ML20151L785

Proposed Tech Specs,Changing Requirements Re Emergency Power for Control Room Ventilation Sys

ML20151L785
Person / Time
Site:	Catawba
Issue date:	07/26/1988
From:	DUKE POWER CO.
To:
Shared Package
ML20151L782	List: ML20151L778 ML20151L785
References
NUDOCS 8808040135
Download: ML20151L785 (10)

Text

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Attachment 1 Proposed Technical Specification Changes 1

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l 8808040135 880726 PDR ADOCK 05000413 P PDC

PLANT SYSTEMS 3/4.7.6 CONTROL ROOM AREA VENTILATION SYS 4 [

t LIMITING CONDITION FOR OPERATION frNo.r / N 3.7 wo independent oatrol Room Area Ventilation System)( shall be OPE Ey ud cap 6ts of %;a3 peaued by an opggggig ,m,j,, p,, 3,u,ee APPLICABILITY: -Jef MODES t,2,3 W 4 ACTION: (Units 1 and 2)

,, ., ,,a n or mk ca h d heg powerM h m

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'yg gg otG%6tA e mteseauf Poutc sowee-With onelControl Room Area Ventilation System inoperabl)e restore the inoperable cy:t to OPERABLE status within 7 days or be in at least HOT STANDBY within g;he t next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLO SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. g4 ,

C;; E := ' -

a. th one Co trol Room ea Ventil ion System 1 operable, r tore th inoperab system to PERABLE s atus within day:. or int fate and aintain eration of he remain'ng OPERABLE ntrol Mom ea Venti tion Sys m with flo through e HEPA filt s and act.iv ed g carbon dsorbors. /

W1 h both ntrol Re m Area Vent'lation 5 tems inoper le, or with om Area Ve ilation stem, requ ed to be s

the PERABL ontrol opera ing by A TION a., ot capable f.being wered by a OPERABLE emerge y power urce, s end all o rations

• volving C E TERATI 5 or pos'tive rea ivity chan s.

c. The ovisio of Spe 'fication .0.4 are n applic le.

N N SURVEILLANCE RE0!JIREttEMS y & 4h-4.7.6. achsContro com Area Ventilation System shall be demonstrated OP

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 90'F;

b. At least once per 31 days on a STAGGERED TE S by initiating, from the control room, flow through the A filter 'and activated carbon adsorbers and verifying that th sye+e- perates for at least (

10 continuous hours with the heaters o erating; g CATAWBA - UNITS 1 & 2 3/4 7-14 Amendment No. (Unit 1)

"y Amendment No. (Unit 2)

l PLANT SYSTEMS.

l SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or activated r

bon adsorber housings, or chem al release in any ventilation pI ,

(2) following painting, fire zone communicating with t Oy:tWby:

tred n

1) Verifying that the c anup system s sfies the in place penetration and bypass eakage testing acceptance criteria of less than 1% (Unit 1), 0.05% (Unit 2) and uses the test pro-cedure guidance in Regulatory Position C.5.a. C.S.c, and C.S.d*

of Regulatory Guide 1.52, Revisions 2, March 1978, and the system flow rate is 6000 cfm t 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative activated 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, Marcb 1978'for a methyl iodide penetration of less than 1%; and f

3) Verifying [asydem4 flow r te of 6000 cfm + 10% during system operation W en te n accordance with XNSI N510-1980.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of activated carbon adsorber operation, by c7 verifying, within 31 days after removal, that a laboratory analysis of a representative activated 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 Posi-tion C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1%;

e. At least once per 18 months by:

1) Verifying that the pretsure drop across the enmhinad HEPA ilters, activated carbon adsorber banks ,o n re separators is less than 8 inches Wa e-Gauge 'i iL flow rate of 6000 m + 10%; g )

ersting the-tytt r at

2) Verifying that on a(High Raditi -Air take,orSmokeDensi)ted -

High test sign , thh ;p t s automa ' y isolates the_.affac I I

intake from outs 1 _ir 'ith-recirculating flow through the HEPA filters and activat ,

adsorber banks; 7

3) Verifying that hehj mai tains the control room at a posi-tive pressure of _atar t or equal to 1/8 inch Water Gauge relative to adjacent areas at less than or equal to pressuriza-tion flow of 4000 cfm to the control room during :ystem operation;

