ML20113H631

Proposed TS 3/4.7.6 Re Heater Dissipation Rate & 3/4.7.7 Re Nonaccessible Area Exhaust Filter Plenum Sys

ML20113H631
Person / Time
Site:	Byron
Issue date:	07/27/1992
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20113H628	List: ML20113H627 ML20113H631
References
NUDOCS 9208050113
Download: ML20113H631 (10)

Text

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ATTACHMENT B PROPOSED CHANGES TO APPENDIX A, TECHNICAL SPECIFICATIONS, OF FACILITY OPERATING LICENSES NPF-37 AND NPf-66 Revision te-3/4.7-17 3/4.7-19 3/4.7-20 3/4.7-21 3/4.9-15 9208050113 920727 PDR ADOCK 05000454 P

pp9 ZNLD/1916/8

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,1 PLANT-SYSTEMS SURVEILLANCE: REQUIREMENTS (Continued) 2)

Verifying, within 31 days after removal, that a laboratory T

analysis of a representt'ive carbon sample from the Emergency Makeup System obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 0.175% when tested at a tempera-ture of 30'C and a relative humidity of 70%; and 3)

. Verifying a system flow rate of 6000 cfm + 10% for the Emergency Makeup System and_49,500 cfm 110% for the Recirculation System d

when tested in accordance with ANSI N510-1980.

d.

After every 720 2urs of Emergency Makeup System operation by verify-

-ing within 31 days after 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 the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978,_for a methyl iodide penetration of less than 0.175% when tested at a temperature of 30*C and a relative humidity of 70%;

e.

At least once per 18 months by:

1)

Verifying that the pressure drop across the' combined ~HEPA filters and charcoal adsorber banks is less'than 6.0 inches Water Gauge while-operating the Emergency Makeup System at a flow rate of 6000 cfm i 10%,

2)

Verifying that-on a Safety Injection or High Radiation-Control Room Outside Air Intake test signal, the system automatically switches into a makeup inode of control _ room ventilation with flow ti' rough.the Emergency Makeup System HEPA filters' and _

charcoal adsorber banks and the recirculation charcoal adsorber;-

4 3), Verifying that the Emergency Makeup System maintains the control room at a positive nominal pressure of greater than or equal to 1/8 inch Water.' Gauge relative to ambient pressure -in areas adjacent to the control-room area when operating. an Emergency Makeup System at a flowrate of-6,000 cfm 110% 'and the recircula -

tion charcoal adsorber at a flowrate. of '49,500' cfm i 10%.

?l 4)

Verifying that the. heaters dissipate 27.2 _. 2.7--kW when tested l'

lee h b or t p W 44.0.

in accordance with ANSI N510-1980.

c 5)

Verifying that the Emergency _ Makeup._ System maintains the Upper Cable-Spreading Area at a positive nominal pressure of greater than or equal to 0.02 inches Water Gauge relative to the ' ambient j/

-pressure in areas adjacent to the upper cable spreading area

/

(except for adjacent control room areas pressurized as specified

/

above) when operating an Emergency Makeup System at a_ flow rate.

/

i of 6,000 cfm i 10% and the recirculation charcoal adsorber at a

/

i-flowrate of 49,500 cfm 2104.

)

BYRON - UNITS 1 & 2 3/4 7-17

e PLANT SYSTEMS 3/4.7.7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent non-accessible area exhaust filter plenums (50%

l capacity each) shall be OPERABLE.

APPLICABILITY:

MODES 2, 2, 3, and 4.

ACT*0H:

With one non-accessible area ennaust filter plenum inoperable, restore the inoperable plenum 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 LHUTOOWN withiri the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS t

4,7.7 Each non-accessible area exhaust filter plenum shall be demonstrated OPERABLE:

a.

At least once per.3' days on a STAGGERED TEST BASIS by initiating, from the control room, f'.ow through the HEM filtets and charcoal adsorbers and verifying that operation occor, for at least 15 minutes; b.

