ML20072S750

Proposed Tech Specs 3.6.1.8,3.7.6,3.9.11 & 3.7.7 Re Carbon Adsorber Test Method & Methyl Iodide Penetration Criteria

ML20072S750
Person / Time
Site:	Catawba
Issue date:	04/08/1991
From:	DUKE POWER CO.
To:
Shared Package
ML20072S749	List: ML20072S745 ML20072S750
References
NUDOCS 9104170031
Download: ML20072S750 (30)

Text

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9104170031 910A08 PDR ADOCK 05000413 P PDR _

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PLANT SYSTEMS co n .

g.C C 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM

.o LIMITING CONDITION FOR OPERATION L 1 o ed v .

• C 3.7.6 Two independent Control Room Area Ventilation Systems shall be de OPERABLE.

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{ CE APPLICABILITYi ALL MODES e 2O s ACTION: (Units 1 and 2) 3 ug N. \

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,C+g[ MODES 1, 2, 3 and 4: e -

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.Se c reasey33 qW e( N n 4h e.

be 4 es M ct s n 4 .'). ..b anid g3%glg q. ith one Control Room Area Ventilation ystem restore he 7. 6.e. 4 g G inoperable system to OPERABLE status within 7 days or b in at least HOT g b..e i STANDBY 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 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

.$ 5 nd 6:

pf]gM0 o,

.W reasons c4be r 4w m +h e.

heohe rs + eskeA_i n 4. ?.b .b a ncI e o g} _ o j a. With one Control Room Area Ventilation system inoperablgf, restore

.s the inoperable system to OPERABLE status within 7 days or initiate -

C' t* (C<y 0UCe C, D ' .

and maintain operation of the remainin OPERABLE Control Room Ventilation System. o r reaso n dhei \ % 4h e-7 ohd I

$ o o cj$ b. hea&c c5 +es4 ed 3 n 4 Me.b and WithbothControlRoomAreaVentilationsystemsinoperab1(,orwithh.l.lo.e.$

4to o +- the OPERABLE Control Room Area Ventilation System, required to be Qu

_c d 4 N operating by ACTION a. , not capable of being powered by an OPERABLE

"+Ch $ t-emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

+ 0 da d f c. The provisions of Specification 3.0.4 are not applicable.

]N+ 00:' C O 5 ok '

Y f.p- % SURVEILLANCE REQUIREMENTS _

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4. c C C 4.7.6' Each Control Room Area Ventilation System shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 90'F;

. b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the' control room, flow through the HEPA-filters and activated carbon adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters operating; CATAWBA - UNITS 1 & 2 3/4 7-14 gty

.- -o, a

. PLANT $YSTOLS SURVE!LLANCE REQUIREMENTS (Continued) i

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

1)' Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Position C.5.a. C.S.c. and C.5.d* of Regulatory Guide 1.52, Revisions 2. March 1978, and the system flow rate is 6000 cfm i 10%;

2) ' Verifying, within 31 days after removal, that a laboratory analysis of a representative activated carbon sample obtained

'in accordance with Regulatory Position C 6.b of Regulatory anel NM # cuide P 1.52. Revision 2. March 1978=t: t e h e r:::r; seesta ,.

A5Tm 038D3'-81 erit ru of 5;eleterj_ Phi p= E4 cf ":e;ht:ri Gttide-1M, S;hS: 2, enetration of'less 4 than0.17p,"and :rch 1070g%gaethyl (685 ) lio L

ide 9

3) Verifying a system (T5W~7 ate of 6000 cfm + 10% during system operation when tested in accordance with-KNSI-N510 1980.

d.- ' After every 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> of activated carbon adsorber operation, by verifying, within 31' days after removal, that a laboratory analysis **

of a representative activated carbon sample obtained in accordance 0nd 4cSted with Regulatory March 1978,q:::t: Position tM C.6.b hhr:ter;of Regulatory teet4pt-eetteric GuideOf1.52, RevisionP2,:4 Regtdeterj PEC "10: 0.5. Of 5;:Sterj S: 1. 62rAevisten-fr- - - , .. a-

i thyl iodide penetration of less than-0.1"%;

has

- e. -At 1 east once per.18_sonths by: . O.% %

~

1) LVerifying-that the pressure drop across the combined HEPA filters,

activated carbon adsorber banks,.and moisture sepsrators is less than 8 inches Water Gauge while operating the system at'a .

flow rate of 6000 cfm + 10%;

2) Verifying that'on a High Radiation-Air Intake, or Smoke Densityw High test signal, an alam is received in the control room; ,

3)- Verifying that~ the system maintains _'the' control room at a posi-tive pressure of greater than or equal:to 1/8 inch Water-Gauge relative'to adjacent areas at less-than or equal to pressuriza-tion flow of-4000 cfm to the control room during system operation;

4) Verifying that the heaters dissipate 25 t 2.5 an cd cx nom i nct vo acge 09 :

(o O L \/ A C. A

'8The-requirement.for reducing refrigerant concentration to 0.01 ppe say 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 y ef M

' 8* Activated carbon adsorber . samples are tested at 30 degree C cm %P7o R H.

CATAWBA - UNITS .; 1 & 2 - - =. 3/4 7-15. . - - _ _ . Amendment " . 05 O nit 1)

PLANT SYSTEMS-SURVEILLANCE REQUIREMENTS (Continued) 1

5) Verifying that on a High Chlorine / Toxic Gas test signal, the i system automatically isolates the affected intake from outside j air with recirculating flow through the HEPA filters and acti- i vated carbon adsorbers banks within 10 seconds (plus air travel '

time between the detectors and the isolation dampers),

f. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration  !

and bypass leakage testing acceptance criteria of less than 0.05%

in accordance with AN$1 N$10 1980 for a 00P test aerosol while operating the system at a flow rate of 6000 cfm i 10%; and

g. After each complete or partial replacement of an activated carbon adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a l halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 6000 cfm i 10%.

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I CATAWEA - UNITS 1 & 2 ^- u- 1A in 4 3/4 7 16 - -* is 6"d/ Lid ~  !

MNJfSTEMS BASES l

3/4.7.5 STANDBY NUCLEAR SERVICE WATER POND The limitations on the standby nuclear service water pond (SNSWP) level l and temperature ensure that sufficient cooling capacity is available to either:

(1) provide normal cooldown of the facility, or (2) mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to safety related equipment without exceeding its design basis temperature and is consistent with the recommend-ations of Regulatory Guide 1.27, " Ultimate Heat Sink for Nuclear Plants,"

March 1974.

The peak containment pressure analysis assumes that the Nuclear Service  !

Water (RN) flow to the Containment Spray and Component Cooling heat exchangers I has a temperature of 86.5'F. This temperature is important in that it, in part, determines the capacity for energy removal from containment. The peak i 7y i 1

containment pressure occurs when energy addition to containment (core decay ,:

heat) is balanced by energy removal from these heat exchangers. This balance ~)

is reached far out in time, after the transition from in,jection to cold leg recirculation and af ter ice melt. Because of the effectiveness of the ice bed L$'O in condensing the steam which passes through it, containment pressure is insensitive to small variations in containment spray temperature prior to ice $' o.

me1toet, c]3 To ensure that the RN temperature assumptions are niet, Lake Wylie temperature is monitored. During periods of time while Lake Wylie temperature 9b is greater than 86.5'F, the emergency procedure for transfer of ECCS flow C(o paths to cold leg recirculation directs the operator to align at least one .9, tre.in of containment spray to be cooled by a loop of Nuclear Service Water +d/

which is aligned to the SNSWP.

