ML20079Q324

Safety Evaluation Supporting Amends 91 & 92 to Licenses DPR-37 & DPR-32,respectively

ML20079Q324
Person / Time
Site:	Surry
Issue date:	01/17/1984
From:	Office of Nuclear Reactor Regulation
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ML20079Q323	List: ML20079Q324
References
NUDOCS 8402010102
Download: ML20079Q324 (12)

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NUCLEAR REGULATORY COMMISSION UNITFD STATES

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' SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 92 TO FACILITY 0?ERATItiG LICENSE NO. OPR-32 AND AMEN 0 MENT NO. 91 TO FACILITY OPERATING LICENSE NO. OPR-37 VIRGINIA ELECTRIC AND POWER COMPANY

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SURRY POWER STATION, UNIT NOS. 1 AND 2 00CKET NOS. 50-280 AND 50-281

[ntroduction By a letter datec August 31, 1976, and sucsecuently revisec in tetters datec May 9, 1977; October 23, 1980; February 3, June 7, July 29, August 5, ano 2.cvemcer.10, 1952; Virginia d6ectric Po.er Compar.y (VEPCO) proposec to amenc its M ?rst.ng Licenses DPR-32 anc DPR-37 'or Surry Power Station, Unit Nos.

1 and 2, by submitting a revision to the Apcendix A Technical Specifications.

The croposed changes -ere suomitted in response to our December 10, 1974 recuest anc consist of the additien to Technical Scecifications (TS) 3.22, 3.23, anc 4.20, and the revisions to existing TS 3.19 and 4.12.

Discussion Our ;etter of Decem er '.0, 1974 to VEPCO indicated tne nee 'ar au r ry. ur 1 *. Nas.

Inc 2, TS to include additional 1 terns to a s sur - that safet.

el3t.m air ilter systa9s would function reliably, when required, at a degree of ef fici ency equal to or greater than that assume <1 in previously perfomed accident analyses.

VEPCO responded to our request on August 31, 1975 inc 'ollowi ng di scus sions al th the '4RC staf f modified their rescense in letters datec a:.

1, 1977; nctober N, 1180; u

February, June 7, July 29, August 5, and November 10, 19S2.

8402010102 040117 DR ADOCK 05000280 PDR

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2 VEoCO's proposed changes to the TS include:

1.

audition of TS 3.22 and 3.23 which address the auxiliary ventilation exhaust and the control room ventilation supply filter trains, respectively; 2.

revisson of T h 4. I2 50 thdt it addresses ca'.y tht' au x i I i a rv

v. rit i I,i t i.1ri exhaust filter train and the addition. of a new TS 4.20 which eittitresse s the a

control room ventilation supply filter trains; and 3.

modification of TS 3.19 to prevent potential duplication and inconsistencies with TS 3.23.

VEDCO's proposal includes the expansion of present TS for the contro room air filtration system and the auxiliary ventilation exhaust filter trains sucn that the frecuency of tests are increased and the number of tests performed to establish the system's operability are also increased.

The changes were proposed by VEPC0 so that the specified filter test pecgram aculc confonn to the objectives of the model 15 included in our letter of December 10, 1974 Evaluation Our evaluation was based upon Positions C.5 (in-place testing criteria) and C.6 (laboratory testing criteria for activated charcoal) of Regulatory Guide 1.52, Revision 2. " Design, Testing, and Maintenance Criteria for Atmospheric Cleanup System Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants," and on the Standard TS for ESF air filtration systems for Westinghouse nuclear reactors (NUREG-0452).

The TS proposed by VEPCO include TS 3.22 and 3.23, which specify required operator action if the particular ESF filter systen is found inoperable, and TS 4.12 and 4.20 which increase the frequency and tne number of tests to oe performed to oewnstrate that tne system is coerable from the i

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e 3-required tests and frequencies presently specified in TS 4.12.

In adoi tion, TS 3.19 is revised to avoid potential duplication and inconsistencies with

-TS 3.23.

The following sections discuss TS which were adced or revised.

Main Control Rocm Bottled Air System (TS 3.19';

I' the bottled air systen is found to be innaaranle by *.ests s eci *ied i n TS 4.1, TS 3.19 requires that the unit be placed in the hot shutdown c0nditior within 8. hours.

