ML20117D173

Proposed Tech Specs 3/4.7.7 Re non-accessible Area Exhaust Filter Plenum Ventilation Sys

ML20117D173
Person / Time
Site:	Byron, Braidwood
Issue date:	08/23/1996
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20117D151	List: ML20117D145 ML20117D173
References
NUDOCS 9608280190
Download: ML20117D173 (13)

Text

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ATTACHMENT B l

MARKED ITP PAGES FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF l FACILITY OPERATING LICENSES l .NPF-37, NPF-66, NPF-72, AND NPF-77 BYRON STATION UNITS 1 & 2 BRAIDWOOD STATION UNITS 1 & 2 REVISED PAGES: REVISED PAGES:

3/4 7-19 3/4 7-17 B 3/4 7-5 B 3/4 7-4 i

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9608290190 960823 PDR ADOCK 05000454 P PDR

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. 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% V 1 "'I capacity each) ces penum in i sha)asag><OPERABLEy wW4 b pcou-..r 4 /irned & c/><rcum APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one non-accessible area exhaust filter plenum inoperable, restore the inoperable plenum to OPERABLE status within 7 days or be in at least HOT l 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 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.f M URVEILLANCE REQUIREMENTS 4.7.7 Each non-accessible area exhaust filter plenum shall be demonstrated

, OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that operation occurs for at least 15 minutes;

b. At least once per 18 months, or (1) after any structural maintenance  !

on the HEPA filter or charcoal adsorber housings, or (2) following '

painting, fire, or chemical release in any ventilation zone communi-cating with the exhaust filter plenum by:

1) Verifying that the exhaust filter plenum satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 1% when using the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide '

1.52, Revision 2, March 1978, and the flow rate is between [

55,669 cfm and 68,200 cfm for the train; ,

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, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for methyl iodide penetration of less than 1% when tested at the 4/

temperature of 30*C and a relative humidity of 70%;

O BYRON - UNITS 1 & 2 3/4 7-19 t

AMENDMENTNO.A

9 INSERT A During testing of any inoperable plenum, it is acceptable to place one of the two OPERABLE plenums in standby.

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PLANT SYSTEMS I

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BASES 4

CONTROL ROOM VENTILATION SYSTEM (Continued) j 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.

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This limitation is consistent with the requirements of General Design Cri-terion 19 of Appendix A, 10 CFR Part 50. ANSI N510-1980 will be used as a

procedural guide for surveillance testing.

' The surveillance requirement to verify that each control room ventilation system has the capability to remove the required heat load, as

determined by the original heat capacity verification test, consists of a combination of testing and calculations. The 18-month frequency is appropriate since significant degradation of the control room ventilation b

system is slow and not expected over this time period.

3/4.7.7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM 1

The OPERABILITY of the Non-Accessible Area Exhaust Filter Plenum j Ventilation System ensures that radioactive materials leaking from the ECCS l equipment within the pump rooms following a LOCA are filtered prior to reaching the environment. The operation of this system and the resultant 3

1 effect on offsite dosage calculations was assumed in the safety analyses.

' yNSIN510-1980 will be used as a procedural guide for surveillance testing.

.Tnud Y l 3/4.7.8 SNUBBERS

! All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems 4 is maintained during and following a seismic or other event initiating dynamic

) loads.

Snubbers are classified and grouped by design and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features

! of the 2-kip,10-kip, and 100-kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by for the purposes of this specification would be of a different Company "B" type, as would hydraulic snubbers from either manufacturer.

I A list of individual snubbers with detailed information of snubber loca-tion and size and of systems affected shall be available at the plant in l accordance with Section 50.7)(c) of 10 CFR Part 50. The accessibility of each i snubber shall be determined and approved by the Onsite Review and Investigative Function. The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each

, snubber location as well as other factors associated with accessibility during 1 plant operations (e.g., temperature, atmosphere, location, etc.), and the i recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

t The visual inspection frequency is based upon maintaining a constant i level of snubber protection during an earthquake or severe transient. There-fore, the required inspection interval varies inversely with the observed BYRON - UNITS 1 & 2 B 3/4 7-5 AMENDMENT N0.

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The.Non-Accessible Area Exhaust Filter Plenum Ventilation System j is designed such that two plenums are on line and one plenum is i in standby. A plenum is in standby if its inlet damper is

operable but closed, and all remaining components are operable.

This alignment ensures proper air flow and prevents fan stall and

, possible fan damage. The action statement provisions for standby j plenums are necessary to accommodate required post maintenance

and surveillance testing activities. These provisions allow an i operable plenum to be placed in standby while performing testing

j. on an inoperable plenum. The standby plenum will still be capable of being realigned and filtering ECCS cubicle air in the

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i event of a LOCA.

