ML20076E343

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Proposed Tech Specs 4.6.1.8.b.1,4.6.1.8.e,4.6.1.8.f, 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 & 4.7.7.f Re Bypass Leakage Criteria of 1%
ML20076E343
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 08/12/1991
From:
DUKE POWER CO.
To:
Shared Package
ML20076E339 List:
References
NUDOCS 9108190264
Download: ML20076E343 (23)
v • d • e


Text

{{#Wiki_filter:r, y \\tf q b c,' v r-Q -+"- l PLANT SYSTEMS J f [t-e ] fi i ( -r f 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM !od l-r - N i r- ' i @ ci { <[ o. : / Q. 7 LIMITING CONDITIOk FOR OPERATION lMJ( \\q) ~J ] y) X 5 3.7.6 Two independent Control Room Area Ventilation Systems shall be W DPERABLE. h }q) D D d n" EPLICABILITY: ALL MODES Q ' 72 ACTION: (Units 1 and 2) n W '%' N gLd Sec r ea ba n s cNn o^ k % Cw M ox ODES 1, 2, 3 and 4: num F.w 41.v.b und b'ysteminoper N h L CA. With one Control Room Area Venti ~ the io inoperable system to OPERABLE status within 7 days or be in at least HOT q) d,< STANDBY within the next 6 hours and in COLD SHUTDOWN within the following @ 1 '. 9 _ / N y ]ib r)V 30 hours. anci'd 7.(p% h.C.4, hW DC QDES'S and 6'. bccmuscW(

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s es ttQ, H. 7 7 f 5. d ;; a. With one Control Room Area Ventilation System inoperabl restore the inoperable system to OPERABLE status within 7 days r initiate c.3 v and maintain operation of remaining OPERABLE Control _ Room Area - g (I Ventilation System. or i ude n s c i ne r b m n W. vuu t h ks F ed i r 4.16

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._o t-j b. With both Control Room Are Ventilation Systems inoperabl, er with pc the OPERABLE Control % m Area Ventilation System, requirs to be w - 4y 9#h operating by ACTI% a., not capable of being powered by an OPERABLE q -5,, emergency power source, suspend all operations involving CORE 7gyy ALTERATIONS.; positive reactivity changes. Cbd The provisions of Specification 3.0.4 are not applicable. c. -no o T:c w , j 3URVEILLANCEREdu!REMENTS N oSS TIh /)g 3 v,4.7.6 Each Control Room Area Ventilation System shall be demonstrated j& t-G. 3PERABLE: i vvyob ]$ d C y a. At least once per 12 hours by verifying that the control room I *dCG air temperature is less than or equal to 90 F; l C 6 Gh At least once per 31 days on a STAGGERED TEST BASIS by initiating, To' b. i fMCf(p ,from the control room, flow through the HEPA filters and activated -SO carbon adsorbers and verifying that the system operates for at least y O y 0 C C,j ' 10 continuous hours with the heaters operating; $Cd0Od e o 9108190264 910R12 d PDR ADerK 03000413 d O,P ,,o F-PDR 0ec u ') v ,d'~'~ ATAWBA - UNITS 1 & 2 3/4 7-14 M endment 5. '8 (Unit 1) AgendKmnt Ne. 72 (Unit 2-) !(

\\ PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c. At least once per 18 months or (1) after 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 Regulstory Position C.S.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) VerifyiIgN)hin 31 days af ter removal, that a laboratory analys s+6f h representative activated carbon sample outained a nc4 with Regulatory Position C.6.b of Regulatory R O d ' O g "g P h n accup_LR Revision 2 March 1978,bccts the hboratory tening. C m 0 5SO N bCr'tzri; *f hi"I***r> P SiM"" C 6 3 of4 *S" ht m C"+d* + 5ih' MT h.i; ion 2, March 1978, ferJp methyl iodide penetration of less than 0.'7 " - i hc 0 W 3) Verifying e ow rate of 6000 cfm + 10% during system operation when tested in accordance with ANSI N510-1980, d. After every 1440 hours of activated carbon adsorber operation, by verifying, within 31 days af ter removal, that a laboratory analysis" ^'# of a representative activated carbon sample obtained in accordance and te5hdper with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, _ arch 1978 9 eee-t+-the-laborstery -te s t i ngami t e r k-o f4 egul a to ry-P o s i-T3Tm D2c3 c ftm c.e.*-ofde9uutory Cume+Es-Revb+en*Menn 1976,@w A / methyl iodide pent:tration of less than 0.17' hc(5 4 L r ' cg % v e. At least once per 18 months by: 1) Verifying that the pressure drop across the combined HEPA filters, activated carbon adsorter banks, and moisture separators is less than 8 inches Water Gauge while operating the system at a fl'ow rate of 6000 cfm : 10%; 2) Verifying that on a High Radiation-Air Intake, or Smoke Density-High test signal, an alarm is receivea 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 dissi ate 25 + mS_kW(andlbC '; s Ce t Ct'.N t' c \\ t ct tC N /% /

  • The requirement for reducing refrigerant concentration to 0.01 ppm may be satisfied by operating the system f or 10 hours with heaters u
    • Activated carbon adsorber samples are tested at 30 degree a m \\ ')5o/o Q.