At least once per 18 months, oc (1) afts-any structaral maintenance on the HEPA filter or charcoal adsorber housings, or (2) following p:41nting, fire, or chemical release in any ventilation zone communi-rating with the exhaust filter plenum by:

1)

Verifying that the exhaust filter plenum. satisfies the in place penetration and bypass leakage testing acceptance cr'iteria of less than 1% when using the th t procedure guidance in Regulatory Positions C.S.a C,5.c and C.S.d of Regulatory Guide 1.52, Revi-sion 2, March 1578, and the flow rate is 66r900-ofm-*-1M for the t rain and-23r300-c4110%-per-bank; (gg 2)

Verifying, within 31 days after removal., that a laboratory analysis of a representative carbon sample from each bank of adsorbers of the train obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, Marc' 1978, meets the laboratory testing criteria of, R gulatory Position C.6.a cf jegulatory Guide 1.52, Revision 2, March 1978, for met

• odide penetretion af less than 1% when tested at the l

temp 3,ure of 30*C and a

• elative humidity of 70%;

n g

• • Not-applicable-o**r to-July-tr1985c BYRON - UNITS 1 & 2 3/4 7-19 l

1

PLANT SYSTEMS b

SURVEILLANCE REQUIREMENTS (Continued)

[

t 3) verifjing a system flow rate of-667900-cfm-t-10%-through-the train-and-22r300-cfm-110L pen-bank through the exhhust filter plenum during operation when tested in accordance with ANSI H510-1980; and ldv;un FS. M ( b e,J 66apa cf 4)

Verifying that with the system opet ating at a flow rate of-6&;900

-efm-*10% through the train end-22 300-cfm-t10%-pen-bank and exhausting 3

through the HEPA filter and charcoal adsorbers, the totc1 bypass flow of the system and the damper le3kage is less than or equal to 1% when the system is tested by admitting. cold DOP at the system intake and the damper leakage rate is determined by either direct measurements or pressure decay measurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, c.

within 31 days after removal that a laboratory analysis of a repre-sentativecarbonsampleobtaInedfromeachbankofadsorbersofthe train in accordance with Regalatory Position C.6.b of Regulatory Gu'de 1.52, Revision 2 March 1978, meets the laboratory testing cri-teria of Regulatory Position C.6.a of Regulatory Guide 1.52 Revision 2, March 1978, when the average for a methyl iodide penetration of less than 1% when tested at a temperature of 30*C and a relative humidity of 70%.

d.

At least once per 18 months by:

1)

Verifying for ach filter bank of the train that the pressure drop across the combined HEPA filters and char:oal adsorber banks of less than 6.0 inches Water Gauge while operating the exhaust filter plenum at a flow rate of-66 900-efm+10% through the 1

train and-22r300-efm-1100per-bank; %ul c;S,m tf og ggy 4 2)

Verifyi q that the exhaust filter plenum starts on manual intd.t1on or Safety Injection test signal; and o

3){ Verifying that the systen maintains the ECCS equipment rooms at a negative pressure of greater than or equal to 1/4 in. Water Gauge relative to the m.tside atmosphere during system operation while operating at a flow rate of-66;900-efm-*10%r through the train and-2R,300 efvt10% per-bank.hg 55,m cp ud GUos cc.

After each complete or partio) replacement of a HEPA filter bank, by e.

verifying that the exhaust filter plenum satisfies the in place penetration testing acceptance criteria of less than 1% in accord-ance with ANSI H510-1980 for a DOP test aerosol while operating at a flow rate of-66r900-efu-t-10% through the train end-22 390-efm-10t 1

i per-bank; and (g gg 4 y

y JNot-applicable-to Unit-2-until-Detober-12-19E i

BYRON - UNITS 1 & 2 3/4 7-20

, PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) f.

After each complete or partial replacement of a charcual adsorber bank, by verifying that the exhaust filter plenum satisfies the in place penetration testing acceptance criteria of less than 1%

in a.:cordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow. rate et 667900-cfat10% through the train, and-23r304-efm-t104 per-bank,

,lj,eWeen 5 5, 4 6 'T e.fm mod 98,200 c f ra Ante omy slut 4ard menieranc.

