ML20137P036

Proposed Tech Spec Changes,Increasing Time Allowed to Restore Inoperable Auxiliary Bldg Filtered Ventilation Exhauset Sys Train to Operable Status to 7 Days

ML20137P036
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/16/1985
From:	DUKE POWER CO.
To:
Shared Package
ML20137N998	List: ML20137N991 ML20137P036
References
NUDOCS 8509190476
Download: ML20137P036 (10)

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communicating with the system, by:

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Verifying that 'the cleanup system satisfies the in place pene-NIh1N y.

tration and bypass leakage testing acceptance criteria of less-N'? '

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Positions C.5.a. C.S.c and C.S.d of Regulatory Guide 1.52,

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iexceeding their design basis temperature and is consistent with the recommend-a ations of Regulatory Guide 1.27, " Ultimate Heat Sink for Nuclear Plants,"

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March 1974. -M.The Surveillance Requirements specified for the dcs inspection i

'will conform to the recommendations of Regulatory Guide 1.127, Revision 1, March 1978 ' Q e

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The OPERABILITY of the Control Area Ventilation System ensures that:

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r' (1) the ambient air temperature does not exceed the allowable temperature for 3W l

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,tcontinuous duty rating for the equipment and instrumentation cooled by this

_.fsystem,'and (2) the control room will remain habitable for operations personnelW$"

during and following all credible accident conditions.? Cumulative operation .9h...

'of the system with the-heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31-day period is - om.0@h$

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' sufficient to reduce the buildup of moisture on the adsorbers and HEPA

.ifilters. The OPERABILITY of this system in conjunction with control room < C$[y;2 t

Idesign provisions is based on limiting the radiation exposure to personnel M

..m occupying the control room to 5 rem or less whole body, or its equivalent.

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f e requirements of General Design

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Criterion 19 of Appendix A,10 CFR 50.

ANSI N510-1975 will be used as a Q.l}-l?iproceduralguideforsurveillancetesting.

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M/;. ' 7., 3/4.7.7 AUXILIARY BUILDING FILTERED VENTILATION EXHAUST SYSTEM 7 ? ? R.

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The OPERABILITY of the Auxiliary Buf1 ding Filtered Ventilation Exhaust i

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System ensures that radioactive materials leaking from the ECCS equipment '

!.:l within the auxiliary building following a LOCA are filtered prior to reaching

~the environment.

peration-of--thic systea; and4hc resultant effect or l

d' offdtc dosage-ca uktions were essumed-in-the-accident analyses, ANSI A '~i-N510-1975 will be

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sed as a procedural guide for surveillance testing.

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8 methyl iodide penet. ration test criteria for the carbon samples have been made more restrictive t an required for the assumed iodine removal in the accident analysis because t e humidity may be, greater than 70% under normal operating j

conditions.

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E Justification and Safety Analysis t

The Auxiliary Bailding Filtered Vencilation Exhaust (VA) system Technical Specification (3.7.7) action requirement currently allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for restor-4 i

ation of an inoperable system, otherwise 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 />.

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However, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is not a sufficient amount of time for certain corrective actions such as replacing the large Charcoal Adsorber Beds or performance of other i

maintenance when the system is inoperable (replacing one of the Carbon Filter Units and subsequent testing requires approximately 5 dayc).

Since Charcoal Filter performance tests do not occur only at scheduled outages this could j

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necessitate a unit shutdown with attendant undesirable thermal cycle and J. '

detrimental effects on availability, component lifetime and safety.

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the proposed amendment would increase the time allowed to restore the inoperableCons l

VA system to operable status to 7 days (2 days allowed for unexpected delays).

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j-The function of the VA system is to filter radioactive materials associated with coolant leakage from ECCS equipment in the Auxiliary Building (shared for both units) following a LOCA which may involve release from the fuel as a i

result of heatup. The McGuire FSAR (Section 9.4.2)c describes the VA system I

as a single train system for each separate unit (as opposed to one large shared system).

before beginning shutdown, instead of 7 days as in Standard A

cations.

Actually, the air intakes for these two VA trains are located in the same general (open) area of the Auxiliary Building near the ECCS Pump Rooms.

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Therefore, the VA system trains have the capability to back up each other.

j Although the two VA system trains are not exactly equivalent, either train has sufficient capacity to maintain the Auxiliary Building under negative j

pressure.

Further, following a LOCA on either unit the Auxiliary Building j

normal ventilation system is isolated and both trains of the VA system start automatically.