&9 4o 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM o, +

The OPERABILITY of the Control Room Area Ventilation System ensures that:

(1) the ambient air temperature does not exceed the allowable temperature for u&

((

0 continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel $ y during and following all credible accident conditions. Operation of the system n with at least the 10 heaters continuousoperating to maintain hours in a 31-day period islow humidity sufficient using to reduce the automatic j buildup of moisture on the adsorbers and HEPA filters. The Control Room Area 34 Ventilation System filter units have no bypass line. Either Control Room Area y Ventilation System train must operate in the filtered mode continuously, en 3L a train is in operation, its associated heater also runs continuously, The OPEkABILITY of this system in conjunction with control room design provisions M

is based on limiting the radiation exposure to personnel occupying the control room to 5 rems or less whole body, or its equivalent. This limitation is con-sistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR Part 50. ANSI N510-1980 will be used as a procedural guide for curveil-lance testing.

CATAWBA - UNITS 1 & 2 B 3/4 7-3a ^ entent Mc. %We44-1)

PLANT SYSTEMS BASES The 18-month surve111ance to verify a positive pressure of greater that 1/8 inch water gauge, with less than or equal to 4000 cfm of pressurization flow, is to be conducted using only one intake from outside air open. By testing the capability to pressurize the control room using each intake individually, the design basis which assumes reopening of the two intakes fo110 win 0 isolation on chlorine, smoke or radiation, is tested.

3/4.7.7 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM The OPffABILITY of the Auxiliary Builoing Filtered Exhaust System ensures that radioactive materials leaking from the ECCS equipment within the auxiliary building following a LOCA are filtered prior to reaching the environment.

Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The operation of this system and the. resultant effect on offsite dosage calcu-14tions was not taken credit for in the safety analyses. However, the operation of this system and the resultant effect on the NRC staff's offsite dose calcula-tions was assumed in the staff's SER, NUREG-0954. ANSI NS10-1980 will be used-as a procedural guide for surveillance testing.

3/4.7.8 SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity ,

of the Reactor Coolant System and all other safety-related systems is main-tained during and following a seismic or other event initiating dynamic loads.

Sout.bers are classified and grouped by design and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features of the 2-kip,10-kip, and 100-kip capacity manufutured by Company "A" are of the same typin. The same design mechanical snubbers manufactured by. Company "B" for.the purposes of this Technical Specification would be of a different type, as would hydraulic snubbers from either manufacturer.

A sist of individual snubbers with detailed information of snubber location and size and of system affected shall be available at-the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Catawba Safety-Review Group. The determination shall be based upon the existing radiation levels and the expected time-to per-form a vibual inspection in each snubber location as well as other factors asso-ciated with accessibility during plant operations (e.g., temperature, atmosphere, location, etc..) and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or oeletions of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

CATAWBA - UNITS 1 & 2 B 3/4 7-4 Amendment No. 78 (Unit 1)

Amendment No. 72 (Unit 2)

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V d. C -- REFUELING OPERATIONS

.O d p (N wo g 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS f %U Y 0eo3 LIMITING CONDITION FOR OPERATION  !

.9 .

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3.9.4 The containment building penetrations shall be in the following status:

a. The equipment hatch closed and held in place by a minimum of four c.0d S bolts, 9 ?00

- f g[, b. A minimum of one door in each airlock is closed, and pYL . o,,

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c. Each penetration providing direct access from the containment M.,g o o atmosphere to the outside atmosphere shall be either:

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1) Closed by an isolation valve, blind flange, or manual valve, or A Jp.' 2) Exhausting through an OPERABLE Reactor. Building Containment pg Purge System HEPA filters and activated carbon adsorbert l 2$ng; L k{C -

APPLICABILITY:

the containment.

During CORE ALTERATIONS or movemer.t of irradiated fuel within l.ShMh 7 d r>

ACTION: (or reasom c4he r +ho.n %c heodd5 4 eshei pee 4.9.4 2.a. and . . '6 3 l

ct, ith the requirements of the above spec fication'not satis , immediately 3[n'0 suspend all operations involving CORE ALTERATIONS or movement f irradiated gkL fuel in the containment building.

N h.h.e &

F5%$lSURVEILLANCEREQUIREMENTS.

I 4 5h'n -C M.9 4.9.4.1 Each of the above required containment building penetrations inall be

]p$ determined to be either in its closed / isolated condition or exhausting through l

T +0 36 an OPERABLE Reactor Building Containment Purge System with the capability of

• - being automatically isolated upon heater failure within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to the 4 3 C -r start of and at least once per 7 days during CORE ALTERATIONS or movement of

){,A 9 {,, irradiated fuel in the containment building by:

M-8 C a. Verifying the penetrations are in their closed / isolated condition, i

o. . - $ or 0 $ . o- )

ju w o$. o

b. Verifying the upper and lower containment purge supply and exhaust valves close upon a High Relative Humidity test signal.

d 5 + n, +% [

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CC f,hc 3'6 .*3 ,C

.\ g CATAWBA - UNITS 1 & 2 3/4 9-4 [ggg y[ f/jjt 'd ,

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nwn a RETUELING OPERATIONS S'JRVEILLANCE REQUIREMENTS (Continued) 4.9.4.2 The Reactor Building Containment Purge System shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow through the HEPA filters and activated carbon adsorbers and verifying that the system operates  !

for at least 10 continuous hours with the heaters operating;

b. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or activated carbon adsorber housings, or l (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 1% and uses the test procedures guidance in Regula-tory 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 25,000 cfm t 10% (both exhaust fans operating);

2) Ver ingwithi 31 days after removal, that a laboratory ana ysil of a epresentative activated carbon sample obtained l in a e ith Regulatory Position C,6.b of Regulatory O m cg 4ggedpr Guid .52, Revision 2, March 1978 4*eet+-the-4ebepatory-tes t4ng-Q3Trri-DS@3-pj eMteHe+Regtdetery%dt4e-C.5. : AReguleteHub L 52, Rev4e4en 2, t rch 19787

• a methyl iodide penetration of less than 6%; and has

3) Verifying a system flow rate of 25,000 cfm i 10% (both exhaust fans operating) during system operation when tested in accordance with ANSI H510-1980.