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-t BYRON - UNITS 1 & 2 3/4 7 21

/

d REFUELING OPERATf0NS SURVEILtANCE REQUIREMENTS (Continued) 1)

Verifying that the Fuel Hartiling Building Exhaust Filter Plenua satisfies the place penetration testing acceptance criteria of less than 1% when using the test procedure guidance in Regula-tory Positions C.S a. C.S.c, and C.S.d of Regulatory Guide 1.52 Revision 2, March 1978, and the flow rate is 21,000 cfm i 10%; -

1 2)

Verifying, within 31 days after 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 the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2. March 1978, and by showing a methy1' iodide penetration of less than 10% when tested at a temperature of 30*C and a relative humidity of 95%.

3)

Verifying a floe rate of 21,000 cfm i 10% through the Fuel Handling Building Exhaust Filter Plenum during operation when tested in accordance with ANSI N510-1980; and 4)

Verifying that with the system operating at a flow rate of 21,000 cfm 110% and exhausting through the HEPA filters and charcoal adsorbers, the total bypass flow of the system and the leakage is less than or equal to 1% when the system is tested by injecting-cG14 DOP at the system intake and the damper leakage rate'is determined by either direct measurements or pressure decay measurerents at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow, Af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, c.

within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory

• Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, by showing a methyl iodide penetration of less than 10% when tested at a temperature of 30*C and a relative humidity of 95%.

d.

At least once per 18 months by-1)

Verifying that the pressure drop across' the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the exhaust fil":t plenum at a flow rate of 21.000 cfm i 10%;

2)

Verifying that on a Safety Injection or a High Radiation test I

signal, the system automatically starts (unless already operating) l.

and directs its exhaust flow through the HEPA filters and charcoal adsorber banks; and t

I BYRON - UNITS 1 & 2 3/4 9-15

ATTACllMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS Commonwealth Edison has evaluated the proposed amendment and has determined that it involves no significant hazards considerations. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hazards if operation of the f acility in accordance with the proposed amendment would not:

1.

Involve a significant increase in the prooability or consequences of an accident previously evaluated; or 2.

Create the possibility of a now or different kind of accident from any accident previously evaluated; or 3.

Involve t significant reduction In a margin of safety.

The proposed amendment makes several changes to Byron's Technical Specifications. These enanges are 1) a change In control room emergency makeup filter heater dissipation rates, 2) change in VA system total flow rate. 3) deletion of periodic bank flow rate requirements, 4) editorial changes, and 5) deletinq " col 1" when describing the DOP used for ventilation system testing.

A.

The proposed changes to not involve a significant increase in the probability or consequences of an accident previously evaluated. The control room emergency make up air filter unit heaters were designed to comply with ANSI N5091976 and Regulatory Guide 1.52 Revision 2 (1978) requirements. These limit the relative humidity of air entering the carbon adsorbents to 70% at the des;gn flow rate. For a LOCA, air conditions were assumed to conservatively reflect atmospheric conditions. It was determined that the relative humidity can be limited to approximately 70%

with a heater capacity of 24.0 kW. The proposed Technical Specification change is consistent tvith this determination, so the probability and consequences of accident remain unaffected.

The revised total system air flow rates for the VA Non Accessible Area Exhaust Filter Plenums are based on a maximum of 110% of the filter rated capacity. The minimum flow is based on the flow necessary to maintain non accessible area ALARA and equipment qualification considerations.

The now f!ow rates still ensure that radioactive materials leaking from the ECCS equipment within the pump rooms following a LOCA are filtered prior to reaching the outside environment. Therefore, the operation of this system with revised flow rates does not affect the assum tions of the safety a

analysis, and the consequences of an accident are not a"fected.

ZNLD/1916/9

The deletion of the periodic bank flow testing will not affect the operation or effectiveness of the VA exhaust filter plenum system. The design basis assumes that the system will be tested in accorriance with ANSI N5101980. Since this change aligns the surveillance requirements with the approved method, the consequences of sny accident previously evaluated are not affected. An additional surveillance requirement was added to ensure that bank flow test!ng is done following certain maintenance activities as required by the ANSI method.

The typographical correction does not affect any accidsnt. The deletion of the footnotes has no offect on any accident since the footnotes are no longer applicable.

Deleting the word " cold" when describing the DOP testing is similar to the deletion of bank flow testin0. The change is removing a restriction on the test requirement to allow testing to be performed in accordance with an approved method, ANSI N5101980.

