ML20198P709

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Proposed Tech Specs 3/4.7.2 & 3/4.3.5.5 Revising Design Basis Qualification Requirements for CREVS & CREVS Instrumentation
ML20198P709
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 11/06/1997
From:
CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20198P704 List:
References
NUDOCS 9711100087
Download: ML20198P709 (38)
v • d • e


Text

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l ENCLOSURE $

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50 325 AND 50424 LICENSE NOS. DPR 71 AND DPR 62 REQUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM TYPED TECHNICAL SPECIFICATION PAGES - UNIT 1 1

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, INSTRUMENTAT10B CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION

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3.3.5.5 The Control Room Emergency ventilation System instrumentation shown in Table 3.3.5.5 1 shall be OPERABLE.* I APPLICABillTY: As shown in Table 3.3.5.5 1.

ACTION:

a. With one or more detectors inoperable, take the ACTION required by Table 3.3.5.5-1.
b. The provisions of Specification 3.0.4 are=not applicable.

SURVEILLANCE REQUIREMENTS

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4.3.5.5 Each of the above required control room emergency ventilation instruments shall be demonstrated OPERABLE by performance of the testing at the frequency required by Table 4.3.5,5-1.

The Control Room Emergency Ventilation System (CREVS) instrumentation may be considered OPERABLE. consistent with the conditions specified in footnote *** to Technical Specification 3.7.2. during the time period from January 30. 1998, to May 1, 1998, in this ~ configuration, the system is not considered to be in an ACTION statement for the purposes-of Technical Specification 3.0.4.

BRUNSWICK UNIT 1 3/4 3-64. Amendment No. I i

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, PLANT SYSTEMS 3/4 7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION

...____._.,_____.m.___mm_,.,

3c7.2 The Control Room Emergency Ventilation System shall be OPERABLE *** with: I

a. An OPERABLE Radiation / Smoke Protection Mode consisting of two OPERABLE control roi.m emergency filtration subsystems.
b. An OPERABLE Chlorine Protection Mode.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2. 3, 4. 5. *. and **

ACTION: >

a. in GPERATIONAL CONDITIONS 1 and 2:
1. With one control room emergency filtration unit inoperable, restore the ino)erable control room emergency filtration '

unit to OPERABLE status within 7 days or be in at least H0T SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTOOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, i

2. With both control room emergency. filtration units ino)erable, be in at least Il0T SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and ,

in.:0LD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. In OPERATIONAL CONDITION 3:
1. With one control room emergency filtration unit inoperable, restore the ino)erable control room emergency filtration unit to OPERABLE status within 7 days or be in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2. With both control room emergency filtration units ino)erable, be in-COLD SHUTDOWN within the following i 24 lours.
  • - During movement of irradiated fuel assemblies in the secondary ,

containment.

    • The Chlorine Protection Mode is required to be OPERABLE at all times when the chlorine tank car 1s within the exclusion area, The Control Room Emergency Ventilation System (CREVS) ductwork'may be-considered OPERABLE. for one or more periods totaling up to 16 days, using temporary ductwork barriers constructed to preserve the leakage i characteristics of the control room pressure boundary under normal l operational conditions, during the implementation of the Control Room Air Conditioning System replacement modification. The chlorine tank car shall be removed from the exclusion area while temporary ductwork barriers are being used. The CREVS may also be considered OPERABLE up to 9 weeks with temporary condensing units and associated piping and controls installed. Two of these units shall be functional during normal operational conditions. This is applicable during the time period from January 10.-1998, to May 1. 1998. In this configuration, the system is not ^onsidered to be in an ACTION statement for the purposes of Technical Specification 3.0.4.

BRUNSWICK - UNIT 1 3/4 7-3 Ameno- ' No.- l

, SLSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTil ATION SYSTEM l-L1HITING CONDITION FOR OPERATION (Continued)

ACTION (Continued):

c. In OPERATIONAL CONDITIONS 4. 5. and *:

l 1. With one control room emergency filtration unit inoperable, restore the ino)erable control room emergency filtration unit to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control building emercency filtration unit in the Radiation / Smoke Protection Mole.

2. With both control room emergency filtration units ino)erable, suspend all operations involvir.g CORE n ALT ERAT 10NS. handling of irradiated fuel in secondary C containment, and operations with a potential for draining the reactor vessel
a. With the Chlorine Protection Mode inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> remove the chlorine tank car from the exclusion area. If the tank car physically can not be removed from the exclusion area, take the ACTIONS required in items a.2. b.2. and c.2 above.

SURVElLLANCE REQUIREMENTS

=

4.7.2 The control room emergency ventilation system shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow, from the control room. through the HEPA filter and charcoal adsorbers in each filtration unit and verifying that the system operates for at leasc 15 minutes.
b. At least once per 18 months or (1) after any structual maintenance on the HEPA filter or charcoal adsort>er housing, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:
1. Verifying that the cleanup system satisfies the in-place testing acceptance criteria of > 99 percent efficiency using the test procedures of Regulatory Positions C.5.a. C.5.c.

and C.S.d of Regulatory Guide 1.52. Revision 1. July 1976, and the system flow rate is 2000 cfm 10%.