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 opc\ heSkec4 per with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2

' :boeatory-t ett4ft-eH teefa-ef-Regtde tery-Pes v-43Tm-03?oB T) . March 19784 meetc th: tun C.5.: ef hgdet ry cuic 1.52, Red *4en-h-March-1978*

methyl iodide penetration of less than 6%; hous

d. At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA fil-ters, activated carbon adsorber banks, and prefilters is less l than 8 inches Water Gauge while operating the system at a flow rate of 25,000 cfm i 10% (both exhaust fans operating); and 1

• The requirement for reducing refrigerant concentration to 0.01 ppm may be atisfied 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) ;1 etat ng. y m 44 AcWWe\ c.wbo n addo r b er S am ples are 4 esied M 30 d ee50, and 15 *k R ay ^ - - A >

CATAWBA - UNITS 1 & 2 3/4 9-5 '=ntscnt 5.37 (Un44-lb

1

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. 1 4

REFUELING OPERATIONS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying that e filter tr in du ter dis i ates 120 t 12 kW\ M a ned m\ vo\%cge o - b OO V AC-

e. After each complete or partia replaceae . - a HEP ilter bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 1% in accordance with ANSI N510-1980 for a 00P test aerosol while operating the system at a flow rate of 25,000 cfm 210% (both exhaust fans operating); and

f. After each complete or partial replacement of an activated carbon l adsorber bank, by verifying that the cleanup system bank satisfies the in place penetration and bypass leakage testing acceptance cri-teria of-less than 1% in accordance with ANSI N510-1980 for a halo-genated hydrocarbon refrigerant test gas while operating the system at a flow rate of 25,000 cfm t 10% (both exhaust fans operating).

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' CATAWBA UNITS 1 & 2

-. -3/4_9 .23993;9} "g. j]"9jj

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3/4.9 REFUELING OPERATIONS BASES 3/4.9.1 BORON CONCENTRATION f The limitations on reactivity conditions during REFUELING ensure that:

(1) the reactor will remain subcritical during CORE ALTERATIONS, and (2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel. These limitations are consistent with the initial conditions assumed for the boron dilution incident in the safety ~ analyses. The value of 0.95 or less for K,ff includes a 1% ak/k conservative allowance for uncertainties. $1milarly, the boron concentration value of 2000 ppm or greater includes a conservative uncertainty allowance of 50 ppm boron.

3/4.9.2 INSTRUMENTATION The OPERABILITY of the Boron Dilution Mitigation System ensures that monitoring capability is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for reactor suberiticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short-lived fission products.

This decay time is consistent with the assumptions used in the safety analyses.

. 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment building penetration closure and OPERABILITY l

of the Reactor Building Containment Purge System ensure that a release of radioactive material within containment will be restricted from leakage to the environment or filtered through the HEPA filters and activated carbon adsorbers prior to release to the atmosphere. The OPERABILITY and closure restrictions are sufficient' to restrict radioactive material release from a fuel element rupture -

based upon the lack of containment pressurization potential while in the REFUELING MODE. Operation of the Reactor Building Containment Purge System and_the resulting iodine removal capacity are consistent with the assumption of the safety analysis. Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the

, adsorbers and'HEPA filters. ANSI N510-1980 will be used as a procedural guide

.for surveillance testing.

l l

l CATAWBA - UNITS 1 & 2 B 3/4 9-1 Amendment No.39(Unit 1)

Amendment No.31(Unit 2)

i CONTAINMENT SYSTEMS d

y ANNULUS VENTILATION SYSTEM

-+ 4

.9 70 LIMITING CONDITION FOR OPERATION O .E 4

3. 6.1. 8 Two independent Annulus Ventilation Systems shall be OPERABLE.

>6 Q9yg APPLICABILITY: MODES 1, 2, 3, and 4.

.j "d ACTION:

S e c r ectSc> n s cdh e r +M n W cc.-h ed f CS e d-

+cm ec in . O>. l B . o. a D*h .

o '13 n ' ope)raertore nopera le sys em W ~$'4.ithoneAnnulusVentilationSy to OPERABLE status within 7 days or be in at ast HOT STANDBY 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 />.

.fr 4 o

&4 SURVEILLANCE REQUIREMENTS

'o Q.c 3 n -

v 4 d <o 4. 6.1. 8 Each Annulus Ventilation System shall be demonstrated OPERABLE:

} -&A r ?o .t 3jj a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, A' C from the control room, flow through the HEPA filters and activated I carbon adsorbers and verifying that the system operates for at least S ]c 10 continuous hours with the pre-heaters operating; ik *93C 3 b. At least once per 18 months or (1) after any structural maintenance a on the HEPA filter or activated carbon adsorber housin s, or (2) fol-

{ p gui ' l

-3o l lowing painting fire, or chemical release in any vent lation zone Q &,5 +g3 communicatingwIththesystemby:

f 8 wW 'O j ' 1) Verifying that the cleanup system satisfies the in place pene-d i

N gf j n -

i trationandbypassleakagetestingacceptancecriteriaofless than 1% (Wit 1), 0.05% sUrit :') and uses the test procedure I]p ):.h o

.: o ,

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

%eedDofdr,. flow rate is 9000 cfm t 10%;

- ht jgg[ O- e W 2) Verifying, within 31 days after removal, that a laboratory analysis of a representative activated carbon sample obtained l

• u,c*Oc. G O .

in accordance with Regulatory Position C.6.b of Regulatory p e o j +oanc{ ks ide 1.52 Re v i s i o n 2 . Ma rc h 19 78 --- + ' + " ' ."_^ " + ^ -" + ", .",aa

. .. . _ _ , . ._. .,. m ..-m 5 kI y ASTkecDSM384M'"2Ei3M,' ~'C,tyi'iodis"Me'tStioEof iOs -

^

f th has 4 %, and

\(u.a.gg c

c d

3) Ver ystem flow rate of 9000 cfm i 10% during system j,To.e 4

C operation when tested in accordance with ANSI H510-1980.

• $Nh c wo n hIO The requirement for reducing refrigerant concentratic.1 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.

O S r inr.t "o. 37 (Wit-1)

CATAWBA - UNITS 1 & 2 3/4 6-14 A-_h_. M. 9n / f f. J & di i

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,. . . . - , . _ . , . _ , __ . . . _ . _. . , _ . . "" ' N"* ' '? *I._3"_*_'"l_

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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 g verifying, within 31 days after removal, that a laboratory analys of a. representative activated carbon sample obtained in accordanc l with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, Qgg 9g March 1978,;= :t: th hberatopy--tut 4r.g-cr4teria of Ragulatory Dad-ASTM OSSOS- j uen C.t.:-of4m44tej Ouid: L 52, b+shn-ar-Hereh-lWB, a methyl iodide penetration of less than-14 has

d. At least once per 18 months by:

1) Verifying that tt.e pressure drop across the combined HEPA fil-ters, activated carbon adsorber banks, and moisture separators l is less than 8 inches Water Gauge while oper ting the sy m at a flow rate of 9000 cfm i 10%; so(e n pe4 ion

2) Verifying that the system starts automatical y on any te *

. -leeleth-test signal ,**

3) Verifying that the filter cooling eleckric motor-operated bypass 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 1 minute after a start signal, and

5) Verifyi t etters dtsii kW, A+- n med vet Mg 5 00 A C. ,

e. After each comp ete PTa'rT#rhtbment HEP ter bank, by verifying that the cleanup system satisfies the in-place penetra-tion and bypass leakage testing acceptance criteria of less than 1%

H Ue4t-1), 0.065 (Unit 2) in accordance with ANSI N510-1980 for a 00P test aerosol while operating the system at a flow rate of 9000 cfm 2 10%; and

f. After each comolete 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%-(#n+t-Ey in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 9000 cfm i 10%.

t

• • This surveillance neea not be performed until prior to enter g HOT SHUT W _

c Mowina the Unit 1 fir _st refuelinor- n 04 AcWMed ccirbors cherber so.cnp\O are. 4eWc\ /

oA 30 otg 0 oncI )yg.5p- /

+ .

