ML20095J701

Proposed Tech Specs Re Administrative Change to Ventilation Filter Testing Program

ML20095J701
Person / Time
Site:	Peach Bottom
Issue date:	12/19/1995
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20095J699	List: ML20095J697 ML20095J701
References
NUDOCS 9512270273
Download: ML20095J701 (9)

Text

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ATTACHMENT 1 PEACH BOTTOM ATOMIC POWER STATION

UNES 2 AND 3 I

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. DOCKET NOS 50-277 50-278 LICENSE NOS. DPR-44 DPR-56 1

TECHNICAL SPECIFICATIONS CF ! GE REQUEST

) 95-13 I

I 2 " ADMINISTRATIVE CHANGE TO VENTILATION FILTER TESTING PROGRAM"

, I SUPPORTING INFORMATION FOR CHANGES - 3 PAGES l

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9512270273 951219 i PDFr ADOCX 050CO277 P__._,.,,__,,, PDR,. .. ,

. Docket Nos. 50-277 I

50-278 License Nos. DPR-44

, DPR-56 PECO Energy Company requests that the Technical Specifications (TS) for the Peach Bottom e . Atomic Power Station (PBAPS), Units 2 and 3 be amended as proposed below to provide for the changing of the Ventuation FBter Testing Program (VFTP).

j~ F rovided below is a discussion and description of the proposed changes, a safety assessment, l hformation supporting a finding of No Significant Hazards Consideration, and information

topporting an Environmental Assessment.

6 W marked-up pages indicating the proposed changes are provided in Attachment 2.

We request that, if approved, the changes be effective by January 11,1996.

Discussion and Descriotion on the Prooosed Chanaes

$ Revise improved Technical Specifications (ITS) Sections 5.5.7.a and 5.5.7.b to correct an

. administreNe error in the VFTP.

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. During the development of the PBAPS ITS submittal, the requirements in existing TS Section

3/4.7.B, " Standby Gas Treatment System," and Section 3/4.11.A " Main Control Room Emergency Ventuation System," regarding testing of high efficiency particulate absolute (HEPA) filters and charcoal adsorber banks were incorporated into ITS Section 5.5.7, "VFTP".

3 i PECO Energy submitted TS Change Request 93-16 to adopt ITS. Included in this submittal were

comparison documents which marked up the existing TS to indicate where the requirements were proposed to be located in ITS. The comparison documents indicated that existing j requirements in TS Section 3.7.B.2a and 3.11.A.4.a were relocated to ITS Section 5.5.7.a and 5.5.7.b. An administrative change to existing TS Section 3.7.B.2s and 3.11.A.4.a was pre,xmed and identified as administrative change number 11. The discussion of changes for administrative change number 11 states, " Requirements in existing Specifications 3/4.7.B. Standby Gas Treatment System, and 4.11.A. Main Cment Room Emergency Ventilation System, regarding testing of HEPA filters and charcoal a?W dr banks were incorporated into Section 5.5.7, Ventilation Filter Testing Program. The Ventilation Filter Testing Program specifies testing requirements equivalent to the existing specifications; however, references to the appropriate sections of Regulatory Guide 1.52 and ASME N510-1989 were added for clarity." This change was discussed in the No Significant Hazards Consideration for ITS along with all other administrative changes for ITS Chapter 5.0, " Administrative Controls."

The NRC approved the VFTP as proposed in Amendments 210 and 214. The NRC Safety Evaluation Report (SER) dated August 30,1995, stated, " Requirements in CTS 3/4.7.8, Standby Gas Treatment System, and 4.11.A, Main (bntrol Room Emergency Ventilation System regarding testing of HEPA fRters and charcoal adsorber banks are incorporated into ITS 5.6.7, Ventilation Filter Testing Program. The Ventilation Futer Testing Program specifies testing requirements equivalent to the CTS; however, references to the appropriate sections for Regulatory Gulae 1.52 and ASME N510-1989 were added for clarity. This change is administrative, is consistent with the STS, and is acceptable.' .

4 Docket Nos. 50-277 i 50-278 License Nos. DPR-44

• DPR-56 I l 4

l An administrative error occurred during the reformatting and relocation of existing TS Sections 3.7.B.2a and 3.11.A.4.s to ITS Sections 5.5.7.a and 5.5.7.b. Existing TS require the in-place cold dictyi phthalate (DOP) and halogenated hydrocarbon tests on HEPA futers and charcoal  ;

adsorber banks to show a 99% DOP removal and a 90% halogenated hydrocarbon removal or  !

to consider that futer train inoperable TS Change Request 93-16 comparison documents, No j Significant Hazards Consideration, and proposed VFTP restated the requirements for an in-picco test of the HEPA filters and the charcoal adsorber to show a penetration and system bypass of j less than 0.05% when tested in accordance with Regulatory Guide 1.52 and ASME N510-1989.