If, nowever, during those 8 nours the control roon ventilation suoply filter trains are tested and found operable, then the unit has 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> before it must ce in'ene not snutoown condition if tne cottlea air systen is not made~. operable within that tine. -The licensee has proposed to delete the final sentence of TS 3.19, which further specifies a transition to cold shutdown af ter an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if the system is not made nperable. This deletion pre-vents cossible inconsistency between TS 3.19 and the precosed TS 3.23.

Evaluation and Findings The main control room bottled air system has the same safety function as ;5e control room ventilation supply filter trains, i.e., to pressurize the control room with respect to surrounding air volumes. The cottled air supply is

'incapaole of being contaninate'd by eitner radioactive releases within the plant or toxic gases released outside the plant, but is limited to the one-hour supply of bottled air contained in the system.

If the bottled air systen is found s.

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'noperacle, then the control room sentilation supply filter trains will ce tested.

Should that system also be found ino"erable, then further action will be dictated by TS 3.23.

If that system is found to be operable, then it can be reliec apon to protect the control room operators during the period of hot shutdown.

'The staf f finds that specification of the transition from hot to cold shutdown has been properly included in the new proposed TS 3.23, and should be deletea t a'

TS 3.19 to prevent botn duplication and possible inconsistency.

Auxiliary Ventilation Exnaast Filter Trains (TS 3.22 and 4.12)

The present Surry Technical Speci fications do.not have a TS which addresses the auxilicry ventilation exhaust filter trains.

VEPC0 has proposed TS 3.22 *nica details the conditions under wnicn tne system must be operable.

TS 3.22 also details what actions must be taken by the plant operator if the filter train is inoperable.

l VEPC0 has proposed, in TS 3.22, that both filter trains must be operable wnenever the reactor coolant temperature and pressure is greater than 350 F and 450 psig, L

respectively. With one exhaust filter system inoperable, VEPCO has preoosed ta2t continued reactor operation may continue for uo to 7 days.

If the inoperable train 1

is not made operable'within the 7 days, then the reactor must be in hot snutccwn 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 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

VEDC0 has also proposed that when one exhaust filter train becomes inoperable, the other train will be demonstrated immediately ard daily thereaf ter.

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e The present TS 4.12 addresses ventilation filter tests and cavers oct, tne auxiliary building ventilation and the control roca air filtration syster.s.

In the revision to TS 4.12 proposed by VEPCO, this specification will adcress only the auxiliary ventilation exhaust filter trains.

A new proposed TS 4.20 will aodress the control room filtration system.

The present T5 4.12 specifies in-olace tests of HEPA filters inc charcoal acsorbers once per 12-18 months.

ne acceptance criteria for these tests are 99.5*. removal of DOP and 99% removal of the freon for the HEPA filter and charcoal adsorber, respectivaly. Once every three years, a sample of the charcoal adsorcer is to be taken and analyzed. The charcoal is considered acceptable if the samole shows a removal ef ficiency of 99% or greater for elemental iodine.

VEPCO has proposed to increase both the frequency and the number of tests to be

. performed on the system to verify its operability.

In-place cold 00P leak tests for the HEPA filters and halogenated hydrocarbon leak tests for the charcoal I

adsorbers are now prooosed to be performed in accordance with AriSI N510-1975 following painting, fire or chemical release in any ventilation zone communicating with the filter system, after each complete or partial replacement of the HEPA 1

l filter or charcoal adsorber trays as appropriate, and af ter any structural maintenance on the filter housing. These requirements are in accvtion to the

-requirement for tests once per refueling cycle. The acceptance criteria for removal of the 00P and the~halogenated hydrocarbon, as proposed by VEPCO, remain the same at 99.5% and 99%, respectively. The licensee has proposed that lacoratory 1

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' analysis on the in-place charcoal samples De perforned initiallf, whenever 3 new batch of charcoal is used to fill the adsorber trays, once per refueling cycle, after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, folicwing painting, f tre, or chemical release in 7.ny ventilation zone communicating with the system or after any structural maintenance on the HEPA filter or charcoal adsorber housings.

The laboratory analysis for the charcoal adsorber has been prooosed to show 96", removal of rethyi iodine when tested using the procedures of ASTM 03803 with a residence ti~e of 3

0.125 seconds, a methyl iodine inlet concentration of 1.7510.25 mg/m, at a U

U relative humidity of 80% + 3% and an air temperature of 30 C + 0.5 C.

