ML20094M962

Proposed Changes to Tech Spec Pages 158,158A-C,172,174 & 174A Re Standby Gas Treatment Sys & Control Room High Efficiency Air Filtration Sys

ML20094M962
Person / Time
Site:	Pilgrim
Issue date:	08/09/1984
From:	BOSTON EDISON CO.
To:
Shared Package
ML20094M953	List: BECO-84-124, Application to Amend License DPR-35,changing Tech Specs Re Standby Gas Treatment Sys & Control Room High Efficiency Air Filtration Sys ML20094M962
References
NUDOCS 8408160045
Download: ML20094M962 (12)

Text

-

PRCPOSED TECHNICAL SPECIFICATION CHANGE  ;

Proposed Change l Reference is made to Pilgrim Station Operating License No. DPR-35, pages 158,

.158A, 1588, 158C, 172, 174 and 174A. These pages contain surveillances and limiting conditions concerning the Standby Gas Treatment System (SBGTS) and the Control Room High Efficiency Air Flitration System (CRHEAFS).

The specific sections to be changed are:

SBGTS (158, 158A) CRHEAF (1588. 158C) 3.7.8.1.a 3.7.8.2.a 3.7.B.1.b.(2) 3.7.B.2.b.(2) 3.7.B.I.c 3.7.B.2.c 3.7.B.I.e 4.7.8.2.c

• 4.7.8.1.a.(3.) Bases (page 174)

Bases (page 172) Bases (page 174A)

Currently, Sections 3.7.8.1.a and 3.7.B.1.c are superscripted with an asterisk which refers to a footnote which states, " Conditional Relief granted from this LCO for the period February 5, 1982 to startup for Cycle 6."

The desired revision deletes both asterisks and the footnote they reference on Page 158A.

Reference is made to Section 3.7.B.1.b.(2), which deals with the laboratory carbon sample analysis. No time frame is currently provided for ascertaining l that the test results demonstrate the charcoal filter's ability to retain methyl lodine consistent with this section.

A revision is proposed which shall add the following to 3.7.B.I.b.(2):

The analysis results are to be vertfled as acceptable within 31 days after sample removal, or declare the train inoperable and take the actions specified in 3.7.8.1.c.

l The Bases on Page 172 are changed to reflect this by the addition of the following:

i The 31 day requirement for the ascertaining of test results ensures that the l ability of the charcoal to perform its designed function is demonstrated and known in a timely manner.

Reference is made to Section 4.7.B.I.a.(3) which provides surveillance requirements concerning the Standby Gas Treatment System.

, Currently this Section references Section 3.7.B.I.b.(2). The proposed change will delete (2), thereby referencing 3.7.8.1.b, both subsections (1) and (2).

This change is to incorporate the appropriate subsection, (1), to address the DOP testing of HEPA filters and the halogenated hydrocarbon testing of the charcoal adsorber banks. As now written, Section 4.7.B.I.a.(3) only references the subsection which deals with the methyl lodine retention ability of the charcoal adsorber material.

DOC O 1_

P

y -

, 'c Currently, Section 3.7.8.1.c states:

From and after the date that one train of the Standby Gas Treatment System is made or found to be inoperable for any reason, continued reactor operaticn or fuel handling is permissible only during the succeeding seven days providing that within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and daily thereafter, all active components of the other standby gas treatment train shall be demonstrated to be operable.

The desired revision shall state:

From and after the date that one train of the Standby Gas Treatment System is found to be inoperable for any reason. continued reactor operation, Irradiated fuel handling, or new fuel handling over the spent ,

fuel pool or core is permissible only during the succeeding seven days providing that within two hours, and daily thereafter, all active components of the other standby gas treatment train shall be demonstrated to be operable.

Section 3.7.8.1.e now states:

Except as specified in 3.7.B.I.c, both trains of the standby gas treatment system shall be operable during fuel handling operations., If the system is not operable fuel movement shall not be started (any fuel assembly movement in progress may be completed). i The desired revision shall state: '

Except as specified in 3.7.B.I.c. both trains of the Standby Gas ,

Treatment System shall be operable during Irradiated fuel handling, or new fuel handling over the spent fuel pool or core. If the system is not operable, fuel movement may not be started. Any fuel assembly movement in progress may be completed.