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PLANT SYSTEMS 3/4.7.7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM

! LIMITING CONDITION FOR OPERATION l

J 3.7.7* Three independent non-accessible area exhaust filter plenums (50%

l capacityeach)shallbeOPERA8LEgwwh hv o p la n u ar . ug,/ rn- ,pw</an cuJ

one pie ora m an i fwlby, i APPLICABILITY

MODES 1, 2, 3, and 4.

i j ACTION:

! With one non-accessible area exhaust filter plenum inoperable, restore the

! inoperable plenum to OPERABLE status within 7 days or be in at least H0T

! STAN08Y 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 l i

30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.9 i hyot k I l SURVEILLANCE REQUIREMENTS i

l 4.7.7 Each non-accessible area exhaust filter plenum shall be demonstrated OPERABLE: ,

a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that operation occurs for at least 15 minutes, i l

b. At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings or (2) following painting, fire, or chemical release in any ventilation zone communi-  !

cating with the exhaust filter plenum by: l

1) Verifying that the exhaust filter plenum satisfies the in place penetration and bypass leakage testing acceptance criteria of l i

1ess than 1% when using the test procedure guidance in Regulatory Positions C.5.a. C.5.c and C.S.d of Regulatory Guide 1.52, Revi- l sion 2, March 1978, and the flow rate is 66,900 cra 2 10% for the train and 22.300 cfa 1101 per bank; i

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, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for methyl iodide penetration of less than 1% when tested at the temperature of 30'C and a relative humidity of' 70%;

• Not applicable prior to December 1, 1907.

BRAIDWOOD - UNITS 1 & 2 3/4 7-17 M E& henf d.

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INSERT A 1 During t.esting of any inoperable plenum, it is acceptable to pla'ce one of the two OPERABLE plenums in standby. 1 l l l l l l l l l

PLANT SYSTEMS BASES a 3/4.7.6 CONTROL ROOM VENTILATION SYSTEM The OPERABILITY of the Control Room. Ventilation System ensures that: (1)  ; the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system, and (2) the control roam will remain habitable for operations personnel during and following all credible accident conditions. Operation of the system with the heaters operating for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system in conjunction with 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. This limitation is consistent with the requirements of General Design Cri-terion 19 of Appendix A, 10 CFR Part 50. ANSI N510-1980 will be used as a procedural guide for surveillance testing. The surveillance requirement to verify that each control room ventilation system has the capability to remove the required heat load, as detemined by the original heat capacity verification test, consists of a combination of '. testing and calculations. The 18-month frequency is appropriate since significant degradation of the control room ventilation system is slow and not expected over this time period. , 3 /4. 7. 7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM The OPERABILITY of the Non-Accessible Area Exhaust Filter Plenum Ventilation System ensures that radioactive materials leaking from the ECCS l equipment within the pump rooms following a LOCA are filtered prior to reaching l the environment. The operation of this system and the resultant effect on offsite dosage calculations was assumed in the safety analyses. ANSI H510-1980 1

 ]%yy 0. _ will be used as a procedural guide for surveillance Itesting. g.

3/4.7.8 SNUBBERS All snubbe's r are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems is main-tained during and following a seismic or other event initiating dynamic loads. Snubbers are classified and grouped by desiin and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features of the 2-kip, 10-kip, and 100-kip capacity manufactured by Company "A" are of the same type.' The same design mechanical snubbers manufactured by Company "B" for the purposes of this specification would be of a different type, as would hydraulic snubbers from either manufacturer. A list of individual snubbers with detailed information of snubber loca-tion and size and of systems affected shall be available at the plant in accor-dance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall be determined and approved by the Onsite Review and Investigative Function. The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber location B 3/4 7-4 Amendment No. RRAIDWOOD - UNITS 1 & 2

INSERT B The,Non-Accessible Area Exhaust Filter Plenum Ventilation System is designed such that two plenums are on line and one plenum is in standby. A plenum is in standby if its inlet damper is operable but closed, and all remaining components are operable. This alignment ensures proper air flow and prevents fan stall and possible fan damage. The action statement provisions for standby plenums are necessary to accommodate required post maintenance and surveillance testing activities. These provisions allow an operable plenum to be placed in standby while performing testing , on an inoperable plenum. The standby plenum will still be capable of being realigned and filtering ECCS cubicle air in the event of a LOCA. i

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ATTACHMENT C EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATIONS FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72, AND NPF-77 Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to Title 10 Code of Federal Regulations Section 50 Subsection 92 Paragraph c (10 CFR 50.92 (c)), a proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment 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.

A. IBERODUCTION Commonwealth Edison (Comed) proposes to amend Byron and Braidwood Technical Specification (TS) 3.7.7, "Non-Accessible Area Exhaust Filter Plenum Ventilation System," and the bases for this TS. This amendment will provide clarification of allowed system lineups which satisfy the requirements of TS 3.7.7. B. NO SIGNIFICANT HAZARDS ANALYSIS

1. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Non-Accessible Area Exhaust Filter Plenum Ventilation (VA) System lineups are not considered as the precursors to any accident. The additional provisions added to the action statement for TS 3.7.7 accommodates required maintenance and surveillance activities. No new equipment is being installed and no existing equipment is being modified. Thus, these proposed changes will not result in an increase in the probability of occurrence of an accident previously evaluated. 1