The licensee also proposed that the laboratory analysis of the charcoal adsorber shall be avail-able within 31 days of sampling and that if the laboratory results are unacceptaole, a;

ne a;svr;ent.in the af fec:ec filter snali ce replaceo witn new acsorcent qualified in accordance with Table 5.1 of ANSI N509-1976.

t VEPC0 has expanded the number of tests to be performed on the system to include monthly operation of' the system for 15 minutes; a denonstration of automatic startup, shutdown and flow path alignment once per refueling cycle; determination of flow-rate to be 36,000 cfm ; 100 af ter any structural maintenance on tne HEpA r

filter or the. charcoal adsorber, once per refueling cycle, or after partial or complete replacement of HEPA filter or charcoal adsorbers; visual inspection of the filter train and its associated comporents in accordance with the intent of ANSI N510-1975 before each in-place air flow distribu' tion test, 00P test, or halogenated hydrocarbon leak test; ~ pressure drop once per refueling cycle, after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation, and after each complete or partial replacement l

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. of HEPA filters or charcoal adsorbers with an acceptable value being less than 7 inches water gauge; and performance of an air distribution test across the prefilter bank after any major modification, repair or maintenance of the air cleaning system affecting filter bank flow distribution with an acceptable distribution being an uncertainty of air velocity within 3 20% of the average vel oci ty.

Evaluation and Findings The filter system covered by TS 3.22 and 4.12 is a system which has been modi fied f rom that presented in the Surry Final Safety Analysis Report (FSAR). The cnanges to this system were described in VEPCO's letters to the NRC dated August 9,1979 and May 29, 1982. Based upon information presented in these lett'ers, the " filter system will be utilized to filter the safeguards and charging pump cubicles in the event of a LOCA, the containment purge in the event of a fuel handling accident inside containment, and the fuel building exhaust in the event of a fuel handling accident inside this building. We conclude that it is acceptable for this filter system to be operable when the reactor coolant system's temperature and pressure is greater than 350*F and 450 psig, because the containment purge is covered in TS. 3.11 and refueling exhaust is covered in TS. 3.10.

VEPC0 proposed to demonstrate daily the operability of the one train if the other train is inoperable. We have previously taken the position with other licensees that a daily demonstration of the operability of a system does not increase the

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- likelihood of.its availability during a period of need.

If anything, it may contribute to the increase likC thood that such a system may not be available.

Therefore, the staff has deletad the requirement for daily demonstration of the available train as being operable. We have discussed this modification to VEPCO's proposed TS 3.22 and they have accepted our position. With these modifications to TS 3.22, the prooosed LCO i s acceptable.

In TS 4.12, VEDC0 proposed ten the laboratory analysis of the cnarcoal adsorcer be performed at a relative humidity of 80 3

1 ".. VEPC0 presented the staff an analysis which showed that the worst relativ-humidity that the adsorcers would see would be 76"..

iowever, in response to our question, VEPC0 indicated that for fuel handling accidents inside and outside containment, the adsorber could be treating air with a relative humidity of 95*..

Therefore, the laboratory nalysis proposed in TS 4.12.B.7 should be perfor ed at a relative humidity of 95 1 ".. We discussed 2

this with VEPC0 and they nave agreed to perform the laboratory analysis at the 95". relative humidity. With this change, the proposed TS 4.12 is judged to be acceptable.

Control Room ventilation Sucoly Filte.' Trains (TS 3.23 and 4.20)

VEPC0 has proposed to add TS 3.23, which addresses the control ventilation supply f11ter ' t rai ns.

Presently, there ~is not a TS which addresses this system. VEPC0 has proposed that these trains must be operable whenever either unit's reactor' 0

coolant system temperature and pressure is greater than 350 F and 450 psig, l

respectively.

With one train inocerable, reactor operation may continue for up l'

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-9 to 7 days. At the end of' the 7 days, the reactor Must be.in the hot snutdown condition within 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 38 naars

'f the ineperable system is not made operable.

As noted above. TS 4.12 oreviously addressed the control ventilation supply filter 4

system in addition to the auxiliary ventilation exhaust filter train. The licensee has precosed TS 4.20 to address only the control room system.