These revisions precede the word " fuel" with " irradiated" to clarify the intention of the limiting condition, and to bring PNPS Technical Specifications into closer correspondence with Standard Technical '

Specifications for BWR's. (STS 3.6.5.3.a.2). -

t Additionally, this change allows the movement of new fuel in areas where damage to irradiated fuel cannot take place.

Reference is made to Sections 3.7.8.2.a and 3.7.B.2.c. The purpose of these sections is to describe the limiting conditions concerning the inoperability of one of the two trains of the Control Room High Efficiency Air Filtration '

System.

Currently, Sections 3.7.B.2.a and 3.7.8.2.c are superscripted with an asterisk which refers to a footnote which provides the same conditional relief described earlier regarding the SBGTS.

The proposed revision deletes both asterisks and the footnote they reference on Page 1588.

There is currently no time frame provided for ascertaining that the test results concerning the charcoal adsorbers associated with the Control Room High Efficiency Air Flitration System are in accordance with Section 3.7.8.2.b.(2.).

p a .

'The f;11owing shall be added t3 Section 3.7.B.2.b.(2):

The analysis results are to be verlfled as acceptable within 31 days after sample removal, or declare that train inoperable and take the actions described in 3.7.B.2.(c).

'The Bases on Page 174 are changed to reflect this additional constraint.

Currently 4.7.B.2.c states:

At least once every 18 months the following shall be demonstrated: ,

1) Operability of heaters at rated power.

The proposed change will state:

At least once every 18 months demonstrate the operability of the heaters at rated power.

This change is pr_o forma to simplify 4.7.B.2.c and make its format consistent with other Technical Specifications. The meaning is unchanged.

Currently, 4.7.8.3 does not contain a surveillance period for testing the humidistat ~which controls the heaters. This amendment provides such a surveillance period by adding "... once per 18 months" to the existing statement.

The Bases on Page 174 and 174A currently state:

If both trains of the system are found to be inoperable, there is no f immediate threat to the control room and reactor operation or fuel l handling may continue for a limited period of time while repairs are being made. If at least one train of the system cannot be repaired f within seven days, the reactor will be brought to a condition where the Control Room High Efficiency Air Flitration System is not required.

This will be deleted, and the following will be added:

In the event that one CRHEAFS 15 inoperable, the redundant system will be -

tested daily. This substantiates the availability of the operable system and justifies continued reactor or refuel operations.

If both trains of CRHEAF are inoperable, the plant is brought to a condition where CRHEAF 15 not required..

Reason for Change The time period for which the existing footnotes in 3.7.B.1.a and 3.7.B.1.c were applicable has expired, and deletion of the footnote and its associated asterisks is proposed to reduce confusion.

A review of STS (3.6.5.3.a.2), and the appropriate PNPS T.S. bases (p. 173) indicates that "irradlated fuel handling" was Intended where " fuel handling" now appears. This change serves to make this point clearer and reduces the possibility of misinterpretation. It also serves to clarify that new fuel may be moved providing such movement does not present the possibility of damaging irradiated fuel.

m

~

... +

\

lThe d:signation of a 31 ' day time ,linit for test results is proposed to ensure I

-that the-surveillance is completed in a timely fashion. Further, it: addresses Generic Letter 83-13,-dated March _2, 1983, wherein the NRC-requested such a time limit to reflect STS 4.6.5.3.b.2.

~

-I

,#s Changes are proposed to Sections 3.7.B.2.a and 3.7.B.2.c to remove the super-scripted asterisks and the footnote they reference on Page 158B because the

_ footnote no longe" applies.

The deletion of the (2) from the reference in 4.7.B.l.a.(3) is to broaden the requirements as described la 3.7.B.l.b.

The change to 4.7.B.2.c is made to make its format clearer and consistent with-other Techn'ical Specifications.

4 Changes to the Bases concerning CRHEAF are proposed to reflect the 31 day time limit for ascertaining test results, and to make the Bases reflect'the LC0 regarding the number.of inoperable trains of CRHEAF that are permitted.

Safety Considerationi The proposed changes to 3.7.B.I.c and 3.7.8.1.e do not compromise safety because the purpose of the Stand by Gas Treatment System is to mitigate the consequences of fission product releases. New fuel cannot cause fission product releases unless'it is dropped onto irradiated fuel and consequently damages it. Since this Technical Specification will not allow movement of new fuel in areas where such evolutions are possible, there is no reason to restrain the movement of new fuel because of SBGTS inoperability.