CATAWBA - UNITS 1 & 2 3/4 7-15 -Amendment-Heres-{ Unit-13 Amendment 40. 7 9 (Un i t-4)-

lVC O h C( n C 6 ~ 1 pyhe I PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 5) Verifying that on a High Chlorine / Toxic Gas test signal, the system automatically isolates the affected intake from outside air with recirculating flow through the HEPA filters and acti-vated carbon adsorbers banks within 10 econds (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 ANSI N510-1980 for a 00P test aerosol while operatin0 the system at a flow rate of 6000 cfm : 10%; and g. After each complete or partial replacement of an activated carbon adsorber bank, by verifying that the cleanup system satisfies + e in place penetration and bypass leakage testing acceptance cri ia 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 ! 10%. CATAWBA - UNITS 1 & 2 3/4 7-16 Amendment No.78 (Unit 1) Amendment No.72 (Unit 2)

PLANT SYSTEMS BASES 3/4.7.5 STAN0BY NUCLEAR SERVICE WATER POND The limitations on the standby nuclear service water pond (SNSWP) level and temperature ensura 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 levci and maximum temperature are based on providing a ?0-day cooling water supciy to safety-related equipment without exceeding its design basis temperctura and is corsistent with the recommend-ations of Regulatory Guide 1.27, " Ultimate Heat S?nk 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 excr gers 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 containment pressure occurs when energy addition to containment (core decay heat) is balanced by energy removal from these heat exchangers. This balance it reached far out in time, after the transition from injection to cold leg recirculation and after ice melt. Because of the effectiveness of the ice bed in condensing the steam which passes through it, containment pressure is insensitive to small variations in containment spray temperature prior to ice meltout. To ensure that the RN temperature assumptions are met, Lake Wylie temperature is monitored. During periods of time while Lake Wylie temperature is greater than 86.5'F, the emergency procedure for transfer of ECCS flow caths to cold leg recirculation directs the operator to align at least one train of containment spray to be cooled by a loop of Nuclear Service Water which is aligned to the SNSWP. q 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM The OPERABILITY of the Control Room Area Ventilation System ensures that: (1) the ambient air temperature does not exceed the allowable temperature for M continuous-duty rating for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel f during and following all credible accident conditions. 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 y. buildup of moisture on the adsorbers and HEPA filters. The Control Room Area V Ventilation System filter units have no bypass line. Either Control Room Area C Ventilation System train must operate in the filtered mode continuously. _When l a train is in operation, its associatec heater also runs continuously.4 The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rems or less whole body, or its equivalen Thi s l imi-t+ti on i; oow .s4: tent : ith--the-requ4 resents--of-Gener-abDes4 n-Cr4 er4on-19-ofApend4LA, 9 10 CFR Part-50. ANSI N510-1980 will be used as a o ural uide for surveil-lance testing. gy q gj CATAWBA - UNITS 1 & 2 B 3/4 7-3a ^n n tent Nc. 78 (Unit 1) ^= n cent Ms. 72 (Unii 2)

e e Insert #1 The specified laboratory test method. namely. ASTM D3803 89, implica j - that heaters may be unavailable for con', rolling the relative humidity of j the influent air entering the charcoal-adsorbsr section to less t' ) equal to 70 percent. Tnis is acceptable, since accident analysis tt> appropriato adsorber officioncdes for radioiodine in elemental an J - organic ' tms based on the above test shows the control room radi 4. n within the 10 CFR Part 30. Appendix A. GDC 19 lituits desce a ug i desige '.* is LOCA conditions. Ilowever, specifications are incluesd to ensure heat.or opera'111ty and corrective ACTIONS are identified to . i address the contingenes of inoperable heaters: these are in place to increase the safety margin of the filters. i i P l' l lJ ' f f r k i

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N& 0., h a es ie PLANT SYSTEMS BASES The 18 month turveillance to verify a positive pressure of greater than 1/8 inch water gauge, with less than or equal to 4000 cfm of oressurization 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. l 3/4.7.7 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM Thi 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. Operation of the system with the heaters operating to maintain low humidity l l 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. l The operat ton of this system and the resultant effect on offsite dosage calcu-l lations was not taken credit for in the safety analyses. However, the operation l 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 p?ocedtral guide for surveillance testing. 1/4.7.8 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 utilizirq the same design features of the 2-kip, 10-kip, and 100-kip capacity manufactered 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 dif ferent type, as would hydraulic snubbers from either manufacturer. l A list 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 I 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. I CATAVBA - UNITS 1 & 2 B 3/4 7-4 Amendment No. 78 (Unit 1) l Amendment No. 72 (Unit 2)

TD ge ' [- C 4 REFUELING OPERATIONS df

Ng 3/4.9.4 CONTAINNENT BUILO!NG PENETRATIONS

{ vo 4 U k. 4 O e o,30 -, Q MITING CONDITION FOR OPERATION l .2 ; L ..**g l / t,, e {Von 3.9.4 The containment building cenetrations shall be in the following status: Oc. f j The equipment hatch closed and held in place by a minimum of four a. e -d3'J

bolts, 0

2I b. A minimum of one door in each airlock is closed, and -I t. c, 60y 0 c. Each penetration providing direct access from the containment j &.,;..+o atmosphere to the outside atmosphere shall be either: o. g 4 $c c 1) Closed by an isolation valve, blind flange, or manual valve, er 4 A :r t. 2) Exhausting through an OPERABLE Reactor. Building Containment y,$ p g Purge-System HEPA filters and activated carbon adsorbers, it >S u+ 4jgC APPLICABILITY,: Ouring CORE ALTERATIONS or movement of irradiated fuel within { &,oy the containment, v w Sh ACTION: "C"3 " 5