4) Verifying that the heaters dissipate 25 1 2.5 kW, and

• The requirement for reducji g16frige ant concentration to 0.01 ppm may be satisfied by operating tfe g y t r fo 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with heaters on and operating, trcLin CATAWBA - UNITS 1 & 2 /4 7-15 Amendment No. (Unit 1)

Amendment No. (Unit 2)

PLANT SYSTEMS _

SURVEILLANCE REQUIREMENTS (Continued) 5 g that on a High Chlorine / Toxic Gas test signal, the o - '- utomatically isolates the affected intake from outside

. g r with recirculating flow through the HEPA filters and acti- 7 vated carbon adsorbers banks within 10 seconds (plus air travel /

time between the detectors and the isolation dampers).

f. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% (Unit 1),

0.05% (Unit 2) in accordan~ with ANSI N510-1980 for a 00P test aero-sol while operating the,eyotee a a flow rate of 6000 cfm t 10%; and After each complete \or ar p#tz.in eplacement of an activated carbon g.

adsorber bank, by verifying that the cleanup system satisfies the

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in place penetration and bypass leakage testing acceptance criteria of less than 1% (Unit 1), 0.05% (Unit 2) in. accordance with ANSI N510-1980 f gggenatedhydrocarbonrefrigeranttestgaswhile operatin he q :t..., at a flow rate of 6000 cfm i 10%.

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CATAWBA - UNITS 1 & 2 3/4 7-16 Amendment No.)f (Unit 1)

Amendment No. g (Unit 2)

PLANT SYSTEMS

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[ _' - ONTROL ROOM AREA VENTILATION SYSTEM - S#kTDowN LIMIT NG CONDITION FOR OPERATION ha;c of k OPER(AUL3.7.13o one o$ ghdindependent gh4ll be, eggble [ Control

,h hin3Roompoggfgj Areal,j on Ventilation ggAfff{ System APPLICABILITY: #et. MODES S a,J 6 8 M* Q*^'y P *"" S * #'#

• ACTION: (Units 1 and 2)

IOZ: 1, 2, 2 =d 4:

it o e C ntr 1 om ea\ Vent'lat n Sy em oper ble, rest e e i p a le st t OP ABh{ st tus ithi 7d s or be i at as li ST 40 th t n t ho sa in COLO HUT WH w thin the 11 wi in kgu N s s -

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a. Withone[ControlRoombeaVentilationSysteminoperable, restore the inoperable syst m to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Area Ventilation Sy t=3with flow through the HEPA filters and activated y carbon adsorbers. kam n frains

b. With botA. Control Room Area Ventilation c"str:[ inoperable,orwith the OPERABLE Control Room Area Ventilati Sp 4em, required to be ,

operating by ACTION a., not capable of.being powered by an OPERABLE  !

emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

c. The provisions of Specification 3.0.4 are not applicable.

1 SURVEILLANCE REQUIREMENTS _

fgin t/r M 4.7. ch ontrol Room Area Ventilation System shall be demonstrated OPER E( , g g e4c. ,( swye;j[gn, g,fy,7u,y/ y, g 4, /,

a lea onc er 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> y ver fying (hat t e con rol room ai temp ratur is le s than or eq al to KO'F;

b. le t on per 1 da on a AGG EO TE BASI by i itiat g, fr th cent I too fl throu th HEPA lters nd tivat y{

carb n a rbe and rif 'ng that he stem erate for t lea

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co tinuo s ho s with the aters era ng; s s s y ,

lh CA'AWBA - UNITS 1 & 2 3/47-X Amendment No. )( (Unit 1)

Amendment No. pf (Unit E)

I PLANT SYSTEMS -

,/ BASES 3/4.7.3 COMPONENT COOLING WATER SYSTEM The OPERABILITY of the Component Cooling Water System ensures that suf-ficient cooling capacity is available for continuedThe operation ofcooling redundant safety related equipment during normal and accident conditions.

capacity of this system, assuming a single failure, is consistent witn the assumptions used in the safety analyses.