The proposed time limits aid in the assurance- that SBGTS and CRHEAF filters can retain methyl iodine, and does not compromise safety.

The proposed change has been reviewed and approved by the Operations Review Committee and the Nuclear Safety Review and Audit Committee.

Significant Hazards Considerations The Commission has provided guidance for the application of the standards for determining whether a significant hazards consideration exists by providing examples of amendments not likely to involve significant hazards considerations (48CFR14870). One such amendment involves a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications: for example, a more stringent surveillance requirement. This proposed change places an additional restriction in that it places a time limit on the verification of the carbon sample associated with Standby Gas Treatment System and the Control Room High Efficiency Air Filtration System. It further adds a restriction by changing the reference in 4.7.B.I.a.(3.), thereby expanding the requirements to be met during surveillance. This change is also consistent with STS and the instructions provided by NRC in Generic Letter 83-13. In changing the Bases on pages 174 and 174A, no significant hazards consideration exists because by removing the incorrect implication that two trains of the CRHEAF can simultaneously be out-of-service the Bases become more restrictive.

4

y.. '..

- LIn the casesof removing _theifootnotes, no significant hazards consideration R

exists because, as described in paragraph (1) of~48 CFR 14870, this is an . j Ladministrative. change made to remove a conditional relief which has expired.

Since:lt has expired this note has.no impact on technical' specifications and

'is a pro: forma action to unclutter pages 158 and-1588. The change to 4.7.B.2.c is also pro forma, and merely rewords the same surveillance-in a

-better format.

The changesLto Sections 3.7.B.I.c and 3.7.B.I.e concerning the operability requirements of SBGTS. involve no significant hazards consideration as exampled by section (vil of-48 FR 14870.In that the change either may result in some increase to the probability or consequences of a'previously-analyzed accident or may reduce .in . sone 'way.a' safety margin, but the results of the change are clearly withir.Lall' acceptable-criteria. Further, this change.is consistent with STS, which have previously been reviewed and; approved by the NRC.

For.the reasons discussed above. the changes proposed herein do not require the application pf a significant hazard consideration because the operation of

. Pilgrim Nuclear Fower. Station in accordance with these proposed changes would not (1)' involve a significant increase in the probability or consequences of

-an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or-(3)

-involve a significant reduction in a margin of safety.

Schedule of Change This change will be put-into effect 30 days following BECo's receipt of approval by the Commission.

Fee Determination Pursuant to 10CFR170.12(c), an application fee of $150.00 is included with this proposed amendment.

I 4

f

. .- .. . . . _ , .- -. - - , - . . - - .. - .-. ~ . - . . . . -

" LIMITING

CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.B -Standby Gas Treatment System and 4.7.8 Standby Gas Treatment System and Control Room High Efficiency Air Control-Room High Efficiency Air Filtration System Filtration System

1. Standby Gas Treatment System 1. Standby Gas Treatment System

] a. Except as specified in a. (1.) At least once every 3.7.B.l.c below, both trains 18 months, it shall of the standby gas treatment be demonstrated that system and the diesel genera- pressure drop across tors required for operation the combined high of such trains shall be oper- efficiency filters able at all times when and charcoal adsorber secondary containment integ- banks is less than 8 rity is required or the. inches of water at reactor shall be shutdown-in 4000 cfm.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(2.) At least once every

b. (1.) The results of the in- 18 months, demonstrate place cold DOP tests on that the inlet heaters HEPA filters shall show on each train are 199% DOP removal. The operable and are cap-results of halogenated able of an output of hydrocarbon tests on at least 14 kW. Per-charcoal adsorber banks form an instrument shall show >99% halo- functional test on the genated hydrocarbon humidistats controlling removal. the heaters.

(2.) The results of the lab- (3.) The tests and analysis oratory carbon sample of Specification 3.7.

analysis shall snow B.I.b. shall be per-195% methyl iodide re- formed at least once moval at a velocity every 18 months or within 10% of system de- following painting, sign, 0.5 to 1.5 mg/m' fire or chemical re-inlet methyl lodide con- lease in any ventila-centration, 2 0%

7 R.H. tion zone communicat-and 1 190*F. The ing with the system analysis results are to while the system is be verified as acceptable operating that.could within 31 days after contaminate the sample removal, or de- HEPA filters or clare that train inopera- the charcoal ble and take the actions adsorbers.

specified in 3.7.B.I.c.