The only exhaust from the Auxiliary Building is via one or the i

other (or both) filtered exhaust trains; as a result there is no unfiltered exhaust even if only one filtered exhaust train is functional.

have sufficient diversity of power sources to ensure the operability of both Both trains j

in the event of a design basis accident at one of the units.

j It is Duke's engineering judgement that defacto redundancy exists for the VA system.

detailed description of the VA system is provided in attachment 2A,along with 9 A

"as built" drawings with appropriate protions of the VA syst em highlighted.

Based on the above judgement of defacto redundancy, the requirenent to restore the VA system to operability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is excessively stringent when compared with other filtered ventilation systems required for safety. For example, the McGuire (slared) Control Room is equipped with two filtered i

ventilation systems for which Technical Specifications (TS 3.7.6) allow 2

i 7 days to restore the inoperable system to operability provided the redundant system is functional.

Further, Westinghouse standard Technical Specifications (Rev. 4 TS 3.7.8) allow a 7 day restoration period for redundant ECCS Pump i

Room exhaust air cleanup systems (which correspond to McGuire's VA system).

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The offsite dose consequences of a LOCA are discussed in FSAR Section 15.6.4.3 and Table 15.6.4-11.

REM at the exclusion area boundary.The thyroid doses with ECCS equipment leak Although the VA system is provided to i

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Page 2 reduce offsite doses due to excessive ESF equipment leakages following a LOCA, no credit is taken for Auxiliary Building exhaust filtration in these calcula-tions.

Therefore, the dose consequences would not exceed 200 REM (thyroid dose) whether or not any VA train is functional post-LOCA.

These consequences are well within 100FR 100 requirements...In areallife situation the consequences are expected to be less since at least one VA train is expected to be functional.

In fact, inoperability of one filter train reduces offsite doses slightly because the Auxiliary Building air is processed more slowly by a single unit allowing some decay of the radioactivity. Therefore, the consequences of inoperability of one VA system train following a LOCA are insignificant.

Finally, the requested 7-day duration of operation without each unit having its own VA train operable is small.

The VA system is not required for normal oper.

ation and is only used post-LOCA. The probability of a LOCA occurrence with potential for core heatup during this exposure time is extremely small.

For example, considering a large break (>6 inches) LOCA frequency of 4.7 x 10-5 per reactor year (Ref. Sequoyah RSSMAP-NUREG/CR-1659 large break LOCA during a 7-day period is 9.0 x 10-7) the probability of a The probability of excessive ECCS leakages subsequent to a LOCA are even smaller.

Therefore, the proposed Technical Specification change does not involve any undue risk to the health and safety of the public, and would avoid unnecessary thermal cycles and provide real benefits in terms of availability, component lifetime and safety.

In addition, the footnote for T.S. 3.7.7 which allowed hot standy conditions to be maintained until 11:59 p.m., September 7, 1983,without proceeding to cold shutdown is being deleted since it is no longer applicable.. This is an administrative change only and has no safety implications.

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Attechm:nt 2A Additional Information Regarding The Auxiliary Building Ventilation System 1.0 Auxiliary Buildino Supply & Exhaust 1.1 System Puroose 1.1.1 The purpose cif this system is to provide the " normal" ventilation and "emer-gency" exhaust requirements for the Auxiliary Building. The Auxiliary Building supply and unfiltered exhaust serve no function during a LOCA and are not Nuclear Safety Related. The filtered exhaust, however, does function during a LOCA.

1.2 System Description & Function 1.2.1 The supply portion of this system consists of four (4) 50% capacity air handling units, two (2) in Unit I and two (2) In Unit 2, containing water cooling coils, hot water heating coils, roughing filters, and associated ductwork.

1.2.2 The laks water cooling coils are controlled by a thermostat with averaging bulb located in the air handling unit discharge. This thermostat is set at 45 F, and will call for cooling as long as the discharge temperature is above 45 F.

Out-side air temperature and cooling water supply temperature are monitored and compared to determine if lake water should be admitted to the cooling coils.

if the lake water is cooler than outside air, the RV throttling valve will open and allow flow through the coils.

if the outside air temperature is less than the cooling water temperature, the RV throttling valve will close to take advantage *of the cooling effect of the cooler outside air.

1.2.3 The heating coils are supplied a water glycol solution from a primary-secondary hot water heating system (YH). Supply to the coils is also thermostatically controlled by the thermostat with averaging bulb located in the air handling unit discharge.

1.2.4 The thermostat with averaging bulb located in the discharge of the supply units controls both the cooling and heating operations. The thermostat is set for 45 F and will call for cooling (either from iake water or outside air) as long as the discharge temperature remains above 45 F.