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On the postulated Loss Of Coolant Accident (LOCA) with Loss Of Offsite Power (LOOP), the operating plenum will either realign immediately or following the re-energization of its ESF bus which will occur within 10 seconds. Thus, there will always be at least one plenum operating immediately during an accident. The emergency procedures direct the

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realignment of the standby plenum. This direction is contained in the Byron and Braidwood Emergency Procedures (BEP/BwEP)-0, " Reactor Trip or Safety Injection," and is performed prior to conducting event diagnostic steps. Filtration of the air from the Emergency Core Cooling System ' (ECCS) equipment cubicles becomes critical when the ECCS pumps begin pumping accident water from the containment  ! recirculation sumps. Prior to this the water flowing in these pumps is Refueling Water Storage Tank (RWST) water. This swap over from the RWST to the containment recirculation sump is expected to occur, at the earliest, 11 minutes following accident initiation leaving time to open the inlet damper on the standby VA plenum. Thus, since the standby plenum can be realigned before filtration of the i ECCS equipment cubicle air is required, the Updated. Final Safety Analysis Report (UFSAR) assumptions, and offsite dose  ! calculation assumptions remain valid. There will be no i significant change in the types or significant increase in i the amounts of any effluent that may be released offsite, and there will be no significant increase in individual or > cumulative occupational radiation exposure. Observations conducted on licensed operators undergoing simulator , training verified that the VA system is realigned well l before the swap-over to the containment recirculation sump under these conditions. Therefore,these proposed changes will not result in a significant increase in the  ! consequences of an accident previously evaluated. , A review of the Byron and Braidwood Probabilistic Risk i Assessment (PRA) shows that these proposed changes will have no effect on either Core Damage Frequency (CDF) or Uncontrolled Release Frequency (URF). Therefore, these changes do not involve a significant l increase in the probability or consequences of an accident previously evaluated.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

These proposed changes continue to ensure that, following a LOCA, the air being exhausted from the ECCS equipment rooms is properly filtered before being released to the  ! environment. 2 j

l 9 l These changes will not result in the installation of any new l equipment or the modification of any existing equipment. No

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new operating modes or system interfaces will be created. l The VA system will continue to operate as designed during normal and-post accident conditions. All of the accident analysis assumptions and conditions will remain satisfied Thus this proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed change does not involve a significant reduction in a margin of safety.

These proposed changes reflect the design lineup for the VA system and provide action requirements to accommodate required maintenance and surveillance testing. The VA' system will continue to ensure that following a LOCA, the air being exhausted from the ECCS equipment rooms is properly filtered before being released to the environment. Filtration of the ECCS equipment cubicle air does not become l critical until the suction of the ECCS pumps is switched from the RWST to the_ containment recirculation sumps. This is postulated to occur, at the earliest, 11 minutes following accident initiation. On the postulated LOCA with i LOOP, at least one VA plenum will be in operation immediately and the emergency procedures direct the re-alignment of the standby plenum well before the ECCS pump ! suction swap-over. Observations conducted on licensed-

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operators undergoing simulator training have verified this fact. Therefore, these proposed changes do not alter or l affect any UFSAR or off-site dose calculation assumptions, and the margin of safety is not reduced. l A review of the Byron and Braidwood PRA shows that these l proposed changes will have no effect on either CDF or URF. No new equipment is being installed, and no existing equipment is being modified. The VA system will continue-to operate as designed during normal and post accident conditions. All of the accident analysis assumptions remain satisfied. > I l Therefore this proposed change does not involve a  ! significant reduction in a margin of safety. Therefore, based on the above evaluation, Commonwealth Edison has concluded that these changes involve no significant hazards - considerations. 3 l l l l

m ATTACHMENT D 1 l ENVIRONMENTAL ASSESSMENT FOR j PROPOSED CHANGES TO APPENDIX A l TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES NPF-37, NPF-66, NPF-72, AND NPF-77 Commonwealth Edison Company (Comed) has evaluated this proposed license amendment request against the criteria for identification of licensing and regulatory actions requiring environmental assessment in accordance with Title 10, Code of Federal ) Regulations, Part 51, Section 21 (10 CFR 51.21). Comed has  ! determined that this proposed license amendment request meets the l criteria for a categorical exclusion set forth in i 10 CFR 51.22(c)(9). This determination is based upon the following-  ! i

1. The proposed licensing action involves the issuance of l an amendment to a license for a reactor pursuant to 10 CFR 50 which changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or which changes an inspection or a surveillance requirement. This proposed license amendment request will provide clarification of allowed system lineups which satisfy the requirements of Technical Specification 3.7.7, and provide action requirements to ,

accommodate required maintenance and surveillance  ! activities on the Non-Accessible Area Filter Plenum Ventilation System.

2. As demonstrated in Attachment C, this proposed license amendment request involves no significant hazards considerations;

3. As discussed in Attachment C, there is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite; and

4. There is no significant increase in individual or cumulative occupational radiation exposure.

Therefore, pursuant to 10 CFR 51.22(b), neither an environmental impact statement nor an environmental assessment is necessary for this proposed license amendment request.}}