(4.) At least once every )

l c. From and after the date that 18 months, automatic j one train of the Standby Gas initiation of each Treatment System is found to branch of the stand-be inoperable for any reason, by gas treatment continued reactor operation, system shall be irradiated fuel handling, or demonstrated, with new fuel handling over the Specification 3.7. l spent fuel pool or core is B.I.d satisfied. l

[

l Amendment No. 158

h

" " ~

LIMITING CONDITIONS FOR 0PERATION' SURVEILLANCE REQUIREMENTS 3.7.B':(Continued) 4.7.B (Continued) . )

permissible only during the succeeding seven days pro-viding that within two hours, and daily thereafter. all active components of the other Standby Gas Treatment L train shall be demonstrated to be operable. (5.) Each train of the standby gas treat-

d. Fans shall operate within ment system'shall be 110% of 4000 cfm. operated for at least 15 minutes per month.

e. Except.as specified in 3.7.B.I.c, both trains of (6.) The tests and analysis the Standby Gas Treatment. of Specification 3.7.

System shall be operable dur- B.I.b.(2) shall be ing irradi.ated fuel handling, performed after every or new fuel handling over 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system o the spent fuel pool or core. operation.

If the system.is not opera-ble, fuel movement may not b. (1.) Inplace cold DOP test-be started. Any fuel ing shall be performed assembly movement in progress on the HEPA filters may be completed. after each completed or partial replacement-of the HEPA filter bank and after any structural maintenance-on the HEPA filter sys-tem housing which could affect the HEPA filter bank bypass leakage.

(2.) Halogenated hydrocarbon

, testing shall be per-formed on the charcoal adsorber bank after each partial or com-plete replacement of the charcoal adsorber bank or after any structural main-tenance on the charcoal adsorber housing which could affect the charcoal adsorber bank bypass leakage.

Amendment No. 158A

r;' ' ,

2..  :. '

• l.IMITING CONDITIONS:FOR OPERATION SURVEILLANCE REQUIREMENTS

. l

" 73.7.8 (Continued)' 4'.7.8-1(Continued) m

2. Control Room High! Efficiency -

2.: Control Room High Efficiency: -

Air-Filtration System Air Filtration. System

~

a. Except as specified in. .a. -At least once very 18 months

. Specification 3.7.B.2.'c the pressure drop across below, both. trains of the 'each combined filter train '

Control Room.High Efficiency shall-be-demonstrated to be-Air.FiltrationLSystem_used less than 3 inches of water-

-for the processing of. Inlet- at 1000 cfm.

~a ir to-the control room

-under accident conditions b. (1.) The tests and analysis

-and the diesel generator (s)' of Specification 3.7.

required.for the operation B.2.b shall be per-of.each train of the system- formed once every 18 shall be operable,whenever, . months or following secondary containment.inte- painting, fire or

.grity is-required and during chemical- release in fuel handl.ing operation. any ventilation zone communicating with the

b. (1.) The.results of the.in - system while the place cold DOP tests on system is operating HEPA filters shall'show

> 99% DOP removal. The (2.)'Inplace cold DOP results of the halo- testing shall be genated'hydrocarbonL performed testsaon charcoal adsor- after each ber banks shall show complete or partial

> 99%'halogenated hydro- replacement of the HEPA carbon removal when test filter bank or after results are extrapolated any structural main-to the initiation of the tenance on the system test. housing which could affect the HEPA filter (2.) The results of the labo- bank bypass leakage.

ratory carbon sample analysis shall show >- (3.) Halogentated hydro-95% methyl iodine re- carbon testing shall moval at a velocity be performed within 10% of system after each design, 0.05 to 0.15 complete or mg/m3 inlet methyl partial replacement of-todine removal at a > the charcoal adsorber 70% R.H., and > 125*F. bank or after any The analysis results structural mainten-are to be verified as ance on the system acceptable within 31 housing which could days after sample affect the charcoal removal, or declare adsorber bank bypass that train inoperable leakage.

and take the actions specified in 3.7.B.2.c.