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l ~5 cg q,With the_ requirements of the above specification not satis immediately l Nf y q q g, suspend'all operations involving CORE ALTERATIONS or movement f irraciated fuel in the containment building. I?)Q n l Mh$ SURVE!tLANCE REQUIREMENTS f ! Pin io9"C_ l I p (9 '1 # N 4.9.4.1 Each' of the above required containment building penetrations sna11 ::e determined to be either iri its closed / isolated condition or exhausting througn j T0 an OPERA 8LE Reactor Building Containment Purge System with she capability of j l ) M. d d i being automatically isolated upon heater failure within 72 hours prior to the l C start of and at least once-per-7 days during CORE-ALTERATIONS or movement of-m - gA.j irradiated fuel in the containment building by: 1I h C-a. Verifying the penetrations are in their closed / isolated condition, 3 hii l j t, o b. Verifying the upper and lower containment purge supply and exhaust d y + cx $ valves close upon a High Relative Humidity test signal. .o n - h Y ! j sVC g.gP c - f336i .O

? REFUELING OPERATIONS SURVEILLANCE REQUIREMENTS (Continued) 4.9.4.2 The Rea.ctor Building Containment Purge System shall be demonstratea OPERABLE: i l a. At least once per 31 days by initiating flow through the HEPA filters and actitated carbon adsorbers and verifying that the system o?erates l l for at least 10 continuous hours with the heaters operating; b. At least once per 18 months or (1) af ter any structural main' 1ance on the HEPA filter or activated carbon adsorber housings, or j (2) 'u lowing painting, fire, or chemical release in any vent >1ation Zone communicating with the system by: 1) Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria.of r less than 1% and uses the test procedures guidance in Hgula-tory Positions C.S.a. C.5.c. and C.S.d* of Regulatory Guide 1.52, Revision 2. March 1978, and the s stem. flow rate is 25,000 cfm i 10% (both exhaust fans operatin ); 2)- Verify n wi in 31 days after removal, that a laboratory analys %5f a representative activated carbon sample obtained l y( in accordance with Regulatory Position C.6.b of Regulatory Mg g.gt I . Guide 1.52. Revision 2: March 1978.wc:t --the laboratory--testing-r ~ itsi: of4eguletory-40stt4on4r6ra--of4egulatory4uide4,52 4 $S p,OffD3 -GrRevitkn 2 Merch lWe, fe-a methyl iodide penetration of less 5 than 6%; and g 3) Verifying a system flow rate of 25,000 cfm t 10% (both exhaust fans operating) during system operation when tested in accorcance with ANSI N510-1980. j After every 720 hours of activated carbon adsorber operation, by c. verifying, within 31 days after removal, that a laboratory analysi N f a representative activated carbon sample obtained in accordance l C\\nc\\heSkfC) ith Regu'.atory Position C.6.b of Regulatory Guide 1.52, Revhion 2, ~ March 1978,3 ::t: the 12:eatoey-tet4*g-ce4+rt; cf 9:guistoey40s t-MSTWYM. bh tion-tMne-ofdeguhtery-Guke--1752, Revishn47-March-1978, y a methyl iodide penetration of less than 6%; bw 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

  • The requirement for reducing refrigerant concentration to 0.01 ppm may be l

M tisfied by,,opitatM g the system for 10_ hours W eLa_ters on an ooerating, a Mc;\\ dcd ed CDS DC' G CV_hcrbe C mm pies M e_ 4ed ed a J $O *f. CwC hW CATAWBA - UNITS-1 & 2 3/4 9-5 ^m n A nt h.M ' Unit 1)- Ah--A um S o /Iln d 6

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4 REFUEL.ING OPERATIONS SURVL'.g2(CEREQUIREMENTS(Continueo) 2) Verifying that the filtfL_tr.ain dujLheater dj,sJimtteL/ h s 120 t 12 k A ne. miM g e\\ \\.cte e:. c4 OCC\\HC g w After each complete or partia replacement of a HEPA filter Dank, b7~~'- e. 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 i 10% (both exhaust fans operating); and f. After each complete or partial replacement of an activated carbon i 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 accoidance with ANSI N510-1980 for a halo-genated hydrocarbon rsfrigerant test gas while operating th-

tem at a flow rate of 25,000 cfm i 10% (both exhaust fans operat,ag).