A - UNITS 1 & 2 3/4 6-15

l' CONTAINMENT SYSTEMS BASES 3/4.6.1.B ANNULUS VENTILATION $YSTEM The OPERABILITY of the Annulus Ventilation System ensures that during LOCA conditions, containment vessel leakage into the annulus will be filtered througn the HEPA filters and activatedcarbon adsorber trains prior to discharge to the l atmosphere. Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA fiIters. T-h4+-mpir+ ment i6-nesetsary-t&-meet-the-assumpt4Gns--us*4 4n-the-6afety see+yte; enc limit tu !!TE BOUN0f" rectaMon-eases-to eithin the cose-9aco~

lin; selve cf 10 C" PaM-M0 cring LOGA-ten #Mense ANSI H510-1980 will be used as a procedural guide for surveillance testing. #

3446.1.9 CONTAINMENT PURGE SYSTEMS The containment purge supply and exhaust isolation valves for the icwer corhpartment and the upper compartment (24 inch), and instrument room (12 inch),

and the Hydrogen Purge System (4-inch) are required to be sealed closed during plant operation since these valves have not been demonstrated capable of closing during a LOCA. Maintaining these valves sealed closed during plant operations ensures that excessive quantities of radioactive materials will not be released via the Containment Purge System. To provide assurance that these contains. ant valves cannot be inadvertently opened, the valves are sealed closed in accord-ance with Standard Review Plan 6.2.4 which includes mechanical devices to seal or lock the valve closed, or prevents power from being supplied to the valve operator.

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 accicent 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 1 4 inch valves. The total time the containment purge (vent) system isolation 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 to facilitate personnel access for surveillance and maintenance activities, may 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 oegradation 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 tne previously determined total <

for al', valves and penetrations subject to Type B and C tests.

CAT AWB A - UNIT S 1 & 2 B 3/4 6-3 Wnment M. 3' (Un+

2:ns;nt M. &(hit 2) =

W REFUELING OPERATIONS o

J g 3/4.9.11 FUEL HANDLING VENTILATION EXHAUST SYSTEM v .+

G,  ;.~ 1 0 .- LIMITING CONDITION FOR OPERATION b -b Cky e"w

+ 3 o g 3.9.11 At least one train of the Fuel Handling ventilation Exhaust System

$ shall be OPERABLE.

b kPPLICABILITY: Whenever irradiated fuel is ir. the stgrage pool.

ACTION: Fer r G We h rs t gygg in , L t . 2. ._ ot a nci 4 9. m 2.14 g' _ ___-

O o ,g a. With both\ trains of the Fuel Handling Ventilation Exhaust System Oyg g gj inoperabid; suspend all operations involving movement of fuel within the storage pool or crane operation with loads over the storage pool Lpo.f until the Fuel Handling Ventilation Exhaust System is restored to C 0 OPERABLE status.

g

-0 j g -t- C,. . The provisions of Specification 3.0.3 are not applicable.

+

• 0 c)-a4-t SURVEILLANCE REQUIREMENTS Wh k 4.9.11.1 One train of the Fuel Handling Ventilation Exhaust System shall be

.5 o. a determined to be operating and discharging through the HEPA filter and acti-T t, n J vated carbon adsorbers at least once per 12 nours whenever irradiated fuel is 1 C. < being moved in the storage pool and during crane operation with loads over the V) h storage pool.

Nd $4.9.11.2 Both trains of the Fuel Handling Ventilation Exhaust System shall be

• demonstrated OPERABLE:

o a. At least once per 31 days by initiating, from the control room, c[

ei L $ g cg -t- flow through the HEPA filters and activated carbon adsorbers and verifying that the system operates for at least 10 continuous hours yo.7 with the heaters operating; s-3o D At least once per 18 months or (1) after any structural maintenance y h t>J-d

b. +

on.the HEPA filter or activated carbon adsorber housings, or (2) fol-

.kr lowing painting, fire, or chemical release in any ventilation zone gy , communicating with the system by:

g C 1) Verifying that the cleanup system satisfies the in place

-E penetration and bypass leakage testing acceptance criteria C D 'o- j ,\) of less than 1% -(Unit 1), S-05% (Unit-H and uses the test

.l'.72 0" procedure guidance in Regulatory Positions C.5.a. C.S.c, and C.5.d* of Regulatory Guide 1.52, Revision 2, March 1970, and j {gdy' the system flow rate is 16,565 cfm i 10%;

Nbqc ro

.t D o,d The requirement for reducing refrigerant concentration to 0.01 ppm may be 3j 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.

J .c- CATAWBA - UNITS 1 & 2 3/4 9-14 -Amend 3t-NG. 40 (Unit-lt

-Am:ndment Na :.1 (Unit 2' _

. )

i l

! . I 1

I REFUELING OPERATIONS

l

, SURVEILLANCE REQUIREMENTS (Continuod) i i

l m 2 Verifying, within 3L days after removal, that a laboratory analysis of a representative activated carbon sample obtained Onel +estec\ pep in accordance with I!agulatory Positions C.6.b of Regulatory 1 45Trn 03?o3-BC/ Guide :,.52. Revistort2, March 1978,;::t: th: 1 e:= t:r; t:: tin; J 5b h.5.5.5 [ bi!N.. N...f.n, ._,

I.I.. T'5 N 5_N.&,.b5N.

m ....

b.m5db. ... hS!.'

";t%;d "A"; ^

. sethyl iodide penetration of less than s "" .

and has  !

3). Verifying a system flow rate of 16,565 cfm i 10% during sys e operation when testec in accordance with ANSI N510-1980.  ;

c. After eve 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of activated carton adsorber operation in any train fying, within 31 days after removal, that a laboratory '

analy of representativi activated carbon sample obtained in acco ith Re ulatory Position C.6.b of Regulatory Guide 1.52, ,

omoi +eSheclper Itavinion 2. March $978.enen th: 1 2 : = t:r 5: ting Ori u ri: ef ASM M -Q hj ,

@, d i,j g '[ u a methyl iodide penetration of less than h 0.7 d- At least once per 18 months ~for each train by:

- 1)- Verifying that the presstre drop across the combined HEPA filters,.

activated carbon adsorber banks :and moisture separators is less than 8-inches Water Gauge while, operating the. system at a flow r rate-of 16,565 cfm i 105. -

2) Verifying that the system maintains the spent fuel storage pool area at a negative pressure of greater than or equal to % inch Water Gauge relative to the outside anosphere during system

. operation,

3) Verifying that the filter cooling bypass valves can be manually opened, and

4) Verifying that the heaters dissi ata 80 + 8 kW/_-17_.3 k ** -

l;

