPECIFICATION CHANGE REQUEST Proposed Technical Specification Amendment 1

This Technical Specification (TS) change request will change TS14.6.1,8.b.2 and 4.6.1.8.c.

to read "... meets the laboratory testing criteria'of ASTM D3803-86, Test Method "A" for a methyl ~ iodide penetration of less than-0.71%."

The TS Bases for TS 4.6.1.8 are modified to. reflect the above

~

test criteria.

Revising the carbon adsorber test method will assure that the Annulus Ventilation filters have a decontamination efficiency of greater than or equal to 95% under all anticipated operating modes, l

This proposed TS change also contains a revision to' TS Surveillance:

4.6.1.8.d.2.

This Surveillance is changed to read, " Verifying that-the system starts on any SAFETY INJECTION test. signal".

This change is made-because the surveillance currently states-that the system should start automatically on any Phase "A" Isolation test signal.

Discussion During the HVAC Review currently in progress at Catawba Nuclear Station it was discovered that the Safety-Related Annulus Ventilation. System Heaters i

were not conservatively sized for all postulated operating modes.-

During low voltage conditions sufficient power is not supplied to the Annulus Ventilation Heaters for them to maintain the relative humidity of the air entering the Annulus Ventilation System Below 70%.

The Electrical Distribution System at Catawba can be powered from either.offsite power or the Safety-Related Diesel Generators.

Station-Technical Specifications allow the Diesel Generators to. operate at 4160 VAC 1 420 VAC and offsite power to drop under degraded bus conditions to approximately 3685 VAC. The minimum calculated voltage supplied to the-Annulus Ventilation Heaters was conservatively calculated to be 541.18 l

VAC.

l The design basis of the Annulus Ventilation System Heaters is to ensure that the relative humidity of the air entering the Annulus Ventilation System carbon adsorber beds lis less than-70% relative humidity.

Under low voltage conditions, with the maximum TS allowed Annulus Ventilation' flow rate of 9900 cfm the relative humidity of the air entering the carbon adsorber beds was calculated to be approximately 74%.

In order to satisfy the design basis maximum relative humidity of 70% the maximum allowed Annulus Ventilation flow rate has been limited to less than 8700 cfm.

With a restricted upper limit of 8700 cfm and a lower limit required per TS of 8100 cfm, an unnecessarily restrictive operating margin is placed on the system.

TS 4.6.1.8.d.2 is also corrected to reflect the fact that the Annulus Ventilation System Starts automatically on a Safety Injection signal, not l

a Phase "A" Isolation signal.

i l

e Technical Justification This proposed amendment to TS will change the carbon adsorber-test method to ensure'that the Annulus ventilation filters have a decontamination efficiency'of greater than or equal to 95% under all anticipated operating conditions. The maximum expected relative humidity under the worst case of highest flow and lowest voltage is 74%.

The laboratory test of carbon samples will be'_ conservatively tested at 95% relative humidity, instead of the 70% which is currently: required.

Changing the allowable penetration for the carbon beds to 0.71% instead of 1% raises the safety factor of the Annulus Ventilation System.

Using the methodology of Regulatory Guide 1.52, Revision 2, March 1978, changing the allowable methyl _ iodide _

penetration to 0.71% ensures that the Decontamination Factor of 95% that--

is assumed in the existing Catawba FSAR, Oose Analysis for-the Annulus Ventilation System, is met.

Using the laboratory test method outlined in ASTM 03803-86, Test Method "A" adds further conservatism.

For the reasons f

described above, this change will conservatively ensure'that calculated offsite and onsite doses are not_ adversely affected while_ allowing the 9000'cfm +10% Annulus Ventilation flow rate, Changing the TS Surveillance 4.6.1.8.d.2 is needed to correct the starting signal for the system.

The Annulus Ventilation System does not start in response to a Phase "A" Isolation. The system is started by the D/G Load

. Sequencer in response to a Safety Injection signal. The Annulus Ventilation System will not start on a Manual Phase "A" Isolation.

- Technical Specification Table 3.3-3 correctly identifies Safety Injection as the initiating signal.

No Significant Hazards Analysis 10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation accordance with the proposed amendment would not:

1) Involve a significant increase in the probability or consequences of an i

accident previously evaluated; or

2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) Involve a significant reduction in the margin of safety.

This proposed TS amendment will not increase the probability or consequences of an accident which has been previously evaluated. Offsite and onsite doses will remain the same because of the added conservatism in the laboratory test method and the penetration factor.

This change will be in accordance with the decontamination factor which'is assumed in the FSAR Chapter 15 Analysis. This change will also make the TS correctly reflect the initiating signal for an automatic start of the Annulus l

Ventilation System.

l This proposed TS amendment will not create the possibility of a new or l

different kind of accident from any accident previously evaluated.

This l

change makes no physical changes to the plant or operating procedures, l

because of this no new or different accidents are created.

LThis proposed TS amendment does not involve'a_significant decrease inLthe margin'of-safety.

This change makes no physical changesEto the plant or operating procedures.

Changing the allowable penetration of the carbon beds to-0.71% raises the safety factor of_the annulus ventilation' system.

This ensures that the current FSAR Chapter 15 analysis for the Annulus Ventilation System is not affected, and that the existing decontamination factor, 95%, can be used. Because.the decontamination factor is the same no revision to the On or Offsite Dose analysis is required and therefore the margin between the current dose analysis and 10 CFR 100 is not affected.

I This proposed amendment also corrects the TS to reflect thatLa Safety Injection Signal is the initiating signal for an automatic start of the-Annulus Ventilation System.

Environmental Impact Statement The proposed' Technical Specification change has been reviewed against the t

criteria of 10 CFR 51.22 for environmental considerations. 'As shown above, the proposed' change does not involve significant hazards considerations, nor increase individual or cumulative occupational radiation exposure.

Based on this, the proposed amendment meets the criteria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirements for an Environmental Impact Statement.

(

,.. -