When the discharge temperature falls to 45 F or below, the thermostat will open the heating water valve, controlling the discharge temperature at 45 F.

i 1.2.5 The exhaust portion of this system is divided into unfiltered exhaust and filtered exhaust. The unfiltered exhaust consists of four (4) 50%

fans, two (2) in Unit I and two (2) in Unit 2, and associated ductwork. capacity The unfiltered exhaust takes air from the non-contaminated areas of the auxiliary building and discharges directly to the atmosphere through the unit vent stack.

The filtered exhaust consists of four (4) 50% capacity fans, two (2) in Unit I and two (2) in Unit 2, and two (2) filter trains, one (1) in Unit I and one (1)

In Unit 2, and associated ductwork. The filtered exhaust takes air from poten-tially contaminated areas of the auxiliary building and filters it prior to discharge to the atmosphere through the unit vent stack.

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1.2.6 The auxiliary building filtered exhaust filter train contains prefilters, absolute filters, and carbon filters of the gasketless design.

1.2.7 Dampers consist of check valve type dampers in the discharge of fans for Isolation; pneumatic motor operated dampers on outside air intake to the supply units for shut-off; pneumrtic motor operated dampers on outside intake to filter units for shutoff and volume control; manual volume dampers to balance air flow in duct system; and pneumatic motor operated isolation dampers on filter units for bypass control.

1.2.8 Air flow monitors are provided in the filtered and unfiltered exhaust ducts to the unit vent stack, and the supply duct to monitor air flow rates (cfm).

Read-outs are on control panels I ABFX-CP-IB and 2ABFX-CP-lB for filtered exhaust and IRB-CP-1 and 2RB-CP-1 for unfiltered exhaust and supply air.

1.2 9 A thermostat in the discharge of the charcoal absorber section of the filtered exhaust filter train controls the outside air intake to the filter tra!n to maintain a maximum discharge temperature of 200 F.

1.2.10 High limit thermostats set for 160 F and located at the intake to the filtered exhaust filter trains and the intake to the unfiltered exhaust fans will shutdown' the auxiliary building supply air handling units if actuated.

1.2.11 The supply units are freeze protected by a low limit thermostat located in the dischcrge of the heating coll. The thermostat is set for 35 F and will shut down the supply unit if actuated. Another low limit thermostat located s

in the gutside air intake is set for 40 F and will start the secondary hot 0

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water pump if actuated.

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1.3 Component Desion Parameters 3

1.3.1 Auxiliary Building Supply Units (MCH-1211.00-252) a) Design Flow /AH Unit 31,355 cfm b) External Static Press / Unit 3.82 inches w.g.

c) Air Density 0.075 PCF d) Motor HP 40 e) Motor Electrical Data 575v/60cy/3ph f) Cooling Coil Data Ent. Air 95 Fdb & 78 Fwb Leav. Air 73 1 db & 72.3 Fwb Ent. Water 70 F Leav. Water 77 F Gpm 195 g) Heating Coil Data Ent. Air 10 F Leav. Air 81 F Ent. Glycol 190 F Leav. Glycol 154 F Gpm 149 1.3.2 p,

Auxiliary Building Unfiltered Exhaust Fans (HCH-1211.00-359 and 360) a) Design Flow / Fan 19,074 b) Static Press 4.47 inches w.g.

c) Air Density 0.075 PCF d) Motor HP 25 e) Hotor Electrical Data 575v/60cy/3ph

1.3.3 Auxiliary Building Filtered Exhaust Fans (MCM-1211.00-361 and 362) a) Design Flow / Fan Unit i Unit 2 27,140 cfm

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b) Static Press 21,700 cfm c) Air Density 8.0 inches w.g.

d) Motor H.P.

0.075 PCF Unit 1 40 Unit 2 30 e) Motor Electrical Data 575/60cy/3ph 1.4 Instrumentation and Control 1.4.1 Electrical 1.4.1.1 For detailed information concerning electrical Instrumentation and control refer to the electrical system description in Duke File humber MCSD-0166-00.

1.4.2 Pneumatic 1

1.4.2.1 For detailed information concerning pneumatic Instrumentation and control refer to Duke drawings MC-1522-01.56-00 and MC-1522-01 57.00, and Duke File Number MCM-1211.00-707.

1.4.3 Control Panels 1.4.3.1 The HVAC Main Control Board (hereinaf ter referred to as HVAC located in the Control Room as indicated on Duke drawing MC-1205-4.1.

1.4.3.2 description in Duke File Number MCSD-0166-00,For location o 1.4.3.3 Pneumatic control panels IRB-CP-1, IRB-CP-IA, 2RB-CP-1 and 2RB-CP-IA Building as indicated on Duke drawings MC-1205-2 a 1.4.4 Startup and Operat!on Sequence 1.4.4.1 for ABSU-2A and 2B on control panel 2RB-ECP-1 in Au c es will start provided all exhaust fans are operating.