The 0.05% value for penetration and system bypass was in error. The correct value for penetration and system bypass is less than 1.0%

Safety Assessment l The proposed changes do not involve any physical changes to plant systems, structures, or

components (SSC), or the addition of new SSC. The proposed changes are purely

administrative in nature to make ITS requirements consistent with the current PBAPS licensing basis and have no impact on any safety analysis assumptions.

Informatinn Sunnnrtina a Findina of No Sionificant Hm7ards Consideration

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The changes proposed in the Application do not constitute a Significant Hazards Consideration j in that:

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The ornanaad chanoes do not involve a sianificant lacrease in the orobabuity or conseauences of an accident previousiv evaluated because the changes are purely administrative and do not involve any physical changes to plant SSC. These proposed changes do not impact initiators of analyzed events, and wul not increase the probabuity of occurrence of an accident previously evaluated. These proposed changes do not impact the assumed mitigation of accidents or transient events. Therefore, these changes wHl not involve a significant increase in the probabHity or consequences of an accident previously evaluated.

ii) The orooosed chances do not create the oossibility of a new or different kind of accident from anv accident oreviousiv evaluated because the changes wWI not involve a physical alteration of the plant (no new or different type of equipment will be installed) or changes in methods goveming normal plant operation. The changes do not allow plant operation in any mode that is not already evaluated in the safety analysis. Therefore, these changes wHi not create the possibHity of a new or different kind of accident from any accident previously evaluated, lii) .Ibe oronosed chanaes do not involve a slanificant reduction in a marain of safety because they are purely administrative and will not involve any technical changes.

Generic Letter 83-13 (GL 83-13), " Clarification of SurveHlance Requirements for HEPA Futers and Charcoal Adsorber Units in Standard Technical Specifications on ESF

- Cleanup Systems," was reviewed for guidance. GL 83-13 based in-place penetration and bypass leakage testing acceptance criteria in part on the NRC staff assumptiore used in its safety evaluation reports (SERs) for the ESF atmospheric cleanup systerm , GL 83-13 stated, '0.05% value applicable when a HEPA futer or charcoal adsorber efficiency cf

Docket Nos. 50-377 50-278 i

License Nos. DPR-44 DPR-56 99% is assumed, or 1% when a HEPA filter or charcoal adsorber efficiency of 95% or

less is assumed in the NRC stats safety evaluation." in the original SER for PBAPS dated August 11,1972, the NRC staff assumed a 90% halogen removal efficiency for the elemental and particulate forms of iodine, and 70% for the organic forms of lodine in the j HEPA fBters and charcoal adsorbers of the Standby Gas Treatment System (SGTS). The SER for Amendments 10/7 dated June 25,1975 was issued to resolve an issue raised by a December 10,1974, letter from the NRC proposing model TS for PBAPS Control Room Air Treatment Systems and SGTS. The June 25,1975, SER documented the acceptability of values of less than 1% penetration and bypass leakage which is stil in j place in the existing TS Bases. No SlRs assumed HEPA filter or charcoal adsorber efficiency of 99%. Therefore, GL 83-13 recommends acceptance of less than 1%

, penetration and bypass leakage. Therefore, maintaining the current requirements for penetration and bypass leakage does not involve a reduction in the margin of safety.

Also, because the change is administrative in nature, no question of safety is involved.

] Therefore, the change does not involve a significant reduction in a margin of safety.

Information Suncortina an Environmental Assessment 4

An environmental assessment is not required for the changes proposed by this Application because the changes conform to the criteria for " actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(10). The proposed changes relate

to changes in recordkeeping, reporting, or administrative procedures or requirements.

Conclusion The Plant Operations Review Committee and the Nuclear Review Board have reviewed the proposed changes and have concluded that the changes do not involve an

unreviewed safety question and will not endanger the public health and safety.

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4 ATTACHMENT 2 PEACH BOTTCM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 DPR-56 6

TECHNICAL SPECIFICATIONS CHANGE REQUEST 95-13 1

Ust of Attached Pages j i

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Unit 2 Unit 3 5.0-12 5.0-12 i 5.0-13 5.0-13

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Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testino Proaram (VFTP) (continued)

1) Once per 12 months for standby service or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; and,

2) After each complete or partial replacement of the HEPA filter train or charcoal adsorber filter; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.

Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed once per 24 months.

The test described in Specification 5.5.7.f shall be performed once per 12 months.

The provisions of SR 3.0.2 and SR 3.0.3 are hpplicable to the VFTP test frequencies,

a. Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass < l.0 %

< 0.051 when tested in accordance with Regulatory Guide 1.52, Revision 2, Section Sc, and ASME N510-1989,  !

Sections 6 (Standby Gas Treatment (SGT) System only) and 10, at the system flowrate specified below.

ESF Ventilation System Flowrate (cfm)

SGT System 7200 to 8800 Main Control Room Emergency 2700 to Ventilation (MCREV) System 3300 (continued) l l

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PBAPS UNIT 2 5.0-12 Amendment No. 210 l I

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Programs and Manuals

5.5

5.5 Programs and Manuals i

5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued)

b. Demonstrate for each of the ESF systems that an inplace test l

! of the cg r oal adsorber shows a penetration and system i bypass < when tested in accordance with Regulatory Guide 1.52, Revision 2, Section 5d, and ASME N510-1989, i

Sections 6 (SGT System only) and 11, at the system flowrate

' specified below.

ESF Ventilation System Flowrate (cfm)

SGT System 7200 to

- 8800 i

! MCREV System 2700 to 3300 l

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! c. Demonstrate for each of the ESF systems that a laboratory

! test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, Section 6b, l shows the methyl iodide penetration less than the value l

specified below when tested at the conditions specified

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ESF Ventilation System i'

SGT System MCREV System .

l Methyl iodide a 95 a 90 removal rate:

(%)

l Methyl iodide 0.5 to 1.5 0.05 to 0.15 i

concep)tration

(mg/m Flow rate: 80 to 120 80 to 120

(% design flow) l Temperature: a 190 h 125

(degrees F)

Relative Humidity: a 70 a 95

(%)

(continued) d PBAPS. UNIT 2 5.0-13 Amendment No. 210

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5'.7 Ventilation Filter Testina Proaram (VFTP) (continued)

1) Once per 12 months for standby service or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation; and,

2) After each complete or partial replacement of the HEPA filter train or charcoal adsorber filter; after any structural maintenance on the system housing; and, following significant painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation.

Tests described in Specifications 5.5.7.d and 5.5.7.e shall be performed once per 24 months.

The test described in Specification 5.5.7.f shall be performed once per 12 months.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies,

a. Demonstrate for each of the ESF systems that an inplace test of the HEPA filters shows a penetration and system bypass 4. l.0%

4 0.05". when tested in accordance with Regulatory 1 Guide 1.52, Revision 2, Section Sc, and ASME N510-1989, Sections 6 (Standby Gas Treatment (SGT) System only) and 10, at the system flowrate specified below.

ESF Ventilation System Flowrate (cfm) I SGT System 7200 to

! 8800 l

Main Control Room Emergency 2700 to

Ventilation (MCREV) System 3300 (continued)

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! PBAPS UNIT 3 5.0-12 Amendment No. 214 t

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i Programs and Manuals

5.5 I

l 5.5 Programs and Manuals

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5.5.7 Ventilation Filter Testina Proaram (VFTP) (continued)

I b. Demonstrate for each of the ESF systems that an inplace test of the c a oal adsorber shows a penetration and system i bypass < when tested in accordance with Regulatory i Guide 1.52, Revision 2, Section 5d, and ASME N510-1989, Sections 6 (SGT System only) and 11, at the system flowrate specified below.

l ESF Ventilation System Flowrate (cfm) i

SGT System 7200 to 8800 MCREV System 2700 to 3300

! c. Demonstrate for each of the ESF systems that_a laboratory i test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, Section 6b, shows the methyl iodide penetration less than the value specified below when tested at the conditions specified below.

ESF Ventilation System SGT System MCREV System Methyl iodide m 95 m 90 removal rate:

(%)

Methyl iodide 0.5 to 1.5 0.05 to 0.15 concep)tration:

(mg/m Flow rate: 80 to 120 80 to 120

(% design flow)

Temperature: a 190 m 125 (degreesF)

Relative Humidity: a 70 m 95

(%)

(continued) l P8APS UNIT 3 5.0-13 Amendment No. 214 1 l

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