3/4.7.4 NUCtEAR SERVICE WATER SYSTEM The OPERABILITY of the Nuclear Service Water System ensures that sufficient cooling capacity is available for continued operation of safety-related The redundant equip-cooling capacity of ment during normal and accident conditions.

this system, assuming a single f ailure, is consistent with the assumptions used in the safety analysis.

3/4. 7. 5 STANOBY NUCLEAR SERVICE WATER POND The limitations on the standby nuclear sarvice water pond level and temperature ensure that sufficient cooling capacity is available to either:

- (1) provide normal cooldown of the facility, or (2) mitigate the effects of accident conditions within acceptable limits.

The limitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to safety-related equipment without ,

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

March 1974.

3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM The OPERABILITY of the Control Room Area 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

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o system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions. Operation of the system with the heaters operating to maintain low humidity using automatic control for at least 10 continuous hours in a 31-day period is sufficient to p reduce the buildup of moisture on the adsorbers and HEPA filters. The q OPEP. ABILITY of this system in conjunction with control room design provisions y is based on limiting the radiation exposure to personnel occupying the control q

q room to 5 rems or less whole body, or its equivalent. This limitation is con-y sistent with the requirements of General Design Criterion 19 of Appendix A, will be used as a procedural guide for surveil-P 10 CFR Part 50. ANSI N510-1980

, i lance testing.

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CATAWBA - UNITS 1 AND 2 B 3/4 7-3

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INSERT FOR PAGE B 3/4 7-3  !

Each train of the Control Room Ventilation (VC) System can be aligned to either a Unit 1 or a Unit 2 emergency diesel generator. If a diesel generator that is being used as the applicable emergency power source becomes inoperable, the affected VC System train (if requiring an OPERABLE emergency pc4er source for OPERABILITY) may either be d'sclared inoperable and the appropriate ACTION Statement complied with, or it may be aligned to an OPERABLE emergency power source.

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Attachment 2 Discussion and No Significant Hazards Analysis l

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o DISCUSSION AND NO SIGNIFICANT HAZARDS ANALYSIS The Control Room Area Ventilation (VC) and Chilled Water (YC) Systems combine to form one system which is designed to maintain a suitable environment in the following plant areas at all times: Control Room, Cable Room, Battery Room, Switchgear Rooms. Motor Control Center Rooms, and the Electrical Penetration Rooms at elevation 594+0. The VC/YC System is shared between both Units. There are two 1007. redundant trains of VC/YC equipment. Each is capable of being powered by Unit 1 or Unit 2 Essential Auxiliary Power, but under normal conditions both trains are aligned to Unit 1. Two diesel generators (D/Gs) are provided per Unit to enetgize the Essential Auxiliary Power buses during emergency conditions.

Technical Specification 3.7.6 specifies that two independent trains of VC/YC shall be OPERABLE during all operational modes. If one train becomes Inoperable while either Unit is in Mode 4. Hot Shutdown, or above, the Inoperable train must be restored to OPERABLE etatus within seven days, or the operating Units must be shutdown. If both Units are below Mode 4 and one train is Inoperable, the train must be restored to OPERABLE status within seven days or the OPERABLE train must be operated in the filter mode. If both trains are Inoperable, or with the OPERABLE train not capable of being powereu by an OPERABLE emergency power source, all core alterations and positiva reactivity changes must be suspended on both Units. The requirement for an OPERABLE emergency power source is only specifically stated for Units operating below Mode 4. However, the bases for Technical Specification 3.7.6 states that the operability of VC/YC ensures that ambient air temperature does not exceed allowable lir.its for equipment and instrumentation, and the Control Room will remain habitable, during and following all credible accident conditions. This implies that an OPERABLE emergency power supply should be a prerequisite to VC/YC operability in all modes.