- /H cs n c h es go%g e, o GoOVAC M '

^ __

• "= ef 'S" S'*?? ^', T::t tthid "A" :: c':" ;1r::t :;;lis: =til'

, .t;":t 05, 1**1. Th: =:ft ., th: : rni11:=: =;;f7--::t 05:11_ M M ,s

" . . . rM tM le- :Sr/ hetim; _:riteri: ef ".:3 Of " ;;1:t:r; Ocid: 1. 52, *"::i ' r, 2, ",:r;h 1975,1:ur; 107 : =*=144en-Cr6te t'y1 i:did:

=

t nti n f 1::: th-- 1 "-

7hereefter, the "00 < ' hS/-17.3 hS :;;1i:: =til t;nt 20 1001. '--*-- '"* h **

rnill== =;;irr: .t 05:11 n:d ' t'

, 4.g]h0g er mp\ ego fe ie'M]r 6pgc,and '35' o 8&

3/4 9-15

- UNITS 1 & 2 -AmeCM" " '" " " -

i REFUELING OPERATIONS SURVE!LLANCE REQUIREMlNTS (Continued)

e. After each complete or partial replacement of a HEPA filter bank in any train, by verifying that the cleanup system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% (#nft4)r-0,05%.(UMt4)-in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 16,565 cfm t 10%; and

f. Af ter each complete or partial replacement of an activated carbon adsorber bank in any train, by verifying that the cleanup system satisfies the in place penetration and bypast leakage testing eccept-ance criteria of less than 1% (Unit 4)r-Or065-(Unit-4 in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the tystem at a flow rate of 16,565 cfm 1 10%.

o l

l CATAWBA - UNITS 1 & 2 3/4 9 16

-Amendment-No.

. -.. _ ,.. ,-. y, 75 junkt -l'JJoi H b

REFUELING OPERATIONS BASES 3/4.9.9 and 3/4.9.10 WATER LEVEL - REACTOR VESSEL and STORAGE POOL The restrictions on minimum water level ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly. The minimum water depth is consistent with the assumptions of the safety analysis.

3/4.9.11 FUEL HANDLING VENTILATION EXHAUST SYSTEM The limitations on the Fuel Handling Ventilation Exhaust System ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and activated carbon adsorber prior to discharge to the atmosphere. Operation of the system with the heaters operat-ing to maintain low humidity using automatic control for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system and the result-ing iodine removal capacity are consistent with the assumptions of the safety analyses. ANSI N510-1980 will be used as a procedural guide for surveillance testing. A&TM-03803-86r-Test-Method eau-wf44-be-used-foe-survel44ence-test 4n0

-(4ebeeatoey-test}-for-methyl-40dide-penetrabion-in-4ite ;;f th: Id:ratory-tes t-

+ pee 444ed-in-Regulatory-Guide-1r623 -Rew-4-March-19783-Regulatory-Pos4 tion-C.0.6. The-A&TM-03803-06-teet-method-uses-a-relet 4ve-hu:idity of-954-at-40'C. T he - u se-of-th4 &-test-and-the-acceptance-c rite r4 on--o f-4-me%yl-iodi de -

penetr-atior of--1+56-thanM1%-are-cons 4 stent-with-essumed-decontamination-ef ficienefee-of-95%r--TMt-change-eetutted-from-the-4 ewer sy;te;;; heeter eapae4 ty-during-deg raded -vol tage-cond i t ions t-T he-use-o f - ASTM-03803-06-wi41 apply-unt44- Augus t-46r-1991 r-Thi s-da te< o rres ponds- to-t h e - nex t-due-date-f or the-18 month-surve144ance-on4 nit-2. The4 nit--2-dete-it-used - for bath-units bec:e:: the next 1&amenth-fespest4en-date for Unit-1, December 13, 1990;-wHi ect :lhw feMuf44e4ent time to-evelvete-ASTH-03003-09:

CATAWBA - UNITS 1 & 2 B 3/4 9-3

l

[

PLANT SYSTEMS

[' d h 3/4.7.7 AUXILIARY Bull 0 LNG FILTERED EXHAUST SYSTEM p'a p .g e .

LIMITING CONDITION FOR OPERATION 3.7.7 Two independent trains of the Auxiliary Building Filtered Exhaust System ga shall be OPERABLE.

j APPLICABILITY: MODES 1. .

9%$Y ACTION:

(v5phtbecklaMM 4er reasons c+he r thomud1AO"'v

$tY d $ q. With one train of the Auxiliary Building Filtered Exhaust System inoperably$

W C hC" 4 0 4o restore the inoperable train to OPERABLE status within 7 days or be in at least d0 5Y o HOT STANDBY 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 SHVTOOWN within the following g S o-b 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

v$.9h A

'd N SURVEILLANCE REQUIREMENTS kg6u 8c f 4.7.7 Each train of the Auxiliary Building Filtered Ixhaust System shall be 4

V demonstrated OPERABLE:

gg@S 0 Y a. At least once per 31 days by initiating, from the control room, flow t gg through the HEPA filters and activated carbon adsorbers and verifying l c 1 that the system operates for at least 10 continuous hours with the

' ~615 o <C J heaters operating; p m) ,,

3 /

CCCY b. At least once per 18 months or (1) after any structural maintenance

. -i. '5 2 " on the HEPA filter or activated carbon adsorber housings, or (2) fol- l e .+ o lowing painting, fire, or chemical release in any ventilation zone

'j* communicating with the same by:

$g[ -

1) Verifyin that the cleanup system satisfies the in place penetrat on and bypass leakage testing acceptance criteria of

[ksg6* o - less than 1% :(Unit 1), 0,US%-(Un444)-and uses th6 test proce-e 0 ,3 i.) dure guidance in Regulatory Positions C.S a, C.S.c, and C.S d*

6 of Regulatory Guide 1.52, Revision 2, March 1978, and the system ieC flow rate is 30,000 cfm i 10%;

+

0 .0 -

10 2) Verifying, within 31 days after removal, that a laboratory I+0 8 # o C analysis of a representative activated carbon sample obtained l f,2

• h C C in accordance with Regulatory Position C.6.b of Regulatory t , Guide 1.52. Revision ( Marr h 147B Aeetsr-t-he-laborat+ry-testa

.g p h .g.-AST 4 m(qanel OMo*3 - 4eM p]87 4ng-or4ter44-of-Regdatory-pos444p-Cr&ra Gu4 de-1r62 r-Rev4+4en-h-March-1978r4+ a methyl iodide penetra-40S [ps tion of less than 4,h and y#

+ $p# D fTf $j *The requirement for reducing refrigerant concentration to 0.01 ppm may be sati fied by operating tne 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.

y y5 g 4 CATAWBA - UNITS 1 & 2 3/4 7-17 Amendment N: 4M4)nh-+)-

m m t No. mUme

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

3) Verifying a system flow rate of 30.000 cfm t 10% during system operation when tested in accordance with ANS! N5101980,

