ML20150F320

Proposed Tech Specs Re Control Room Emergency Filtration Sys & Control Room Air Filtration Sys

ML20150F320
Person / Time
Site:	Quad Cities
Issue date:	07/05/1988
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20150F315	List: ML20150F313 ML20150F320
References
4805K, NUDOCS 8807180232
Download: ML20150F320 (13)

Text

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1 ATTACHMENT 1 1

PROPOSED CHANGES TO APPENDIX A

' TECHNICAL SPECIFICATIONS FOR QUAD CITIES STATION UNITS 1 AND 2 FACILITY OPRRATING LICENSES DPR-29 AND DPR-30 Revised Pages: 3.8/4.8-14a (DPR 29) 3.8/4.8-14b (DPR 29) 3.8/4.8-19 (DPR 29) 3.8/4.8-14b (DPR 30) 3.8/4.8-14b (DPR 30) 3.8/4.A-19 (DPR 30) 4805K 8807180232 880705 PDR ADOCK 05000254 P PDC h .j

.. QUAD-CITIES

, . OPR 39

'H. Control Rcom Emergency Filtration H. Control Room Emergency Filtration System System

1. The control room emergency 1. At least once per month.

f11tration system, including at initiate 2000 cfm (i 10%) flow least one booster fan shall be through the control room operable at all times when emergency filtration system for secondary containment integrity at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the is required, except as specified heaters operable.

in Sections 3.8.H.I.a. or b.

a. After the control room emergency filtration system is made or found to be inoperable for any ieason.

reactor operation and fuel handling are permissible only during the succeeding 14 days. Within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following the 14 days, the reactor shall be placed in a condition for which the control room emergency f11tration system is not required in accordance with Specification 3.7.C.I a.

through d.

b. Specification 3.8.H.I.a.

above does not apply during performance of surveillance testing..or during removal of the charcoal test canisters.

2. Periodic Performance Requirements

2. Performance Requirement Tests

a. The results of the in-place 00P tests at 2000 cfm a. At least once per operating (i 10%) on HEPA filters cycle but not to exceed 18 Shall show less than or months, or following equal to 1.0% 00P painting, fire, or toxic penetration per bank when chemical release in any i tested with 0.3 micron DOP vent 11ation zone aerosol. comunicating with the intake of the system while

b. The results of in-place the system is operating that halogenated hydrocarbon c0uld contaminate the HEPA tests at 2000 cfm (i 10%) on filters or charcoal the overall charcoal banks aosorbers, perform the l shall show less than or following; equal to 0.5% penetration.

1) In-place 00P test the

c. The results of laboratory HEPA filter banks to carbon sample analysis of verify leaktight both carbon canisters shall integrity.

show less than or equal to 0.5% methyl todide 2) In-place test the penetration (overall) when charcoal adsorber banks tested at 30'C and 70% R.H. with halogenated l hydrocarbon tracer to verify leaktight integrity.

1301H/04142 3.8/4.8-14a Amendment No.

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QUAD-CITIES i DPR-29

3) Remove one carbon test canister from each charcoal adsorber bank.

Subject these samples to a laboratory analysis to verify methyl iodide removal efficiency.

b. At least once per operating cycle, but not to exceed 18 months, the following conditions shall be demonstrated:

1) Pressure drop across the ,

combined filters is less '

l than 6 inches of water at 2000 cfm (1 10%) flow rate.

2) Operability of inlet heater demonstrates heater AT of 15'F.

3. Postmaintenance Requirements

3. Postmaintenance Testing

a. After any maintenance or testing that could affect l a. After any maintenance or the HEPA filter or HEPA testing that could affect filter mounting frame the leaktight integrity of leaktight integrity, the the HEPA filters, perform results of the in-place DOP in-place 00P tests on the tests at 2000 cfm (1 10%) on HEPA filters in accordance HEPA filters shall show less with Specification 3.8.H.2.a.

than or equal to 1.0% DOP penetration per bank in b. After any maintenance or accordance with 3.8.H.2.a. testing that could affect the leaktight integrity of

b. After any maintenance or the charcoal adsorber banks, l testing that could affect perform halogenated the charcoal adsorber l hydrocarbon tests on the leaktight integrity, the charcoal adsorbers in results of in-place accordance with halogenated hydrocarbon Specification 3.8.H.2.b.

tests at 2000 cfm (1 10%)

shall show less than or l

equal to 0.5% overall penetration in accordance with 3.8.H.2.b.

130lH 3.8/4.8-14b Amendment No.