i l l l l l l CATAWBA - UNITS 1 & 2 3/4 9-6 Amendment-bS(-Unit-lb -Amendment-No-M43ntt4F

f. k; 0\\g nc Q hl + fhC 3/4.9 REFUELING OPERATIONS BASES 3/4.9.1 B$NCONCENTRATION the limitations on reactivity conditions during RErVELING ensure ttat: (1) the reactor will remain suberitical 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 dilutier, incident in the safety analyses. The value of 0.95 or less for K,ff includes a 1% ak/k conservative allowance for uncertainties. Similarly, 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 Mitigat 'n System ensures that inonitoring capability is available to detect changes in the reactivity condition of the core. 3/4.9.3 DECAY TIME The minimum requ'.rement for reactor subcriticality prior to movement of c irradiated fuel assemblies in the reactor vessel ensures tnat suf ficient time l has elapsed to allow the radioactive decay of the short-lived fission products. l This decay time is ennsistent with the assumptions used in the safety analyses. 3/4.9.4 CONTAINHENT BullDING PENETRATIONS The reouirements on containment building penetration closure and OPERABILITY of the Reactor Building Containment Purge System ensure that a release of radioactive material within containment will be restricted from leakage to the 1-l environment or filtered through the HEPA filters and activated carbon adsoroers prior to release to the atmosphere. The OPERABILITY and closure restrictions are suf ficient to restrict radioactive inaterial 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 rutomatic 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 l for surveillance testing. l l CATAWBA - UNITS 1 & 2 B 3/4 9-1 Amendment No.39(Unit 1) Amendment No.31(Unit 2)

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[ ,[ LlHITING CONDil!0N FOR OPERATION Q ~~ ~ f{/ 3.6.1.8 Two independent Annulus Ventilation Systems shall be OPERABLE. +j'n 3 and 4 r N ^v' N 'l APPLICABILITf: MODES 1, 2, & v.- ~ w o.n : ItW C O\\h O. ' i ACTION: I M{t/ \\J'@2g U h 93@; b D(') s

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. Fith one Annulus Ventilation $7sf.em inoperable,' restore the inopirable system ,. s 3 s s to OPERABLE status within 7 days or be in at i-ast HOT STANDBY *ithin the next l

oa {. l-6 6 hours and in COLD SHUT 00WN within the following 30 hours.

+2 3 s y. ,s u OT U( SURVEILLANCE REQUIREMENTS M ma~gJ;( 7 v-)i O v' 4.6.1.8 Each Annulus Ventilation System shall be demonstrated OPERABLE: 4-C d # 6cCy At least once per 31 days on a STAGGERED TEST BASIS by initiating, h a. 4 M53? from the control room, flow through the HEPA filters and activated L {x 2%0 CF.rbon adsorbers and verifying that the system operates for at least l wv-C, 10 continuous hours with the pre-heaters operating; gs JN~jU b. At least once per 18 months or (1) after any structural maintenance f y [ ; -_,, on the HEPA filter or activated carbon adsorber housings, or (2) fol-I lowing painting, fire, or chemical release in any ventilation :ene v v communicating with the system by: -Ory7 7 2 '3 : \\ 0 1) Verifying that the cleanup system satisfies the in-place pene- '$ \\ tration and bypass leakage testing acceptance criteria of less 7 [0 y than 1% (Unit 1), 0.05% (Unit 2) and uses the test procedure T guidance in Regulatory Positions C.S.a, C.5.c, and C.5.d* of oi c I '& Regulatory Guide 1.52, Revision 2, March 10 8, and the system f g, ' flow rate is 9000 cfm 10%; MyrC 54 2) Verify' ith a 31 days after removal, that a laboratory l fI2 t analys representative activated carbon sample obtained i ; i eV?% $ in accor ce with Regulatory Position C,6.b of Regulatory LU0.0 ' QOCI N Guide 1.52, Revision 2, MarchJ2fLeaceh -the 120 eat +rydest4ng -

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p$3Tm 0MC 3' evh h --2, Hetch-1WB, fttaa methyl iodide penetration of less K 4teMa-o Aegu4 to ry-#es4t4oM4ra-of-Regul+t-oey-Gui40 1.52, l 1 C C h [ 5 8pc 3) VerifythgYsystem flow rate'of 9000 cfm ! 10% during system T ?(h$ operation when tested in accordance with ANSI N510-1980.

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/ U ed : v.W"n he requirement for reducing refrigerant concentration to 0.01 ppm may be 3 satisfied by operating the system for 10 hours with heaters on and operati.'g. 1 .O l CATAWBA - UNITS 1 & 2 3/4 6-14 %eneent Mc. " (Unit 1+- AmendmeNcNc. 20 (Unit 2)

4 CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) c. After every 720 hours of activated carbon adsorcer operation, by .~{ verifying, within 31 days after removal, that a laboratory analysis. ' of a representative activated carbon sample obtained in accordance ~ l GOcI I Qi cd gli" with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2, March 1978 geetc the !& oratory-test 4no-er4ter44-of4eguistory-434-p" l iy. gW J cg/ 44+n4r61-a-of-49ulatery-Gu4de--Ir62r ev b4endrMarch-1978r, fem .g a methyl iodide penetration of less than_ g s 70 ) d. At least once per 18 n,onths by: v 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 the lytter at a flow rate of 9000 cfm i 10%; p& p l,yech 2) Verifying that the system starts automatically on any T e d 'E -isolat4on test signal,** 3) Verifying that the filter cooling electric 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 annulu ( j ^ within 1 minute after a start signal, and Ai a, a. i m uu 5) Verifying that the pre-heaters dissipate 45 t 6.7 kg. A l b ' 'I \\ IcC y dC., N, e. After each complete or partial replacement of a HEPA filter ank, 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 : 10%; and f. 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 1% (Unit 1), 0.05% (Unit 2) in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 9000 cfm 10%.