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 -

verifying, within 31 days after removal, that a laboratory analy is* "

of a representative activated carbon sample obtained in accordanc Qnd ieSf6d pff~ with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 p) M O M M . g "= March 19786:t:

tten C.5es th 1:b:rchey-test 4ag-cMterie-of-RegulatoryJosh.

ef S;dekey4(de-Ir6ih-Redskn 2, " erg-1978, a methyl iodide penetration of less tha 40 - hag 4

d. At least once per 18 months by:

1) Verifying that the pressure drop across th'e combined HEPA filters, activated carbon adsorber banks, and moisture separa- l ,

tors of less than 8 inches Water Gauge while operating the system at a flow rate of 30,000 cfm t 10%,

2) Verifying that the system starts on a Safety injection test signal, and directs its exhaust flow through the HEPA filters and activated carbon adsorbers',** l

3) Verifying that the system maintains the ECCS pump room at a negative pressure relative to adjacent areas,

4) Verifying that the filter cooling bypass valves can be manually opened, and

5) Verifying that the he sd . i at t -

e. Aft'er each complete or part a re o a HEPA r ba >

by verifying that the cleanup system satisfies the in-place pene-tration and bypass leakage testing acceptance criteria of less than 1% ("ait U , 0.00% ("ait 2) in accordance with ANSI N510 1980 for a 00P test aerosol while operating the system at a flow rate of 30,000 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% (hit 1), 0.05% (Unh-4) in accordance with ANSI N510-1980 for a halogenated-hydrocarbon refrigerant test gas while operating the system at a flow rate of_30,000 cfm t 10%.

O This surveillance follo g Unit need _1not berefueling.

first performed until prior to entering HOT SHUT 00W

[gp Ac;YMed cAfbon odsorber sunp\es are, keded s

(# 30de9ccf5 C Omd %

Gns CATAWBA - UNITS-1 & 2 3/4 7-18 -?:::t:nt h ??

?:::t: t W. 90 -[.UM nit-13--

t 1)-

l'- .

PLANT SYSTEMS i

BASES The 18-month surveillance to verify a positive pressure of greater than 1/8 inch water gauge, with less than or equal to 4000 cfm of pressurization flow, is to be conducted using only one intake from outside air open. By testing the capability to pressurize the control room using each intake individually, the design basis which assumes reopening of the two intakes following isolation on chlorine, smoke or radiation, is tested.

3/4.7.7 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM The OPERABILITY of the Auxiliary Building Filtered Exhaust System ensures

, that radioactive materials leaking from the ECCS equipment within the auxiliary building following a LOCA are filtered prior to reaching the environment.

4 Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HiPA filters.

The operation of this system and the resultant effect on offsite dosage calcu-1ations was not taken credit for in the safety analyses. However, the operation of this system and the resultant effect on the NRC staff's offsite dose calcula-tions was assumed in the staff's SER, NUREG 0954. ANSI N510-1980 will be used as a procedural guide for surveillance testing.

t 3/4.7.8 SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety related systems is main-tained during and following a seismic or other event initiating dynamic loads.

Snubbers are classified and grouped by design and manufacturer but not by

- size. For example, mechanical snubbers utilizing the same design features of the 2-kip,10-kip, and 100-kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by Company "B" for the purposes of this Technical Specification would be of a different type, '

as would hydraulic snubbers from either manufacturer.

A list of individual snubbers with detailed information of snubber location and size and of system affacted shall be available at the plant in accordance with Section 50.71(c) of-10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Catawba Safety Review Group. The determination shall be based upon the existing radiation levels and the expected time to per-form a visual inspection in each snubber location as well as other factors asso-

- ciated with accessibility during plant operations (e.g., temperature, atmosphere, location, etc.) and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletions of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

CATAWBA - UNITS 1 & 2 B 3/4 7-4 Amendment No. 78 (Unit 1)

Amendment No. 72 (Unit 2)

I i .

ATTACitMEllT 2

i CATAWBA NUCLEAR STATIO!4 TECilNICAL SPECIFICATION CitANGE REQUEST

Background

During a review of the llVAC systems at Catawba Nuclear Station it was discovered that the pre-heators in some ESF filter units woro not conservatively sized for all postulated operating modos. The pre-heators are used to control the relative humidity of the influent air entering the carbon adsorbor. These filters woro designed in a manner that assumos the heators maintain the relativo humidity (Ril) of the air at 70% or loss. Duke PoWor's review revealed that during postulated low voltage conditions with loss of one of the two offsito power sources and all plant auxiliarios of the unit aligned to the other power source through the remaining step-up transformer with a concurrent LOCA, aufficient' power may not be supplied to those heators to enable them to maintain an Ri!

of loss than or equal to 70%. The af fected systems are the Annulus Ventilation System, the Control Room Arca Ventilation System, the Containment Purgo System, the Fuel llandling Ventilation Exhaust System, and the Auxiliary Building Filtered Exhaust System.

Five different options wore considered for permanently addressing this relative humidity problem. The options woro:

1) Increase the minimum voltage availablo

2) Provide supplomontal heators

3) Restrict upper flow limit

4) Roduce upper and lower flow limits

5) Change carbon test to factor in high humidity (95%)

Option (1) . was rejected since this solution would cause over-voltago problems during normal operation. Since the low voltage concern is the result of the unlikely series of ovents outlined earlier and problems are. created. during normal oporation, increasing the minimum voltage to provido onough heator capacity during a low voltago event is inappropriato.

Option (2) was rejected because the additional heators and associated controls'aro costly and would make the system needlessly more complex. This option would also require additional omorgency-power during loss of preferred power conditions, reducing the spare power margin available on the diosols.

option (3) would require that the maximum air flow be rostricted through the filter units. This would allow the heaters to properly control humidity in a degraded bus situation. This option was rejected because of the increased operator burden caused by the flow restrictions. With the margin betwoon the maximum and minimum allowable air flows reduced, operators would have a very

i 2

rostrictive flow rango in which to operato the systems. This rango was judged to be overly rostrictive and could Icad to system unavailability.

Option (4) would relieve the flow margin restriction of Option (3) by decreasing both the upper and lower flow parameters. Even though there is no increased operator burden with Option (4), it was rejected because of possible increases in dopo consequences.

This is most apparent in the Annulus Ventilation System. Reducing the flow range would increase the timo required to draw the annulus to a negativo pressure which significantly increases the Exclusion Area Boundary (EAB) (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) thyroid doso.

Option (5) involved changing the carbon penetration test method to factor in high humidity. This option was chosen even though it requires a chango to the TS and will result in more frequent carbon change out. The bonofits of this option are: 1) no incroaced burden on operator due to flow rostrictions, 2) no increase or change in the doso consequences. This o;3 tion will require more frequent carbon chango out. }!oweve r, thns is acceptable to the station.

PURPOSE The purpose of this Technical Specification amendment is to addrops humidity control associated with the Annulus Ventilation, the Control Room Area - Ventilation, the Containment Purgo, the Fuel

!!andling Ventilation Exhaust, and the Auxiliary Building Filtered Exhaust Systems. This proposed change will make the carbon adoorber testing consistant betwoon the different ventilation systems, and will continue to assure that the design bases for the systems continue to be mot.