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. QUAD-CITIES DPR-29 3.8/4.8.C MECHANICAL VACUUM PUMP The purpose of isolating the mechanical vacuum line is to limit release of activity from the main condenser. During an accident, fission products would be transported from the reactor through the main-steamline to the main condenser. The fission product radioactivity would be sensed by.the main steamline radioactivity monitors which initiate isolation.

3.8/4.8.E SOLID RADI0 ACTIVE WASTE The operability of the solid radioactive waste system ensures that the system will be available for use whenever solid radwastes require processing and packaging prior to being siilpped off-site. This specification implements the requirements of 10 CFR 50.36a and General Design Criteria 60 of Appendix A to 10 CFR Part 50.

3.8/4.8.F MISCELLANEOUS RADI0 ACTIVE MATERIALS SOURCES The objective of this specification is to assure that leakage from byproduct, source and special nuclear material sources does not exceed allowable limits. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium.

'3.8/4.8.H CONTROL ROOM AIR FILTRATION The purpose of these specifications is to assure availability of the control room emergency air filtration unit that has been installed in response to NUREG-0737 Item III D.3.4. Operation of this unit is described in the "Control Room Habitabililty Study" for Quad-Cities Station which was submitted to the NRC in December 1981.

The frequency of tests and sample analysis is necessary to show that the HEPA filters and charcoal adsorbers can perform as eva'uated. The Control Room Filtration system in-place testing procedures will to established utilizing applicable sections of ANSI N510-1975 standard as a procedural guideline only. Operation of the Control Room Filtration system every month for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> will reduce the moisture buildup on the adsorbent. If painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis should be performed as required for operational use. Replacement adsorbent should be qualified according to the guidelines of Regulatory Guide 1.52, Revision 1 (June 1976). The charcoal adsorber efficiency test procedures will allow for the removal of one representative sample cartridge from each bank and testing in accordante with the guidelines of Table 3 of Regulatory Guide 1.52, Revision 1 (June 1976). The sample will be at least two inches in diameter and a length equal to the thickness of the bed. If the lodine removal efficiency test results are unacceptable, all adsorbent in the system will be replaced. High efficiency particulate filters are installed before and after the charcoal filters to prevent clogging of the carbon adsorbers and to minimize potential entrance of particulates that may be released to the environment following an accident. This will be demonstrated by in-place testing with DOP as the testing medium. Any HEPA filters found detective will be replaced with filters qualified to regulatory guide position C.3.d of Regulatory Guide 1.52, Revision 1 (June 1976). Once per operating cycle demonstration of HEPA filter pressure drop and operability of inlet heaters at rated power is necessary to assure system performance capability.

130lH/ 3.8/4.8-19 Amendment No.

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O a QUAD-CITIES

• OPR-30 H. Control Room Emergency Filtration H. Control Room Energency Filtration Syst en System

1. 'The control room emergency 1. At least once per month, filtration system. including at initiate 2000 cfm (i 10%) flow least one booster fan shall be through the control room operable at all times when emergency filtration system for secondary containment integrity at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the is required, except as specified heaters operable.

in Sections 3.8.H.1.a. or b. l

a. Af ter the control room emergency filtration system is made or found to be inoperable for any reason.

reactor operation and fuel handling are permissible only curing the succeeding 14 days. Within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following the 14 days, the reactor shall be placed in a condition for which the

. control room emergency filtration system is not required in accordance with Specification 3.7.C.I.a.

throush d.

b. Specification 3.8.H.I.a.

above does not apply during perfornunce of surveillance testing, or during removal of the charcoal test canisters.

2. Periodic Performance Requirements

2. Performance Requirement Tests

a. The results of the in-place 00P tests at 2000 cfm a. At least once per operating (i 10%) on HEPA filters cycle but not to exceed 18 shall show less than or months, or following equal to 1.0% 00P painting, fire, or toxic penetration per bank when chemical release in any tested with 0.3 micron 00P ventilation zone aerosol. consnunicating with the intake of the system while

b. The results of in-place the system is operating that halogenated hydrocarbon could contaminate the HEPA tests at 2000 cfm (i 10%) on filters or charcoal the overall charcoal banks adsorbers, perform the l

shall show less than or following:

equal to 0.5% penetration.

1) In-place 00P test the

c. The results of laboratory HEPA filter banks to carbon sample analysis of verify leaktight both carbon canisters shall integrity, show less than or equal to 0.5% methyl iodtde 2) In-place test the I penetration (overall) when charcoal adsorber banks tested at 30'C and 70% R.H. with halogenated l teydrocarbon tracer to verify leaktight integrity.