    • This surviillance need not be perf ormed until rior to entering HOT y N f

. M h ing the Uni frAre f uel i ri W ed O_t cCEL, d 3g"tgg n M4 i\\d.m\\W cm wo at ac e b e r wy 5 05 C CATAWBA - U 3/4 6-15 Amendment 4cs(enM-It emot u.muna n

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BASES 3/4 6.1 9 ANNU WS VENT'LAi!0N SYS?!u Tne OPERABILiiY of the Annulus Ventilation System ensures that cucin;

  • ,,0 A

conditiers. containPent vessel leakage into the annulus will be filterec thr: q the MEDA filters and activatedcaroon aoserber trains prior to discharge to toe [ stmosonere. Coeration of the system with the heaters coerating to maintain lo. humidity using automatic control for at least 10 continuous nours in a 31 cay perloc is suf ficient to reouce the Duildup of moisture on the adsorbers and MEDA filters. Tmt-rettr4 *emen t-45-eec e s s a ry-to-mee t-t he-a llump t 40ns-u s e 0-in-t he-s a f e t y -e nelys e s-4 n4 14a44_4ne_S !M-3004A Ar a d i a t 40n-cos e s -to + i t h i n-the-00 $e -gv+ ce-h+-v41ve: Of-IC CM Aar4-lM-emng44CA40ndit40nsq ANSI N5101!80 -ill ce usedasaprocecuralguioeforsurveillancetestygyl, _ hlc{cl I nSt C D 3/4 6.1.9 CONTAINu!NT PURGE SYSTEWS W-._ p - / ~ The containment purge supply and exhaust isolation valves for the lower compartment 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 curing a LOCA. Maintaining these valves sealed closed during plant operations ensures that excessive cuantities of radioactive materials will not be released l via tne Containment Purge System. To provide assurance that these containment valves cannot be inadvertently opened, the valves are sealed closed in accort-ance with Standarc Review Plan 6.2.4 which incluces mechanical devices to seal or lock tne valve closed, or prevents power from being supplied to the valve operator. l 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 Syst.em 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 hours curing a calendar year for the t 4 inch valves. The total time the containment purge (vent) system isolation valves may be open during H0 DES 1, 2, 3, and 4 in a calendar year is a function of anticipeted need and operating experience. Only safety related reasons-e.g., containment pressure control or the reduction of cirborne radioacti

y 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 !.upply and exhaust valves will provide early indication of resilient material se61 degradation and will allow opportunity for repair before gross leakage failures could develop. The 0.60 L, leakage limit of Specification 3.6.1.2d. shall not be exceeded when the leakage rates determined by tne leakage integrity tests of these valves are added to tne previously detseminec total for al' valves and penet. rations suoject to Type B anc C tests. CATAWBA - UNITS 1 & 2 5 3/4 6-3 -A+enoment-- E F (U"MY Amenement-fte-MdUn&tY

~ _. - - -. - _.... ~.... 9 Insert #2 The specified laboratory test method, namely, AST!! D3803-89, implies that heaterc may be unavailabic for controlling the relativo humidity of the influent air enterin;; the charcoal adsorber section to less than or equal to 70 percent. This is acceptable since accident analysis with appropriate adsorber efficiencies for radiolodine in elemental and organic forms based on the above test shows the site boundary radiation doses to be within the 10 CFR Part 100 limits during design basis LOCA conditions, llowever, specifications are included to ensure heater operability and corrective ACTIONS are identified to address the contingency of inoperable heaters these are in place to increase the safety margin of the f11ters. s I i I i i i 1 - I l [ t t I l-l i =.. -..

~v 0 1 c . $ k ll REFUELING OPERATIONS ~ +. ~ 3/4.9.11 FUEL HANDLING VENTILATION EXHAUST SYSTEM "30/ o t dI I'{hh LIMITING CONDITION FOR OPERATION e e_ h0$ 3l-

3. 9.1' At least one train cf the Fuel Handling Ventilation Exhaust System obe shal' be OPERABLE.

j% a: Q $ h AsPLICABILITY:Whenever irra g d th G arag g .t C A] ACTION: per i tmc m, cht \\nuo et b e cW D -i c-q,g g g q, ,gg, ,c 4 3 a. With bot i ng Ve lation E ust System bJ inoperable., suspend all operations involving movement of fuel within )[g40 the storage pool or crane operation with loade over the storage pool i a ? until the Fuel Handling Ventilation Exhaust System is restored to j RABLE status. ! y ga C The provisions of Specification 3.0.3 are not applicable. 4ec0 gw -f 3g j SURVEILLANCE REQUIREMENTS 1 Lu )dy 4.9.11.1 One train of the Fuel Handling Ventilation Exhaust System shall be g g determined to be operating and discharging through the HEPA filter and acti-g y vated carbon adsorbers at least once per 12 hours whenever irradiated fuel is g o' oeing moved in the storage pool and during crane operation with loads over the ~ % 4] storage pool. C s 3 Oy .9.11.2 Both trains of the Fuel Handling Ventilation Exhaust System shall be V