TERMS The following terms are defined as they apply to this docu'ad and to provido clarity to the discussion.

1) bypass leakage - the percentage of flow that passes around a filter without being filtered.

2) penetration -

the amount of methyl iodide

, which will pass through a sample of carbon j without being adsorbed. This value can bo

established by ASTM D3803.

[

1 i

__,,_y____-_,__y.___,

i l

3

3) decontamination officiency - the porcent of radioactive iodine that will be removed by a filter system. This value is a function of bypass leakage and penetration.

DE : 100% - (BL + PE)

CilA11GES TO TECllNICAL SPECIFICATIONS AND TECilNICAL DISCUSSION FOR ANNULUS VENTILATION, Col 1 TROL ROOM AREA VENTILATION, CONTAINMENT PURGE, FUEL llANDLING VENTILATION EXilAUST AND AUXILI ARY BUILDING FILTERED EXilAUST SYSTEMS The similar TS changes for each system will be discussed together, since the technical reasoning for them is the same. This requested TS amendment changos the carbon adsorber test method for Catawba Nuclear Station for the Annulus Ventilation, Control Room Aron Ventilation, Containment Purgo, Fuel llandling Ventilation Exhaust ar1 Auxiliary Building Filtered Exhaust Systems to ASTM D3803-89.

This proposed amendment also makes changes which support using this standard, such as revising the ACTION statomonts to reflect that the ventilation systems aro OPERABLE without heators, and changing the allowable methyl iodido penetration to reflect the now test.

The heator testing requiroments are also revised to clarify tho heator tost method.

1. CilANGES TO TS The Surveillance Requirements (SR) 4.6.1.8 b.2 and 4.6.1.8.c for the Annulus Ventilation System, 4.7.6.c.2 and 4.7.6.d for the Control Room Area Ventilation System,

4. 9. 4. 2. b. 2 and 4.9.4.2.c for the Containment Purgo System, 4. 9.11. 2.b. 2 and 4. 9.11. 2.c f or the Fuel llandling Exhaust Ventilation System, and 4.7.7.b.2 and 4.7.7.c for the Auxiliary Building Filtered Exhaust System are changed to indicate that the laboratory testing critoria of ASTM D3803-89 will be used.

TEC11NICAL JUSTIFICATION The proposed carbon adsorber testing standard, ASTM D3803-89, is a stringent procedure for establishing the capability of now and used activated carbon. The following table comparos this standard with the original TS required test method and ASTM D3803-86 (temporary TS test method for Fuel llandling Exhaust Ventilation System) for used carbons.

1 i

4 Test Period Original ASTM D3803-06 ASTM Test Method Test Method A D3803-89 Pro- not required not required 30*C 95%R}i Equilibration 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Equilibration not required not required 30*C 95%Ril 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Challengo 30*C 70%Ril 30'C 95%Ri! 30'C 95%Ril (Food) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> The major diffornnce betwoon the ASTM D3803-89 and the other test methods is that the ASTM D3803-99 method require 0 the carbon beds to be pro-conditioned with 30*C and 95% relativo humidity air for c:,ghteen (18) hours before the methyl lodido challongo (food) period. This approach is intended to make the carbon test repeatable so that results from similar tests can be compared. The pro-conditioning is conservative because it saturatos the carbon beyond the conditions expected during Design Basis Events for the Catawba Nuclear Station ventilation systems. The water vapor competos with the methyl iodido for adsorption s.itos on the carbon, thorofore, the higher the relativo humidity the hardor it is for methyl lodido to be adsorbod. ASTM D3803-89 is a more repeatable test for carbon adsorbor, and the pre-equilibration period at 95% relative humidity makes it more stringent than previous standards.

2. CilANGES TO TS SRs 4.6.1.8.b.2, 4.6.1.8.c, 4.9.11.2.b.2, 4.9.11.2.c, 4.7.7.b.2 and 4.7.7.c are changed to indicate that a methyl lodido penetration of 4% will be used for the Annulus Ventilation System, the Fuel llandling Vontilation Exhaust System and the Auxiliary Building Filtered Exhaust System.

SR's 4.7.6.c.2 and 4.7.6.d will be changed to indicato that a methyl iodido ponotration of 0.95% will be used for the Control Room Area Ventilation System as the acceptance critoria for the carbon adsorber testing.

The methyl iodido penetration for the Containment Purgo System will not be changed. It has boon dotormined that using the current mothyl lodide penetration will provido acceptable margin for carbon adsorbor chango-out.

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5 TECHNICAL JUSTIFICATIOf{

The test acceptanco critoria of Regulatory Guido 1.52 will no longer be referenced in the TS becauso Regulatory Guido 1.52, Revision 2, March 1978, does not address the testing of a system without humidity control which operatos outsido the primary containment.

Because of the pre-equilibration period, which does not oxist in previous carbon adsorber test standards, the carbon is tested at a more conservativo point. Using the ASTM D3803-89 testing standard would always be expected to give a more conservativo mothyl lodido ponotration value than current test methods. The ASTM D3&O3-89 test method is also conservative with respect to the plant conditions expected during an accident. Postulated accident conditions do not subject the carbon to saturated conditions, therefore, the radioactive iodino penetration during an actual accident would be lower than that predicted by the laboratory test. A 4% methyl iodido ponotration is acceptable for the Annulus Ventilation System, the Fuel Handling Ventilation Exhaust System, and the Auxiliary Building Filtered Exhaust System, and a 0.95% Inothyl lodido ponotration is acceptable for the control Roor.i Arca Ventilation System sinco added conservatism is built into the now carbon adscrbor test, and current Design Bases decontamination efficiencies are mot using those values.

Duko Power believes that this method for defining ponotration is conservativo for the following reasons:

a) The scope of ASTM D3803-89 describes this standard as "a very stringont proceduro" and says that it "is recommended for the quantification of the degradation of used carbons."

b) Limited testing done by Duke Power shows that testing dono por the 1989 revision of ASTM D3803 will result in more frequent carbon change out than testing por the 1986 revision. Por this TS chango, Duke Power will generally have newer, fresher carbon in its filter systems, c) The 1989 revision also requires that the carbon be pro-saturated before being tested. Saturating the carbon limits its ability to adsorb iodino. Postulated accident scenarios do not subject the carbon adsorber to saturated air, thereforo, testing por the 1989 revision will yield conservativo results relative to actual adsorption ability.

d) Design basis dose analyses for Catawba show that the combination of all ESF systems , io, containment sprays, ice condonsor, HEPA and carbon filters and Inost

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6 importantly the containment itself, serve to keep of fsite ard onsite doses well below regulatory limits. The relative importance of the carbon adsorbers to mitigate

! iodine releasee is questionable in light of source term studies over the last decade which predict only a small elemental iodine constituent in the release.