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1302H/0414Z 3.8/4.8-144 Amen $nent No.

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3) Remove one carbon test canister from each charcoal adsorber bank.

Subject these samples to a laboratory analysis to verify methyl iodide removal efficiency.

b. At least once per operating cycle, but not to exceed 18 months, the following conditions shall be demonstrated:

1) Pressure drop across the combined filters is less than 6 inches of water at 2000 cfm (1 10%) flow rate.

2) Operability of inlet heater demonstrates heater AT of 15'F.

3. Postmaintenance Requirements 3. Postmaintenance Testing

a. After any maintenance or a. After any maintenance or testing that could affect testing that could affect the HEPA filter or HEPA the leaktight integrity of filter mounting frame the HEPA filters, perform leaktight integrity, the in-place DOP tests on the

results of the in-place DOP HEPA filters in accordance tests at 2000 cfm (2 10%) on with Specification 3.8 H.2.a.

HEPA filters shall show less than or equal to 1.0% 00P b. After any maintenance or penetration per bank in testing that could affect accordance with 3.8 H.2.a. the leaktight integrity of the charcoal adsorber banks, l ,

b. After any maintenance or perform halogenated testing that could affect hydrocarbon tests on the the charcoal adsorber l charcoal adsorbers in leaktight integrity, the accordance with results of in-place Specification 3.8.H.2.b.

halogenated hydrocarbon tests at 2000 cfm (2 10%)

shall show less than or equal to 0.5% overall penetration in accordance with 3.8.H.2.b.

1302H/0414Z 3.8/4.8-14b Amendment No.

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,',. QUAD-CITIES ,

OPR-30 3.8/4.8.C MECHANICAL VACUUM PUMP l The purpose of isolating the mechanical vacuum line is to limit release of activity from the main condenser. During an accident, fission products would be transported from the reactor through the main steamline to the main condenser. The fission product radioactivity would be sensed by the main steamline radioactivity monitors which

. initiate isolation.

3.8/4.8.E SOLID RADI0 ACTIVE HASTE -

The operability of the solid radioactive waste system ensures that the system will be available for use whenever solid radwastes require processing and packaging prior to being shipped off-site. This specification implements the requirements of 10 CFR 50.36a and General Design Criteria 60 of Appendix A to 10 CFR Part 50, 3.'/4.8.F MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES Tht =bjective of this specification is to assure that leakage from byproduct, source and spt al nuclear material sources does not exceed allowable limits. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium.

3.8/4.8.H CONTROL ROOM AIR FILTRATION ThJ purpose of these specifications is to assure availability of the control room emergency air filtration unit that has been installed in response to NUREG-0737 Item III.

D 3.4. Operation of this unit is described in the "Control Room Habitabililty Study" for Quad-Cities Station which was submitted to the NRC in December 1981.

The frequency of tests and sample analysis is necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. The Control Room Filtration system in-place testing procedures will be established utilizing applicable sections of ANSI N510-1975 standard as a procedural guideline only. Operation of the Control Room Filtration system every month for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> will reduce the moisture buildup on the adsorbent. If painting, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals, or foreign materials, the same tests and sample analysis should be performed as required for operational use. Replacement adsorbent should be quallfled according to the guidelines of Regulatory Guldt 1.52, Revision 1 (June 1976). The charcoal adsorber efficiency test procedures will allow for the removal of one representative sample cartridge from each bank and testing in accordance with the guidelines of Table 3 of Regulatory Guide 1.52, Revision 1 (June 1976). The sample will be at least two inches in diameter and a length equal to the thickness of the bed. If the iJdine removal efficiency test results are unacceptable, all adsorbent in the system will be replaced. High efficiency particulate filters are installed before and after the charcoal filters to prevent clogging of the carbon adsorbers and to minimize potential entrance of particulates that may be released to the environment following an accident. This will be demonstrated by in-place testing alth DOP as the testing medium. Any HEPA filters found detective will be replaced with filters qualifted to regulatory guide position C.3.d of Regulatory Guide 1.52, Revision

-1 (June 1976). Once per operating cycle demonstratten of HEPA filter pressure drop and operability of inlet heaters at rated power is necessary to assure system performance capability.

1302H/0414Z 3.8/4.8-19 Amendment No.