Supply fans 1.4.4.2 Place switches for ABFXF-IA, IB and ABFXF-2A, 2B on control panels IB and 2ABFX-ECP-!A, fans will start.

IB respectively to On position and filtered exhaust 1.4.4.3 Place swi tches ABUXF-1A, 2RB-ECP-l respectively to On position and the unfiltered e s ta r t.

7 I.4.4.4 Place switches for ABI-P-2, 2A, 3 and 3A and AB2-P-2, 2A, 3, 3A, on contr panels IRB-ECP-1 and 2RB-ECP-i respectively to Auto position.

should remain in Auto position except when the hot water pumps are down forT maintenance, or when Hand position is used to test operation of the hot water pumps, or when it is necessary to manually operate the hot water pumps due

to a malfunction of the automatic controls.

1.5 _ System ooeration 1.5.1 The normal mode of operation for this system requires the operation of all exhaust fans and supply fans during normal plant operation.

1.5.2 If any one (1) of the unfiltered exhaust fans stops operating for any reason, the associated supply unit will stop operating, i.e., if unfiltered cxhaust fan ABUXF-IA stops operating then supply unit ABSU-IA will stop operating, etc.

building, This is required to prevent pressurization of the auxiliary 1.5.3 i

If any one (1) of the filtered exhaust fans stops operating for any reason, all of the supply fans will stop operating.

This is to prevent pressuriza-tion of the auxiliary building and to prevent movement of air from potentially contaminated areas to non-contaminated areas.

1.5.4 if a fire alarm Indicates a fire in one (1) of the filtered exhaust filter trains, the Operator must manually open the deluge valve at the filter train.

1.6 Maintenance 1.6.1 Visually check the operation of dampers every 90 days making sure they open fully and close tight.

Replace or repair damaged parts as necessary.

1.6.2 Lubricite fan bearings in accordance with manufacturer's recommendations.

1.6.3 Visually inspect fan drive belts every 90 days, adjust belt tension and replace belts as necessary.

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1.6.4 Maintenance of valves and pumps in hot water system to be covered in system description for the heating water system - YH in Duke File Number MC-121100-1.6.5 Maintenance of filtered exhaust filter train covered in CVI Ma Operation Manual in Duke File Number MCM-1211.00-525.

1.6.6 Visually inspect operation of valves IRV28, IRV23, 2RV28 and 2RV23 every 9 days. Check diaphragm and spring operation. Replace damaged parts as" necessary.

1.6.7 Change filters in supply units as indicated by filter change lights on control panels IRB-ECP-1 and 2RB-ECP-1.

1.6.8 The Mechanical Contractor responsible for the installation work is Bahnson Service Company, P. O. Box 10458, Winston Salem, N.C. 27108 Telephone:

919-724-1581.

Contact this firm for other than routine maintenance problems.

1.6.9 The pneumatic controls sub-contractor to Bahnson Service Company is Powers Regulator Company, Charlotte, N.C.

They may be contacted directly for what' f

appears to be a pneumatic controls problem; although, preferably they should be contacted through Bahnson Service Company.

s 1.6.10 None of the electrical controls are vendor (Powers Regulator Co.) supplied l.6.11 Check operation of pneumatic controls yea or malfunctioning controls as necessary. rly. Repair or replace damaged T

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e Analysis of Sienificant Hazards Consideration As required by 10 CFR 50.91, this analysis is provided concerning whether the proposed a=end=ents involve significant hazards considerations by 10 CFR 50.92.

no significant hazards considerations are if operation of the

, as defined accordance with the proposed amendment would not:

1) involve a significant

2) create the possibility of a new or different kind of a e;

previously evaluated; or 3) involve a significant reduction in margin of safety ent The proposed amendment would increase the time allowed to restore an inop VA system to operable status from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days.

Because the VA system serves only to mitigate the consequences of a LOCA probability of an accident is unaffected by the proposed amendment.

, the sequences of an accident are not significantly increased by the proposed amend-The con-postulated ECCS leakage, (2) no credit for VA system fi offsite dose LOCA calculations, and j)3) the probability of a LOCA du seven-day period is small (9.0 x 10-No new or different accident is created by the proposed change because the VA system only serves to mitigate accidents.

The safety margins contained in the LOCA analyses described in the FSAR are unaffected.

cantly affected with one VA train filter out of service.Also, the dose signifi-proposed amendment would not involve a significant decrease in a safety ma Accordingly, the The deletion of the outdated footnote which allowed hot standby condition only and has no safety implicaitons.be maintained until 11:59 p.m.,

September 7,1983, is an administrative chang s to e

Based upon the preceding analyses, Duke Power Company concludes that the p amendments do not involve a significant hazards consideration.

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