Amendment'No. 1588

_ u _ _. _ ,_ __ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ - . _ . _ _ _ . . _ . _

a . -

LIMITING. CONDITIONS FOR OPERATION SURVEILLANCE REQUIREMENTS 3.7.B (Continued) 4.7.B (Continued) 1

c. From and after the date (4.) Each train shall be that one train of.:the operated with the Control Room High . heaters in automatic

-Efficiency Air Filtration for at least 15 min-System is made or-found to utes every month.

be incapable of supplying filtered air to (5.) The test and analysis the control room for of Specification 3.7.B.

any reason, reactor opera- 2.b.(2) shall be tion or refueling operations performed after every

'are permissible only during 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system the succeeding 7 days. If operation.

the system is not made fully operable within 7 days, c. At least once every 18 reactor shutdown shall be months demonstrate the initiated and the reactor operability of the shall be in cold shutdown heaters at rated power.

within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and irradiated fuel handling 3. Perform an instrument operations shall be termi- functional test on the nated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. (Fuel humidistat controlling the handling operations in pro- heaters once per 18 months. l gress may be completed).

d. Fans shall operate within

+ 107. of 1000 cfm.

' Amendment No. 158C

7 ~

.4 x. .

> '.a

, 28ASES: . .

,P , 4 3.7.B.l'and 4.7.B.1? Standby Gas Treatment '

JT W Standby. Gas' Treatment System isLdesigned-to filter and exhaust the reactort

~

ibuilding atmosphere to~the stack 1during secondary containment isolation Econditions Upon containment isolation,- both standby gas treatment fans are

_ ~ designed to start to bring the-reactor building pressure negative so that all Lleakage should be in leakage. 'After a preset time delay,.the' standby fan automatically shuts down so the-reactor building pressure is maintained

[approximately.1/4: inch of' water negative. Should one system fall to start, >

- the redundant system is designed to start automatically. ' Each of the two

.. trains has 1001. capacity.'

-High Efficiency Particulate Air (HEPA) filters are installed before and after the charcoal adsorbers.to minimize potential release of particulates to the environment and to prevent clogging of the lodine adsorbers. The charcoal adsorbers are installed to< reduce-the potential release of radiolodine to-the ,

environment. The in-place' test results should indicate a system leak-  :

tightness of_less than'1: percent bypass leakage for the charcoal adsorbers and

.a HEPA filter; efficiency of at~1 east 99 percent removal of cold DOP particulates. The' laboratory. carbon sample test results'should indicate a methyl lodide removal efficiency of at least 95 percent for expected accident conditions. The specified efficiencies for the charcoal and particulate filters.is' sufficient to preclude exceeding 10 CFR 100 guidelines for the accidents analyzed. The analysis of the loss of coolant accident' assumed a  ;

charcoal.'adsorber efficiency of 95% and TID.14844 fission product source terms, hence, instilling two banks of adsorbers and filters in each train provides adequate margin. A:14 kN heater maintains relative humidity below 70% in order to ensure the efficient removal of methyl lodide on the impregnated charcoal adsorbers. Considering the relative simpilcity of the heating circuit, the' test frequency on once per 18 months is adequate to demonstrate' operability.

Air flow through the filters and charcoal adsorbers for 15 minutes each month

. assures operability of the system. Since the system heaters are automatically controlled, the air flowing'through the' filters and adsorbers will be < 70%

relative humidity and will have the desired drying effect.

Tests of impregnated charcoal identical to that_used in the filters indicate that shelf life of five years leads to only minor decreases in methyl lodide removal efficiency. Hence, the frequency of laboratory carbon sample analysis is adequate to demonstrate acceptability. Since adsorbers must be removed to i perform this. analysis, this frequency also minimizes the system out of service

-time as a result of survelliance testing. In addition, although the halogenated hydrocarbon testing is basically a leak test, the adsorbers have charcoal of known efficiency and holding capacity for elemental iodine and/or -

, methyl iodide, the testing also gives an indication of the relative efficiency j- of the. Installed system. The 31 day requirement for the ascertaining of test I

results ensures-that the ability ofthe charcoal to perform its designed .

p function'is demonstrated and known in a timely manner.  ;

" i The' required Standby Gas Treatment flow rate is that flow, less than or equal i

to 4000 CFM which is needed to maintain the Reactor Building at a 0.25 inch of

> water negative pressure under. calm wind conditions. This capability is

.a'dequately demonstrated during Secondary Containment Leak Rate Testing

' performed pursuant to Technical Specification 4.7.C.I.c.