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• ATTAC W WT 2

SUMMARY

OF CHANGES ,

A total of thirty-two (32) changes to'the Quad Cities Station Units 1 i-Cnd 2 Technical Specifications have been identified-(16 per unit)-and are ilisted below as follows:

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1) Page 3.8/4.8-14a. DPR-29 and'30 (a) Limiting condition for Operation (LCO), 3.8.H.1 - Delete the word "and" and replace with the word "or", so that 3.8.H.1 now' reads, "except as specified in Sections 3.8.H.1.a or b.

This change merely replaces the word "and" with "or" and is considered to be administrative.

~(b) LCO, 3.8.H.1.b. - Delete "or post maintenance" and replace with "of surveillance", so the sentence now reads, "does not apply during performance of surveillance testing, or during...".

Changes 1(b) clarifies the testing requirement and corrects a The word "post-maintenance" has typographical error ("or" to "of").

been changed to "surveillance".

This change is administrative.in nature.

(c) LCO, 3.8.H.2.a. - Add the statement, "per bank when tested with 0.3 micron DOP aerosol.", so the sentence now reads, "the results of the in-place DOP tests...with 0.3 micron DOP aerosol."

This change clarifies the testing results. ,

(d) LCO, 3.8.H.2.b.-Deletethephrase,"charcoalbanksshallshowfl% h

. penetration." and replace with "overally charccal banks shall s ow less than or equal to 0.5 penetration." Change 1(d) clarifies the tgsting requirements and reduces the allowable penetration percent to

"-0,5" to "fl.0". '

(e) LCo,3.8.H.2.c.-Deletethewords"shallshowE90%methyliodide and replace removal efficiency when tested at 130'c and 95% R.H."

with "of both carbon canisters shall show less than or equal to 0.5%

methyl iodide penetration (overall) when tested at 30'C and 70' R.H.", so the sentence now reads, "The results of laboratory carbon sample analysis of both...at 30'C and 70% R.H."

1 Item 1(e) reduces the % allowable penetration to "{0,5" from 10 (290%

removal efficiency). Testing parameters have also been changed to "30'C and 70% R.H." from "130*C and 95% R.H.".

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'(f) Surveillance Requirements, (S.R.), 4.8.H.2.a. - Replace the word "absctbers" which exists-in the current Technical Specifications,

~with the word "adsorbers", so the sentence now reads, "At least once '

per operating cycle...or charcoal adsorbers...". t This change is-administrative os it corrects a typographical error.

(g) S.R. 4.8.H.2.a.(2) - Replace the word "absorber" with the word "adsorber" (same change as that identified in Item If)), so the sentence.now reads, "In-place test the charcoal adsorber...".

This change is administrative as it corrects a typographical error..

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2) Page 3.8/4.8-14b, DPR-29 and 30 (a) LCO 3.8.H.3.a. - Replace the word "heating" with the word "testing",.

so the sentence now reads, "After any maintenance or testing...".

This change correct.s a typographical error replacing "heating" with the word "testing" and is administrative.

(b) LCO 3.8.H.3.a. (con't) - Replace "<61% penetration." with "less than or equal to 1.0% DOP penetration per bank in accordance with 3.8.H.2.a.", so the specification now reads, "After any maintenance or testing...less than or equal to...with 3.8.H.2.a.".

Item 2(D) changes the 4 penetration allowed from "fl.0" to ".60.5".

(c) LCO 3.8.H.3.b. - Replace the word "absorber" with the word "adsorber", so the sentence now reads, "After any maintenance or testing...adsorber...".

This change is administrative in nature and corrects a typographical error (adsorber instead of absorber).

(d) Lco3.8.H.3.b-Replace"fl% penetration"with"lessthanorequalto 0.5% overall penetration in accordance with 3.8.H.2.b.", so the specification now reads, "After maintenance or testing...less than or equal to 0.5%...with 3.8.H.2.b."

This change reduces the % penetration allowed to 'A(0.5" from "$1.0".

(e) S.R. 4.8.H.2.a(3) - Delete "the charcoal absorber", and replace with "each charcoal adsorber bank.", so the sentence now reads "Remove one carbon test canister from each charcoal adsorber bank."

Change 2(e) clarifies the test requirements and corrects a typographical error (absorber vs. adsorber).

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(f) S.R. 4.8.H.3.b. - Replace "absorber" with the word "adsorber", so the sentence now reads, "After any maintenance...of the charcoal adsorber banks,...".

This change corrects a typographical error (absorber vs. adsorber).

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3) Page 3.8/4.8-19, DPR-29 and 30 t (a) Bases Page, Item 3.8/4.8.E., SOLID RADIOACTIVE WASTE - The location

! for 3.8/4.8.B. has been interchanged with the location for 3.8/4.8.P.

to put it in alphabetical order with the preceeding item. The contents of Item 3.8/4.8.E. have not been changed, only the location has.