lemanstrated OPERABLE:

r-7 n t0 C' G s< At least once per 31 days by initiating, from the control room, 7b.$ ; $ flow through the HEPA filters and activated carbon adsorbers and a. j Z ;7 verifying that the system operates for at least 10 continuous hours 7_ I 0 with t,he heaters operating; C3a (~ b. At least once per 18 months or (1) after any structural maintenance a4 on the HEPA filter or activated carbon adsorber housings, or (2) fol-i lowing painting, fire, or chemical release in any ventilation zone 3 ( g 0-communicating with the system by: w3 2 1) Verifying that the cleanup system satisfies the in-place, e Yn penetration and bypass leakage testing acceptance criteria c fl o 3 of less than 1% (Unit 1), 0.05% (Unit 2) and uses the test ~ p1 l procedure guidance in Regulatory Positions C.5,a C.S.c, and p C.S d* of Regulatory Guide 1.52, Revision 2, March 1978, and jga r-c. - @ [ the system flow rate is 16,565 cfm 2 10%; 4f: ) 0-u ; Ow*fTherequirementforreducingrefrigerantconcentrationto0.01ppmmaybe .I

c. 3

'3 M [ satisfied by operating the system for 10 hours with heaters on and operating. ATAWBA - UNITS 1 & 2 3/4 9-14 ke ndmnt N;. '.0 (Un+t-1-)- -4 Amendment L. 4 (Unft 2)- V

REFUELING OPERATIONS SURVEILLANCE REQUIREMENTS (Continued) p n y Verify ,djthin31daysafterremoval,thatalaboratory 7 analy rdo Va represetative activated c4rban saple obtailed f y a.Mgcg y (- in acc Nance with Regulatory Positions C.6.b of Regulatory i y AST m 03703 -E3 r Guide 1.52. Revision 2, March 1978,ptMbontery-test 4+ng j v .d M teris f~%gu4aterf4es44en C.T. & ef-4egutetory Guidc 1. 52, . Aavieio9-2r March-1978, :: :upplemented -by-ASTM-OBB0b6&--4est -Hethod "A"*,Soe a methyl iodide penetration of less than Ak Q{] and LtY/ _. 3) Verifying a system flow rate of 16,565 cfm i 10% during system operation when tested in accordance with ANSI H510-1980, c. After eve 720 hours of activated carbon adsorber operation in any train (fying, within 31 days after removal, that a laboratory analy(1 of 1 representative activated carbon sample obtained in omei Te5 becher.accordan'se,with Regulatory Position C.6.b of Regulatory G hyi31on 2. March 1978 pet:- th: l aboratocy-ten 4fwJ-eP4 tem 4-of-Reguhrtory-Pes +t4cn C. 6. O cf-Reguletory-Gu4de-1r&2v-Aev4644n-2, ASTM 0STo3 -B] March-1970, 0: Outplemented-by-ASTM-J3803-8&r-Te Sthod "A"*, M ' for-a methyl iodide penetration of less than G-74. c/g w d. At least once per 18 months for each train by: 1) Verifying that the pressure 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 rate of 16,565 cfm 1 10L I 2) Varifying that the system maintains the spent fuel storage pool area at a negative pressure of greater than or equai 'o % inch I Water Gauge relative to the outside amosphere during system operation, 3) Verifying that the filter cooling bypass valves 01.a. be manuali, opened, and 4) Verifying that the heaters dissipate 80 + a kw/-17.3 x A G C C V AC_ y) me At o. netoscu\\ W oWo.g e, o 's l Mke-of-A&TM-03803-SS, Test-Method " A" :: Supplemed-app 440 untib August 25, 1991. There:f ter, the-sueve444ane: requineent cha+1-eeaA l .. meet: the 12or4 tory-test 4cg criteria Of -Regulatory-pos& tion-Cr6ta-of gulatoef-Guide-4r627-Revision 2, " arch 1070, for

thy 4-4ed44e

-pendestrion-of les: than IL" until August 20, 1901. Thereafter r-the- "80

  • yV/-17. 3 kW-applie:surve...: nee readment-shal4-nad "V H fyin that-megAg aP m

_A dn-r N-00-*O a.c\\sorbe r sa.mp\\es o.re. hested n v 3c c. cmd 15 e fw ( 4 ATc Wedeci carbon ~ n s

