ML20092H812

Proposed TS 3/4.7.7 Re Auxiliary Bldg Filtered Ventilation Sys Exhaust Sys

ML20092H812
Person / Time
Site:	McGuire, Mcguire
Issue date:	02/05/1992
From:	DUKE POWER CO.
To:
Shared Package
ML20092H809	List: ML20092H806 ML20092H812
References
NUDOCS 9202210368
Download: ML20092H812 (6)

Text

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PL' ANT SYSTEMS 3/4.7.7 AUXILIARY BUILDING FILTERED VENTILATION EXHAUST SYSTEM

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LIMITING CONDITION FOR OPERATION i

i 3.7.7 The Unit 1 and Unit 2 Auxiliary Building Filtered Ventilation Exhaust Systems shall be OPERABLE.

l APPLICABILITY:

MODES 1, 2 3, and 4.

ACTION:

(Units 1 and 2)

I With one Auxiliary Building filtered Ventilation Exhaust System filter a.

package inoperable, restore the inoperable filter to OPERABLE status within 7 days or be in at least 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 SHUTD15! within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, With one Auxiliary Building Filtered Ventilation Exhaust System flowpath b.

inoperable (except carbon and HEPA filter package components and except as addressed by c.1 and c.2 below) restore the inoperable flowpath to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within ths next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

With one Auxiliary _ Building filtered Ventilation Exhaust System able to c.1 i

maintain a negative pressure but unable to maintain 0.12S" WG at the ECCS pump room relative to outside atmosphere, restore system ability to maintain 0.125" WG within the next 7 days or be in a least HOT STAND 8Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 t

hours.

With one Auxiliary Building Filtered Ventilation Exhaust System unable to c.2 maintain'a'_ negative pressure at the ECCS pump room relative to outside atmosphere, restore system ability to maintain a negative pressure within the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least 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 />, With both Unit.1 and Unit 2 Auxiliary Building Filtered Ventilation d.

Exhaust Systems-inoperable, restore at least one inoperable system to i

e OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or-be in at least 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 SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

}URVEILLANCEREQUIREMENTS 4.7.7.1 Each unit's Auxiliary Building filtered Ventilation Exhaust System

.. filter package shall be-demonstrated OPERABLE:

At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or carbon adsorber housings, or-(2) following painting, t

a.

fire, or chemical release in any ventilation zone communicating with the l

system, by:

McGUIRE - UNITS 1 and 2 3/4 7-16 Amendment No.113(Unit 1) l Amendment No. 95(Unit 2) 9202210368 920205 PDR ADOCK 05000369 j'-

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PLANT SYSTEMS SURVE!LLANCE RtQUIREMENTS (Continued)

(1) Verifying that the cleanup system satisfies the in place penetration and bypass leakage testing acceptance criteria uf less than 1% and uses the test procedure guidance of Regulatory Positions C.S.a. C.S.c and C.S.d of Regulatory Guide 1.52, Revision 0, March 1978, and the system flow r9te is 45,700 cfm t 10% (both fans operating - (Unit 1) or 40,500 cfm i 10% (both fans operating - Unit 2);

(2) Verifying within 31 days af ter removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2 March 1978, meets n ecceptance criteria for methyl iodide penetration at 30'C test temperature, and

/ert96 b.

Af ter every 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> of carbon adsorber operation, by verifying, within 31 days af ter removal, that a laboratory analysis of a representative car-bon sample obtained in accordance with Regulatory Position C.6.b of_Regula-tory Guide 1.52. Revision 2, March 1978, meets an acceptance criteria for methyl lodido penetration gof - at 30'C test temperature, and At least once perlH5f W

/d 18 months, by verifying that the pressure drop across l

c.

the combined HEPA filters and carbon adsorber banks of less than 6 inches Water Gauge while operating the system at a flow rate of 45,700 cfm i 10%

i (both fans operating Unit 1) or 40,500 cfm i 10% (both f ans operating -

Unit 2), and d.

After each complete or partial replacemtat of a HEPA.~ilter bank, by verifying that the HEPA filter bank satisfies the in place penetration and bypass leakage testing criteria of less than 1% in accordance with AN$1 N510-1980 for a DOP test aerosol while operating the system at a flow rate of 45,700 cfm

• 10% (both fans operating - Unit 1); or 40,500 cfm t 10% (both fans operating - Unit 2); and After each complete or partial replacement of a carbon adsorber bank, by e.

verifying that the carbon adsorber satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 45,700 cfm i 10% (both fans operating - Unit 1) or 40,500 cfm

• 10% (both fans operating - Unit 2).

4.7.7.2 Each Unit's Auxiliary Building Filtered Ventilation Exhaust System flowpath shall be demonstrated OPERABLE:

a.

At least once per 31 days, by initiating, from the control room, flow through the HEPA filters and carbon adsorbers and verifying that the system operates for at least 15 minutes, b.