Technical Specification 3.8.1.1 specifies for each individual Unit that two separate and independent D/Gs are required to be OPERABLE per Unit, if the Unit is in Mode 4, or above. Below Mode 4 Technical Specification 3.8.1.2 applies and only one D/G is required OPERABLE per Unit. Action Statement c. for Technical Specification 3.8.1.1 specifies that when one D/G becomes Inoperable, all required systems (or trains) that depend on the remaining OPERABLE D/G as a source of emergency power, must be verified OPERABLE within two hours, or the l' nit must be shutdown. This is intended to provide assurance that a loss of '

offsite power event, while one D/G is Inoperable, will not result in a complete loss of safety function of critical systems. It is also the reason Technical Specification 3.7.6 does not specifically require that VC/YC have an OPERABLE emergency power so rce in Mode 4, or above. This action statement is deficient with respect to VC/YC because VC/YC is a Unit shared system, and Technical Specification 3.8.1.1 applies only to individual Units. In order for VC/YC operability to be protected by this Action Statement, the D/G must become Inoperable while the Unit is in Mode 4 or above. There is no such Action Statement in Technical Specification 3.8.1.2 since only one D/G is required OPERABLE, and the Unit is already sht.tdown.

1 This amendment request would remove the ambiguity as to the emergency power l source requirements for the VC System by stating the requirements in the VC System Technical Specification. l

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9 DISCUSSION AND NO SIGNIFICANT RAZARDS ANALYSIS (Continued)

To clarify the requirements the Specification is to be split into two separate Specifications. The first Specification (Technical Specification 3.7.6.1) would state the requirements for the VC System when either unit is in Modes 1, 2, 3 or

4. This Specification will now specifically ree.cire that each train of the VC System be capable of being powered by an OPERAEL2 emergency power source whenever >

either unit is in Mode 1, 2, 3 or 4. This wi!.1 alleviate the confusion which is currently contained in the Specification as to the emergency power source requirements when one unit is in Modes 1, 2, 3 or 4 and the other unit is in Modes S or 6.

Technical Specification 3.7.6.2 is being proposed to clearly state the VC System requirements when both units are in Modes 5 or 6. i The proposed changes to the VC System Specification will also specify that the requirements are to be performed on a per train basis. The VC System is comprised of two independent and redundant trains. The current wording is that which appears in the Standard Technical Specification and should be changed to more clearly reflect what is in place at Catawba.

These proposed changes will add clarification to the requirements of the VC System Specification. The changes will not delete any current requirements or operating restrictions contained in the Specifications and will not allow the plant to be operated in any different mode or configuratien. As such, these changes are considered to be administrative in nature and do not involve any Significant Hazards Considerations, i

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment would nott (1) Involve a significant increase in the probability or consequencas of an accident previously evaluated; or (2) Create the possibility of a new or different kind of  ;

accident from any accident previously evaluated; er  !

(3) Involve a significant reduction in a margin of safety.

The proposed amendment does not involve an increase in the probability or consequences of any previoosly evaluated accident. The operating pcrameters and the design of the VC System are unchanged and no new modes of operation will be introduced by this amendment request. All previous accident analyses are still applicable and remain unchanged by this proposal.

The proposed amendment does not create the possibility of a new or different kind ,

of accident from any accident previously evaluated. The proposed changes will j not change the design or allowed modes of operation of the VC System. As such, '

no new failure modes are introduced and no new types of accidents are possible.

The proposed amendment does not involve a significant reduction in a margin of l safety. These changes will add clarification to the existing Specification j without changing any of the current requirements.

For the above reasons, Duke Power concludes that this proposed amendment does not

involve any Significant Hazards Considerations.

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