3. CHANGES TO TS The ACTION for TS 3.7.6, Control Room Area Ventilation System, 3.6.1.8, Annulus Ventilation System, 3.9.11, the Fuel Handling Ventilation Exhaust System, 3.9.4, Containment Purge System, and-3.7.7, Auxiliary Building Filtered Exhaust System, are changed to_Andicate that they apply for reasons other than heaters. New ACTIONS have been added to indicate that if the heaters are inoperable, they will be fixed within 7 days, or a report filed With the NRC. ,

4 TECHNICAL JUSTIFICATION Since the Design Basis decontamination efficiencies can be met for the systems described above using a test that assumes no heaters, operability of the systems will no longer be dependent on heater operability. -

The heater testing requirements will-remain the same as they are currently, and the heaters will be required to be fixed in a timely manner in the event of failurt. Even though the heaters will remain in.

service, no credit vill be taken for them. This results in additional margin.

4. CHANGES TO TS "At a nominal voltrge of 600 VAC" has been. added to SRs 4.7.6.e.4, Control Room Area Ventilation,- 4.9.4.2.d.2, Containment Purgo, 4.6.1.8.d.5, Annulus Ventilation, 4 . 9 ~.11. 2 . d . 4 , - -Fuel- Handling ' Ventilation Exhaust, and 4.7.7.d.5, Auxiliary Building Filtered Exhaust.

TECHNICAL' JUSTIFICATION The-statement "at a nomina 1' voltage of 600 VAC" has been added to .the heater testing requirements. This clarifies how the heater testing should be-done. With-.the heaters tested at nominal- voltage- of 600 VAC,: a- failure of-- the heater-surveillance would.be indicative.of a heater problem, not a system problem.

5 .- CHANGES TO TS-The sections of-TS 3.9.11, Fuel Handling Exhaust Ventilation System, that apply until August 26,.1991 have.been deleted.

L This. change is administrative in nature.

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6. CHANGES TO TS SRs 4.6.1.8.b.1, 4.6.1.8.e, 4.6.1.6.i, 4.9.11.2.b.1, 4.9.11.2.e, 4.9.11.2.f, 4.7.7.b.1, 4.7.7.e, and 4.7.7.f are changed to indicate a bypass leakage criteria of 1% for Unit 2.

TECHNICAL JUSTIFICATION The 1% bypass leakage criteria is consistent with the requirements for Unit 1. This acceptance value is also specified for a charcoal adsorbor ef ficiency of 95% in Generic Letter 83-13, " Clarification of Surveillance Requiremento for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications on ESF Cleanup Systems." The:1% bypass leakage '

is consistent with the original system design, because, where i '

a 95% filter efficiency is used, a 1% bypass is assumed.

7.- CHANGES TO_TS

-SR 4.6.1.8.d.2 for the Annulus Ventilation System corrects the l automatic' start signal for the system from " Phase "A" i Isolation" to " safety. injection" signal.

-TECHNICAL JUSTIFICATION This change corrects an error in the TS. The original SR stated that the Annulus Ventilation System started on a Phase "A" Isolation signal. This has never been true. The system

.actually starts on a safety injection signal. This error is also found in the Catawba SER Section 6.2.3 which states that "In1the event: of a LOCA, the Annulus Ventilation System is l started by a containment high pressure signal (3 psig) ." The- l Catawba Nuclear Station FSAR was updated in 1989 to reflect the fact that the Annulus Ventilation System is started by a safety injection signal. . Table 7.2.1, " Instrumentation and control-' System Diagrams - Safeguards Actuation Signals," page 8, has always correctly shown that the Annulus . Ventilation System Starts on a safety injection signal.

8.' CHANGES-TO TS=

"And 95% RH" is added to the footnote for the control Room Area Ventilation 1 System... The entire note " Activated carbon adsorber samples are tested at 30 degrees C and 95% RH", is added to the other carbon adsorber testing specifications.

IICJ1HI. CAL JUSTIFICATION This change--adds clarification to the footnote by reflecting 4 the conditions'at which the new test will be done.

9.. The TS Bases have been marked up to reflect these changes.

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RQ_D1Q1{IFICANT HAZARDS ANALYJilf l l

10 CTR 50.92 states that a proposed amendment involvos no }

significant hazards consideration if operation in accordance with the proposed amendment would not

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2) Croato the possibility of a now or dif foront 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 boon previously evaluated.

No physical changes will be made to the plant, thorofore, thoro is no incronced probability of an accident. As discussed in the Technical Justification, the decontamination of ficienclos of the filters romain unchanged using the now test method and penotration acceptance critoria. The changes in the bypass leakago for the Annulus Ventilation System, the Auxiliary Building Filtered Exhaust System, and the Fuel Handling Ventilation Exhaust System which apply to Unit 2, will have no oficct on the decontamination of ficiencies, because a 95% decontamination of ficiency was assumed originally, and this assumption accounts for a 1% bypass leakage.

Because of this, the of fsito dose and control Room dose calculation ,

results are unaffected. In addition to requiring the carbon adsorbor to moet Design Basis decontamination officiencios at 95%

relative humidity, additional margin, for which no credit is taken, will be provided by the heators. For the reasons stated above, there will be no increaso in the consequences of an accident previously evaluated.

This proposed amendment to the TS does not croato the poso'bility of a new or dif ferent kind of accident from any accident prevlously evaluated. This proposed TS change will not causo any physical changes to the plant or changes to operating procedures. Because the plant will continue to operato the same way it does now, this proposed amendment does not create the possibility of any now or different accident from any previously evaluated.

This proposed TS change will not causo a significant reduction in the margin of safety. The now test method is more restrictive than the previous test methods, and, based on limited topting, Duke power expects to have to change out carbon more frequently. The change in the allowed mothyl iodide penetration, which was nado to support the change in test metho6, does not represent a significant decrease in the margin of saf ety. It reproconts the requirement of the test standard to pre-saturate the carbon adsorbor. This pro-saturation causes a higher penetration during testing, and is

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I conservative with respect to Design Daois Events. The test method j D3803-89 is expected to provido a penotration value during testing  !

which is higher than what would be expected during a Design Basis i Event. Those conservative results reflect the fact that the new  !

test conditions are more harsh than expected plant conditions  ;

during a Design Basis Evenit. As an added conservatism, no credit is taken for the heators. However the heators will bo tested and maintained, thorofore, the relativib humidity of air entoring the j carbon adsorber is never be expedtod to reach 95%. i The addition of "at a nominal voltage of 600 VAC" to the heator SR is administrativo, and clarifies that the purpose of the '

requiremont is to detect heator degradation. 'Ihis change involvos no significant hazards consideration.

Footnotes and statomonto related to the footnotes in the Fuel Handling Vontilation Exhaust System TS which expire on August 26, 1991 have boon removed. This change is administrativo, and involves no significant hazards consideration.

The change to SR 4. 6.1. 8.d. 2 for the Annulus Ventilation System corrects an error in the SR. The system actually starts on a safety injection signal. This chango does not reflect an actual change to the plant, it reflects a correction to an error in the Specifications. This change involves no significant hazards consideration.

The proposed Technical Specification change has boon reviewod against the critoria of 10 CFR 51.22 for environmental considerations. As shown above, the proposed chango does not involvo significant hazards consideration nor increase individual or cumulative occupational radiation exposure. Based on this, the proposed amendment moots the critoria given in 10 CFR 51.22(c)(9) for categorical exclusion from the requirements for an Environmental Impact Statement.

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