The present testing requirements for the control ventilation su: ply filter system 3re the same as tnose presented above for the auxiliary ventilation exhaust filter train. VEPC0 has proposed that the in-place 00P leak tests and the in-place halogenated hydrocarbun tests be performed at tne same frequency as was proposed for the auxiliary ventilation exhaust filter train. VEPC0 has proposec :nat laboratory analysis of charcoal adsorbers be performed at the same frequency as the auxiliary ventilation exhaust filter train except that for the control roon system no test will be performed af ter any structural maintenance on the HEPA filter or charcoal adsorber housings.-

VEPC0 has also proposed that tests such as air filtration system flow rate; monthly l

operation of the system for 15 minutes; visual inspection of the filter train and i

its associated components prior to each in-place air distribution test. 00P test or.halogenated hydrocarbon leak test; and pressure drop be conducted at the same I

frequency as the tests for the auxiliary ventilation exhaust filter trains except the air flow rate test shall also be performed following painting, fire, or chemical release in any ventilation zone conmunicating with the system and that the pressure drop test will not be performed af ter 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation.

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The acceptance criteria prcocsec #

ne ccntrol rcen sys.e"t tests tre

• e w m e for the auxiliary ventilation exhaust filter trains except that (1) tne procosac l

flow rate at hich the system is to be tested is a range of 750 to 1100 cim, (2) laboratory analysis of the charcoal adsorber shall show a removal rate of 96",

for methyl radioicdine when tested at a relative humidity of 95 ; 1",, and (3) tne acceptable pressure drop is 5 inches water gauge.

'e tests will be perfor ed in accordance with U151 N510-1975 as preocsed for the auxiliary ventilation exnaust filter trains and laboratory analysis of the cnarcoal will be performed in accordance with ASTM 03803.

Evaluatien and Findings VE?CO has prcpesed that this system needs to be operable only when either unit's 0

reactor coolant system is at a temperature and pressure greater than 350 F and 450 psig. However, it is important to protect the control room operators at all times.

Potential accidents which could occur with the reactor coolant system below this temperature and pressure are the fuel handling accidents inside containment and in the fuel handling building. Therefore, Item A of TS 3.23 should reflect this potentiaI situation by indicating that this system must be operable at all times. We have discussed this with VEPC0 and they are in agreement.

VEPC0 has agreed that Item A of TS 3.23 should be mudified to state that both trains of the system shall be operable whenever either unit is above cold shutdown.

To cover the case of refueling, a new Item 14 has been added to TS 3.10. A.

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' addition states that both trains of the control ventilation system shall be N:

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operable during refueling operations ano tnat if one train is inoperacle, tne remaining train must be demonstrated as operable by preforming the test of TS 4.20.A.1.

This addition to TS 3.10 also requires that refueling of the reactor must cease and no operation which increases reactivity of the core shall be made if both trains are inoperable.

This modification and addition eliminates the staff's original concern with respect to ref eling operations and tne coarability u

of the control room ventilation supply filter trains.

We find the proposed testing frequency and the acceotance criteria for the tests to be acceptable with the following exceptions:

1.

The proposed range of flow rates for tne system to be tested at is not acceptable. The maximum insult'to the charcoal adsorber will occur at the

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highest-flow rate. Therefore, the appropriate flow rate to use is 1000 cfm 10%.

2.

The laboratory analysis of the charcoal adsorber should be performed at a relative humidity of.95 ; 2% in accordande with ASTM 03803 rather than 95 + 1".

i We discussed these dif ferences with VEPC0 ano tney nave agreed to the modi fication listed in items. I and 2 above. With these cnanges, tne proposed TS 3.23 and 1.20 are acceptable..

Summary We have concluded that the proposed changes to TS 3.19 and 4.12 and the addition to TS 3.22,. 3.23 and 4.20 to the Surry TS, when modified by our comments, are acceptable..

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a as Environmental Consideration We have determined that the amendments do not autnorize a change in effluent types or total amounts nor an increase in power level and will not result in any, significant environmental impact. Having made this detennination, we have further concluded that the amendments involve an action which is insignificant from the standpoint of environmental impact and, pucsuant to 10 CFR 551.5(d)(4),

tnat an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of these amendments.

Conclusion-We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public.will not ce endangered by operation in the proposed manner, and (2) such activities will be conducted.in compliance with the Comission's regulations and the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.

Date:

January ll, 1984 Principal Contributor:

1. Hayes

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