.i. (( c L h ti nc e 5 'tC j-h i s g?CL 6 REFUELING OPERATIONS SURVEILLANCE REQUIREMENTS (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% (Unit 1), 0.05% (Unit 2) in accordance with ANSI N510-1980 for a 00F test aerosol while operating the system at a flow rate of 16,565 cfm i 10%; and i f. After 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 bypass leakage testing accept-ance 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 16.565 cfm i 10%. t I o CATAWBA - UNITS 1 & 2 3/4 9-16 Amendment No. 75 (Unit 1) j Amendment No. 69 (Unit 2)

a [ l REFUELING OPERATIONS L BASES f 3/4.9.9 and 3/4.9.10 WATER LEVEL - REACT VFSSEL 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 q -be filtered through the HEPA filters and activated carbon adsorber prior to discharge to the atmosphere. Operation of the system with the heaters operat-4 ing to maintain low humidity using automatic control for at least 10 continuous i hours in a 31-day period is sufficient to reduce the buildup of moisture on 1 l D the adsorbers and HEPA filters. .TAe-44RA84MT-Y--cf tH: ;yste and-- tac re;ul4~ 4ag-4cdine rc=e4-eepee4 ty-ere-consistent with-the assumptivos vise witty-n 7 -analyses;1 ANSI N510-1980 will be used as a precedural guide for surveillance i T sting. AGTM-0380346H+s t-Me the d J A"-wi44-be-us ed-fee-+u ev e444 a nc e-t es t4 ng l ( labora to ry-te st)-Jo r--me thy l-4 odi de-pe net ee t i on-in-4 4 etro f-the-4 e bo re tory-t es t-l %4 gacifded 4n Regulatory-Guide-1752rRev. 2,44aech-1978, Reguletcry Position-l D C. 0, s. <N The ASTM 4300346-ttst-method-uses-a-re4etive-humidity-of-95%- at i 30 C. The-use-of-this-tes t-and-the-acceptance-teiterion-of 1-methy4-4od4de i penet+a t4on-o f--less-t han-Or7-1ba re-cons 4 sten t-w 4 tir-a s s umed-deeont amina t4on-e-f44efene4++-of-9'W This-change-eesulted-f com-the-4ewee-system-hea ter 44 pac 44y-seing-C g raded-vo44 a ge-c ondit i on:. The-use-of-A5rTM-M80346-wal apply-unt44-August-26r1991r-Th4+-date-corresponds-to-the-next-dus-date f-or- { 4he-18-month--serve 4Mance-on-Unit 2. The-Unit-2-date4s-used-for-bctn uni ts-beeeuse--the-ned--18-month-inspest4on-date-for-Un4t--1, Dec+mben--13r1990r-wi44 i .not.-a4Jow for suf4tc4snt-44me-to-ev44uate-A5iWM803-89c [ 1 l l l l l t CATAWBA - UNITS 1 & 2 B 3/4 9-3 Amendment-No. M (Unit--1) l ' cadment-No. 09 (Unit 2) - \\-

Insert ll3 The specified laboratory test method, namely ASTM D3803-89, implies that heaters may be unavailable for controlling the relative humidity of the influent air entering the charcoal adsorber section to less than or equal to 70 percent. This is acceptable, since accident analysis with approFriate adsorber efficiencies for radioiodino in organic and inorganic forms based on toe above test shows the site boundary radiation doses to be well within (i.e., < 25 percent) the 10 CFR Part 100 if.mits dering desiga basis fuel handling accident outside the containment. However, specifications are included to ensure heater operability and corrective ACTIONS are identified to address the contingency of inoperable heaters: these aro in place to increase the safety margin of the filterse b 4 1 .l ~ .. - - -. - ~. _ _, _.... _..

Mn\\ Qu l4 4 o g & ~M PLANT SYSTEMS a s 1 0 3/4.7.7 AUXILIARY BUlt0 LNG FILTERED EXHAUST SYSTEM z y C Jr c: P -7 LIMITING CONDITION FOR OP. ATION

  • r.

u 55A Jce 3.7.7 Two independent trains of the Auxiliary Building Filtered Exhuu o Sys'em A 4' d shall be OPERABLE. ? 2 C 'A v ~y^x 3 04 APPLICABILITY: MODES 1, 2, 3, and 4. 1 gg ;p 3c c r etuc ni c i h.t i . ha,l' y ACTION: iN hecd4i5 S ?tciv,+cI ,,) -, g ;J' M K]. c t G Qcl 4 7, 7. cl, % r ( - T Q ith one train of the Auxiliary Building FilteTed TImilGyst'Mr-inopernil7, ^ ' + V7 +- d estore the inoperable train to OPERABLE status within 7 days or be in at east HOT STANDBY within the next 6 hours and in COLD SHUTOOWN within the following j 4 d,f 30 hours. w - u. f' ->+ @ % 3' SURVEILLANCE REQUIREMENTS vs s c-hC Q t N 'D 3 4.7.7 Each train of the Auxiliary Building Filtered Exhaust System shall be d j pC demonstrated OPERABLE: d 70 a. At least once per 31 days by initiating, from the control room, flew t ~3 y c through the HEPA filters and activated carbon adsorbers and verifying j C P-o c y that the system operates for at least 10 continuous hours with the c. g [ h.f heaters operating; a r-X b. At least once per 1B months or (1) after any structural maintenance d? A on the HEPA filter or activated carbon adsorber housings, or (2) fol-l 1 l 1j. lowing painting, fire, or chemical release in any ventilation zone 'y. W ~ commt.nicating with the same by:

3 d p t

1) Verifying that the cleanup system satisfies the in-place r 3 N ') penetration and bypass leakage testing acceptance criteria of "Op~ less than 1.4 (Unit 1), 0.05% (Unit 2) and uses the test proce-dure guidance in Regulatory Positions C.S a C.S.c, and C.5.c" j c v o G of Regulatory Guide 1.52, Revision 2 March 1978, and the system +- g os q flow rate is 30,000 cfm 2 10%; Dh3} f' ' within 31 days after removal, that a laboratory Verify" M W representative activated carbon sample obtained l analys +$ 0Q-7 5 ayyl 4eQql v in accordance with Regulatory Position C.6.b of Regulatory Ya 9er gidQ.52, Revision 2. March _1978,TeeeM-the-4sboeaury tests a t q-ID N}DJy.o M w eer+ter4e-Toragulatory4 o,4.t4ce:C.s.:-o u egu44te3y-

  1. 9

-Ge4e--h6&r4eV44+n 2, "sech 1978, a methyl iodide penetra-D tion of lessthan-Bj-l0 and g ,f'+I

  • f -

L. a: v

  • The requirement for reducing refrigerant concentration to 0.01 ppm may be l J D

satisfied by operating the system for 10 hours with heaters on and operating, '.3 c( T l 3d t CATAWBA - UNITS 1 & 2 3/4 7-17 Amendment No. 37 (UM t I'- .o ^ cnd cnt No. 29 (Unit 2) - i i -~- - - ,._-.r,_ c -,e...

l PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) i 3) Verifying a system flow rate of 30,000 cfm : 10% during system opeiation when tested in accordance with AN3I N510 1980 c. After every 720 hours of activated carbon adsorber operation, by ~]#6 verifying, within M days after removal, that a laboratory analys J of a representative activated carbon sample obtained in accordance l G n d 4MC CI with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, P C (~ March 1978, -meet +-t+e-Labor 4 tory-4entag-wRer44-of--Regw14 tory-Mi= l A5ivn O' 50347 9"+l lodide penetration of less than@' * * " *S * * * "* + 6 M *d * * ***

  • 8'4 "'
  • methy Ms, pces d.

At least once per 18 months by: 1) Verifying that the pressure drop across the 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 i 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,"* i 3) Verifying that the system maintains the ECCS pump room at a l i negative pressure relative to adjacent areas, 4) Verifying that the filter cooling bypass valves can be manually opened, and 'N 5) Verifying that the heaters g 40 ! 4 kW r -- c 5- (, c c V tK1 anwnee.The, i e. After each complete or partial repT Rtu nt or a HETA fi Ner banT. N by 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) in accordance with ANSI N510-1980 for a 00P test aerosol while operating the system at a flow rate of 30,000 cfm 2 10%; and f. After each complete or partial replacemer.t 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 L% (Unit 1), 0.05% (Unit 2) in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas wnile l operating the system at a flow rate of 30,000 cfm i 10%. ~ t t

    • This surveillance needJtoQ performed until prior to-.rqtering HOT 5HUTDC'aCN

-h>110 wing theM-1'first refue44ng.- c, i y.y Mc.O vcd ed CG r bo n AcW o r be.c M m p l es cWe h5iect cd 300C co d U 4 5', w_ ,7 ~

  1. g CATAWBA - UNITS 1 & 2 3/4 7-18 4mendment !b. H (Un+t-1)

^ endment ib.29 (Unit-t)

PLANT SYSTEMS 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 inttke individually, the design basis which assumes reopening of the two intakes following N isolation on chlorine, smoke or radiation, is tested. 1 3/4.7.7 AUXILIARY BUILDING FILTERED EX4AUST SYSTEM The OPERABILITY of the Auxiliary Building Filtered Exhaust System ensures that radioactive materials leaking from the ECCS equipment within the auxilia y __. building following & LOCA are filtered prior to reaching the environment. Operation of the system with the heaters operating to maintain low humidity n 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.[ J The operation of this system and the resultant effect on offsite dosage calcu-lations 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. 3/4.7.8 SNUBBERS All snubbers are required OPERABLE to e iure 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, i Snubbers are classified and grouped by design and manufacturer but not by l 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 i l same type. The same design mechanical snubbers manufactured by Company "B" l for the purposes of this Technical Specification would be of a different type, l as would hydraulic snubbers from either manufacturer. A list of individual snubbers with detailed information of snubber location i and size and of system affected shall be availabie 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 'iroup. The determination shall be based upon the existing radiation levels and the expected time to per-form a visual i:npection in each snubber location as well as other factors asso-ciated with accessibility during plant operations (e.g., temperature, atmosphere, i 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 l accordance with Section 50.59 of 10 CFR Part 50. l i CATAWBA - UNITS 1 & 2 B 3/4 7-4 -Amendment-Nov-M-Wnit4) Amendment-No. 72 - (Unit-2) .--- -----k-u- --im.-

  • w

---a .e--a g- ,-o

a s Insert (14 The specified laboratory test method, namely. ASTM D3803-89 implies that heaters may be unavailable for controlling the relative humidity of the influent air entering the charcoal adsorber section to less than or equal to 70 percent. This is acceptable, since accident analysis with appropriate adsorber efficiencies for radiciodine in elemental and organic forms based on the above test shows the site boundary radiation domes to be within thu 10 CFR Part 100 limits during design basis LOCA conditions. Ilowever, specifications are included to en=ure heater operability and corrective ACTIONS are identified to address the contingency of inoperable heaterst these are in place to increase the safety margin of the filters. l l-.}}

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