At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or carbon adsorber housings, or (2) following McGUIRE - UNITS 1 and 2 3/4 7-17 Ameniment No.k /[ (Unit 1)

Amendment No.

g(Unit 2)

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TH is PA 6 E PLANT SYSTEMS i

SURVEILLANCE REQUIREMENTS (Continued) 1 i

I i

painting, fire, or chemical release in any ventilation zone communi-I cating with the system, by verifying a system flow rate of 45,700 I

cfm i 10% (both fans operating - Unit 1) or 40,500 cfm i 10% (both fans operating - Unit 2) during system operation when tested in l

accordance with ANSI N510-1980.

c.

At least once per 18 months, by verifying that the system starts on i

a Safety Injection test signal and directs its exhaust flow through I

the HEPA filters and carbon adsorbers.

4.7.7.3 Each Unit's Auxiliary Building Filtered Ventilation Exhaust $ystem shall be demonstrated OPERABLE, at least once per 18 months, by verifying that the system maintains the ECCS pump room at a negative pressure relative to outside atmosphere.

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McGUIRE - UNITS 1 and 2 3/4 7 17a Amendment No. Il3(Unit 1)

Amendmerit No. 95(Unit 2)

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February 5, 1992 NRC Document Contral Page 5 ATTACIIMENT 2 Description of Proposed Changes, Justification, and Safety Analysis PROPOSED Cl!ANGES The current wording for this Technical Specification (TS) is incorrect.

The intention of this chango is to correctly reflect the test acceptanco critoria that the NRC staff approved and documented in the Safety Evaluation Report (SER) for Amendment No. 113 and No. 95 to Facility Operating Licenses NPF-9 and NPF-17, respectively, on September 12, 1990.

JUSTIFICATION The staff found (as Duke indicated in the October 15, 1987 submittal justification) that the proposed acceptance critorion of less than 10% methyl iodido penetration (corresponding to a methyl iodido removal officiency greator than 90%)

is consistent with filter officienclos assigned by the staff for its independent calculations of offsito dose.

The TS wording error occurred when Duke's proposed change

stated,

... meets an acceptance critoria for methyl iodide penetration of 90% at 30' C test t6mperature,..."

A 10%

methyl lodido penetration is synonymous with a methyl iodide removal etficiency of 90%.

The proposal would have been accurately worded if

stated,

... methyl iodide removal officiency of more than 90%..."

or

... methyl iodide penetration of loss than 10%..."

SAFETY ANALYSIS compliance with the test acceptance critoria as it is presently worded in the Tech Spec would be irresponsible.

Most (90%), of the methyl iodide admitted into this filter system could pass through.

The Tech Spec change to match with the testing procedure would allow less than 10% methyl iodido to pass through.

The environmental considerations of offluent and personnel exposure were considered and confirmed acceptable in the Amendment No. 113 and No. 95 in the racility Operating Licenses NPF-9 and NPF-17, respectively on September 12, 1990.

Duke Power, therefore, concludes that this proposed change to TS Surve111ances 4.7.7.1(a)(2) and 4.7.7.1(b) has been, and la currently, technically justified.

i February 5, 1992 NRC Document Control Page 6 AT*TACHMENT 3 SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS The following analysis is provided, in accordanco with 10 Crn 50.91, to datormine whether or not the proposed change will involvo significant hazards consideration.

This datormination will be mado using the critoria of 10 CPR 50.92.

The NRC has provided guidanco concerning the application of the standards for determining whethor a

significant hazards consideration exists by providing cortain examplos (48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration.

Examplo (1) relates to a purely administrative change to Technical Specifications for examplo,.a chango to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature.

Example (i) above is applied in this case.

As discussed in the Technical Justification (Attachment 2), the reason for the technical specification change is to correct an error.

(1)

The proposed amendment would not involve a

significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS change from 90% to loss than 10% for methyl lodido penetration acceptanco criterion is moro conservative and is consistent with the licensing basis. This amendment corrects a typographical error and does not altur the basis of the previously NRC approved design.

This administrative change itself is not considered to be an initiator or a contributer to any previously evaluated accidents.

Therefore there is no increase in the probability or consequencor of an accident previously ovaluated.

(2)

The proposed amendment would not create the l

possibility of a new or different kind of accident not previously evaluated.

The Auxiliary Building Filtered Ventilation Exhaust system is l

an accident mitigation system and the proposed change merely corrects a typographical error in the Tech Spec Surveillance test criterion.

There is no change to structures, systems, components, or operating procedures.

Therefore, this change can not create the possibility of a new or different kind of accident from any accident previously evaluated.

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I February 5, 1992 NRC Document Control Page 7 i

(3)

No significant reduction in a margin of safety will f

occur.

The revised-acceptance values of the testing procedures continue to assure operability of the carbon filter as originally intended in the September 12, 1990 Staff SER. This is an administrative change to correct a typographical error, therefore the margin of safety is not impacted.

Note: The station's administrative acceptance criterion for methyl lodide penetration has been the proper amount (104) since issuance of the previous license amendment containing the error _(September 12, 1990).

Based on-the above, Duke Power concludes that this_ amendment I

request does not involve significant hazards as defined by 10 CFR 50.92.

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