~

V

~

g LAmendment No. 172 L r a- _ _ _ _ _ _ _ _ . _ , _ , _ _._ - __ J

y ' ~ - * ^" ' " ' ' " ~ ^ ^

~, ~ ~ ^ ~ ~

y

a. &

.* i* 6,% , m 18ASES: . .

l l3.7.8.2.b and;4.7.8.2.b - Control Room High Efficiency Air Filtration System i jTheContro1IRoomHighEfficiency-AirFiltrationSystemisdesignedtofilter,

Intake air for,the controlcroom atmosphere'during conditions.when normal

_' -intake air'may be, contaminated. -Following manual. Initiation, the Control' Room High Efficiency Air Filtration System is designed to position: dampers and .

=-

. start, fans'which~ divert the-normal air flow through charcoal'adsorbers before  ;

11t reaches the control-room. ,

LHigh Efficiency ~. Particulate Air ~(HEPA)-filters are installed before the charcoal adsorbers to prevent clogging of the lodine adsorbers. The charcoal sadsorbers are installed to reduce the potential intake of radiolodine to the-control room. A.second' bank of HEPA filters is' installed downsteam of the charcoal filter. ,

The'in-place test results should indicate a system leak ~ tightness of less than l 1 percent-bypass leakage for the charcoal adsorbers and;a HEPA efficiencyiof at 1 east-99% removal:of cold 00P particulates. The laboratory carbon sample-test results should indicate a methyl lodide remo' val efficiency of at least 90%-for expected accident conditions. Tests of impregnated charcoal identical

'to that used in the filters indicate that shelf life of five years leads to only minor.-decreases in methyl lodide removal efficiency. Hence, the frequency-of laboratory carbon' sample analysis is adequate to demonstrate acceptability. Since adsorbers must be removed to perform this analysis, this

. frequency also minimizes the system out of service time as.a result of survelliance testing. In addition, although the halogenated hydrocarbon l testing is basically a leak test, the adsorbers have charcoal of known

. efficiency and holding capacity for elemental todine-and/or methyl lodide,' the testing'also gives an indication of_the relative efficiency of the installed -

system. The 31 day requirement for the ascertaining.of: test results ensures-that the ability of the charcoal.to perform its designed function is demonstrated and known in a timely manner.

Determination of the system pressure drop once per operating cycle provides .

indication that the HEPA filters ~and charcoal adsorbers are not clogged by. -

excessive amounts of foreign matter and'that no bypass routes through the ,

filters or adsorbers had developed. Considering the relatively short times the systems will be operated for= test purposes, plugging is unlikely and the test interval of once per operating cycle is reasonable.

-The. test frequencies are adequate to detect equipment deterioration prior to significant defects, but the tests are not frequent enough to load the filters or adsorbers, thus reducing their reserve capacity too quickly. The filter testing is performed pursuant to appropriate procedures reviewed and approved

,by the Operations Review Committee pursuant to Section 6 of these Technical Specifications. The in-place testing of charcoal filters is performed by- ,

. injecting a halogenated hydrocarbon into the system upsteam of the charcoal adsorbers. Measurements of the concentration upstream and downstream are made. 'The ratio of the inlet and outlet concentration upstream and downstream are made. The ratio of the inlet and outlet concentration gives an overall indication of'the leak tightness of the system. A similar procedure substituting dioctyi phthalate for halogenated hydro-carbon is used to test the HEPA filters.  ;

i l

p Amendment No.- 174

a. . . , . _ . _ . ._a,_,____ .._ _

s  ;

l

m. ,

p

,;  ; BASES: .

I .3.7.B.2.b and 4.7.B.2.b (Continued)'

. Air flow through the filters and charcoal-adsorbers for 15 minutes each month assures operability of the system. Since the system heaters are automatically controlled, the air flowing through the filters and adsorbers will be < 70%

relative humidity and will have the desired drying effect.

In the event that one CRHEAFS is inoperable, the redundant system will be tested daily. This substantiates the availability of the operable system and justifies continued reactor or refueling operations.

If both trains of.CRHEAF are inoperable, the plant is brought to a condition where CRHEAF is not required.

l l

Amendment No. 174A i