This change is administrative in nature.

l (b) Bases Page, Item 3.8/4.8.F., MISCBLLANEOUS RADIOACTIVE MATERIALS SOURCES - The location for 3.8/4.8.F. have not been changed; only the location has.

This change is administrative in nature.

(c) Bases Page, Item 3.8/4.8.H., CONTROL ROOM AIR FILTRATION - Add new paragraph following the first paragraph of this section which reads I as follows, "The frequency of tests and sample analysis is necessary...to assure system performance capabilig ."

This section has been added to reference applicable testing  ;

I requirements and standards and is administrative in nature.

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ATTACHM8NT 3 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF PROPOSED AMENDMENT REOUSST Overall, there are three (3) types of changes associatedThe withfirst this the first two of which are related. l proposed license amendment, type of change results from increasing the filter ef adsorbers in the control Room HVAC Air Filter Unit (AFU) to a moreThe increased conservative value that was previously approved by the NRC. filte The second change pertains to clarification of testing dose limitations.

requirenents for the AFU's in the Surveillance portion of the Tech Specifications.

Technice.1 Specifications.

Lastly, changes to the Technical Specifications These changesare included which correct grammatical and typographical errors.

are considered to be administrative in nature.

Quad Cities Station License Event Report (LER)87-025, Revision 1, 1968 was issued by the Station after it was for DPR-29, dated April 15r determined that there was a conflict between a design basis assumption used in the Control Room Habitability Study and the existing Quad Cities Statio Technical Specifications.

methyl iodide removal efficiencies for both the Standby TheGas studyTreatment performed System and ccntrol Room Ventilation Air Filtration Unit (APU).

for Control Room Habitability assumed 99% overall decontamination e for these trains. Therefore, the Study was more conservative than the values in the current Technical Specification.

A review of records and additional analysis has shown that the maximum thyroid dose allowed for control Room personnel would not have been exceeded for any time in question.

25, 1987, the Station has Since this was identified on November administrative 1y assured that the proper efficiencies are currentl maintained.

to ensure that the values assumed in the Control Roan Habitability design, dure.are maincained during plant operation, rather than via on adminictrative proce BASIS FOR NO SIGNIFICANT HAZARLC CONSIDERATIQ Commonwealth Edison has evaluated this proposed amendment In and determined that it involves no significant hazards consideration.

accordance with the criteria of 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:

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1) ' Involve a significant increase in the probability or consequences of an

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accident previously evaluated because:

(a): In general, increasing the filter efficiencies.actually mitigates the consequences of an accident en control room personnel by lowering the thyroid dose received by personnel during an accident. In this case, the change-assures that thyroid dose limits will be met at.all times a.1 defined in the control Room Habitability report and as required by General Design Criteria (GDC) 19. By using these efficiency values (which were utilized in the Control Room Hability report), the probability or.conseousnces remain unchanged.

Therefore, these changes do not significantly increase the probability increase the probability or consequences of previously evaluated accidents.

(b) The other changes to the Technical Specifications (which include correction of typographical and grammatical errors) are administrative in nature and do not affect the probability or consequences of previously evaluated accidents.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated because:

(a) This change does not result in a direct change to the design or operation of the Control Room Air Filter Units, but rather ostablishes a higher efficiency value for their operation. The use of a higher efficiency value for the AFU's does not create the possibility of a new or different kind of accident from previously evaluated accidents.

(b) The other types of ch nges noted in the proposed amendment are-administrative in natare.

3) Involve a significant reduction in the margin of safety because:

(a) The thyroid doses will be lower than what was previously allowed with a 90 percent filter efficiency. The use of this AFU efficiency value ensures that the Control Room Habitability design is met, which in turn ensures that operator thyroid dose limits will not exceed GDC-19 limits. Additicaally, there are no changes being made to plant systems, hardware or in the manner that the systems are being operated. Therefore, the margin of safety as established in the Detailed Control Room Habitability report is maintained and not decreased as a result of this proposed change.

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(b) .The'second-class of changes are corrections of typographical errors, and therefore do not affect the margin of safety as they.are administrative.-

Therefore, since the proposed license amendment satisfies the criteria specified in 10 CPR 50.92, commonwealth Edison hasVe determined that a no further. request signi-their ficant hazards consideration exist for these items.

tpproval in accordance with the provisions of 10 CFR 50.91(a)(4),

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