B.

The proposed changes do not create the possibility of a new or diffsrent kind of accident from any accident previously evaluated. The chan00 to required heater capacity is based u:>on an analysis that established a minimum heater capacity that enve' opes the accident analysis results.

The new VA system flow rates result from a combination of testing, adjusting, and balancing of the VA system, and achieved acceptable systs.1 performance characteristics of the system design as outlined in the Update Final Safety Analysis Report (UFSAR). Cooling and preseure requirements are maintained within the design and Intent of the UFSAR. The basis for the VA non accessible area system is to ensure that radioactive materlats leaking from the ECCS equipment within the pump rooms following a I.OCA are filtered prior to reaching the environment. The system's ability to perform this function is maintained.

Deleti,1g the bank flow testing surveillance requirement does not affect the operation of the VA system. The change will align the testing requirements,

with the approved ANSI N5101980 methods. The new surveillance requirement ensures that bank flow testing is performed after structural maintenance on the HEPA filter or charcoal adsorber houeing.

Correcting the typographical error has no effect on any accident. Deleting the footnotes that are no longer applicable has no effect on the creation of any accident.

Deleting the word " cold" form the description of DOP testing has no effect on system operation as described in the UFSAR analysis. Since no new equipment is being added and no control changes are being pen'ormed, the possibility of an accident or malfunction of a different type than previously evaluated in the UFSAR is not created.

ZNLD/1916/10 l

m.-,..

m A., _

C.

Th3 propos:d ch ng:s do not involvo a signific nt reduction in a margin of safety. The Bases for Technical Specification 3/4.7.6 state that the operability of the system in conjunction with the control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent.

Dose calculations are based on a charcoal adsorber capable of removing 99% of radioactive forms of iodine. Charcoal efficiency drops as relative humidity increases. The proposed change ;imits the relative humidity entering the adsorbents to 70% in accordance with ANSI N5091976 and Regulatory Guide 1.52 design requirements. With entering air relative humidity maintained below 70%, charcoal efficiency remains above 99%, so the margin of safety is not affected.

The proposed VA system flow rates maintain all ECCS pump room pressures as required. The air i.ow provides negative pressure in the auxillary building to ensure that all radioact!ve materials from ECCS equipment within the pump rooms following a LOCA are filtered prior to reaching the environment. This is consistent with the Basis for Technical Specification 3/4.7.7.

Deleting the periodic VA bank flow testing will not affect the margin of safety because the surveillance requirements are in accordance with ANSI N5101980.

Deleting the footnotes that are no longer apalicable has no effect on the margin of safety. The typographical correct on is also editorialin nature and has no effect on the margin of safety.

Deleting the word " cold" from the descriation of the DOP testing will not affect the margin of safety because the aasis document, ANSI N510-1980, allows both " hot" and " cold" DOP testing.

Therefore, based on the above evaluation, Byron Station has concluded that these changes do not involve significant hazards consideration.

ZNLD/1916/11

9 4

ATTACHMENT D ENVIRONMENTAL ASSESSMENT Commonwealth Edison has evaluated the proposed amendment against the criteria for and identification of licensing ed regulatory actions requiring environmental assessment in accordanco vilth OCFR51.21. It has been determined that the proposed change meets it.e criteria for a categorical exclusion as provided for under 10CFR51.22(c)(9). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10CFR50, it involves changes to surveillance requirements and the amendment meets the following specific criteria:

(l) the amendment involves no significant hazards considerations As demonstrated in Attachment C, this proposed amendment does not involve any significant hazards considerations.-

(11) thero is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite As documented in Attachment A, there will be no change in the types or significant increase in the amounts of any effluents related offsite.

(iii) there is no significant increase in Individual or cumulative occupational radiation exposure -

The proposed change will not result in changes in the operation or configuration of the facility. There will be no change in the level of controls or methodology used for processing of radioactive effluents or handling of solid radioactive waste, nor will the proposal results in any change in the normal radiation levels within the plant. Therefore there will be no increase in Individual or cumulative occupational radiation exposure resulting frorn this change.

ZNLD/1916/12

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