BRUNSWICK - UNIT 1 3/4 7-3a Amendment No. I

4

, E618WENTATLON BASES 3/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYST W (Continued)

Backarouad (Continued) the Service Water Building, or a slow leak lasting for an extended period of time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

Dur< ng a radiation event, the CBHVAC System is recuired to automatically iso' ate and enter the Radiation / Smoke Protection Fode on a Control Room Intake High Radiation signal from the Area Radiation Monitoring System. Upon receipt of a high radiation signal, the CBHVAC System is automatically realigned to the emergency mode of operation. The normal fresh air inlet closes, and. at approximately the same time, the emergency air filtration units begin operation, recirculating control room air and providing filtered makeup air to minimize contamination build up and provide positive pressure in the Control Room Envelope. The CBHVAC System responds to an external smoke event in the same manner as it does for a radiation event, in the event of a chlorine release, the CBHVAC System enters a full recirculation mode (Chlorine Protection Mode), with no outdoor air intake The emergency filtration trains do not start, since they do not effectively remove chlorine and may be damaged by the presence of chlorine. Protection for chlorine Cas events "overrices" any concurrent ongoing, and any subsequent raciation or smoke initiation signals. ,The override design offers protection to operations personnel in the Control Room by providing protection against potentially fatal chlorine gas releases. This protection is required any time the chlorine tank car is within the exclusion area.

The CREVS is designed to meet the criteria of General Design Criterion (GDC) 19 (Reference 1). In addition, the system is designed using the guidance of Regulatory Guide 1.95, Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE chlorine detection and isolation logic to single failure criteria, bot 279-1971,h withand the approved exceptions (Reference 6, Section 3.6),

ACTION Statements 90. 91 and 92 require isolating the control room and the CREVS in either the Chlorine Protection Mode or the operating Radiation / Smoke Protection Mode, as appropriate. These ACTIONS presume that the CREVS is OPERABLE, During implementation of the Control Room Air Conditioning System replacement modification the CREVS instrumentation may be considered OPERABLE. with a temocrary barrier installed in the duct, or during use of temporary condensing units for the Control Room Air Conditioning System, as described in Ba ws 3/4.7.2.

LCD

' Operability of the CREVS instrumentation ensures that the control r'oom operators will be protected from hazards external to the control room, consistent with the assumptions in the various analyses, through the prompt detection and initiation of the necessary protective actions of the system.

BRUNSWICK - UNIT 1 B 3/4 3-3a Amendment No. I

INSTRUMENTATION l BASES

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2L4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Annlicability The instrumentation associated with the Radiation / Smoke Protection Mode of the CREVS is required to be operable to automatically detect and initiate the Radiation / Smoke Protection Mode of operation during times when the potential exists for events which may result in the release of radioactive materials to the environment up to and including design basis accidents. The specific radiological release events for which the system must provide a mitigating function are discussed in the bases of Technical Specification 3.7.2 and DBD 37 (Reference 6)

The instrumentation associated with the Chlorine Protection Mode of the CREVS is required to be OPERABLE to automatically detect and initiate the internal recirculation mode of operation any time the chlorine tank car is within the exclusion area.

The instrumentation associated with the External Smoke Protection function of the CREVS is required to be OPERABLE to automatically detect and initiate the Radiation / Smoke Protection Mode of operation during the same conditions as the Radiation Protection function. This ensures that habitability of the control room is maintained during times when a radiological release could potentially occur.

Actions Radiation Protection Two control room air inlet radiation detectors measure radiation levels in the inlet ducting of the main control room. A high radiation level automatically initiates the radiation protection mode of operation. Both channels are required to be OPERABLE to ensure that no single instrument failure can preclude the initiation of the radiation protection function of the control room emergency ventilation system. The loss of a single detector means that the CREVS teliability is reduced because a single failure in the OPERABLE subsystem could result in reduced or lost system capability. The 7 day out of service time is based on the low 3robability of a design basis accident and a single failure occurring during t1is time period, and the capability of the remaining instrumentation subsystem to provide the reguired isolation and is consistent with the out of-service times allowed for loss of redundancy at the system level.

-The loss of both detectors means that the automatic detection / isolation function of the radiation protection system is lost. Placing the CBHVAC System in the Radiation / Smoke Protection Mode is a suitable compensatory action to ensure that the automatic radiation protection function is not lost.

Chlorine Protection The chlorine detection / isolation instrumentation is organized into two trip systems, with one trip system (remote) located near the chlorine tank car and the other located in the control building intake plenum (local). Each trip system contains two trip subsystems, with two detectors (one from each BRUNSWICK - UNIT 1 B 3/4 3 3b Amendment No. l

, INSTRUMENTATION BASES 3/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Actions (Continued) division) in each tri a subsystem. Both trip subsystems in each trip system are required to be OPERABLE any time the chlorine tank car is within the exclusion area to ensu,e adequate protection for the control room under postulated toxic gas events.

The chlorine detectors in each trip system are arranged in a one out of-two-taken-twice configuration. One detector from each of the tri trip system must actuate to initiate the automatic detection /p isolation subsystems in a function. The loss of a single chlorine detector means that the CBEVS reliability is reduced because a single failure in the remaining OPERABLE trip subsystem detector could result in reduced or lost system capability. The 7 day out of service time is based on the low probability of a design basis chlorine gas event and a single active failure occurring during this time period, and the capability of the remaining detectors to provide the required isolation capabilities. The out of service time is consistent with the out of service time allowed for loss of redundancy at the system level.

The loss of both detectors in any trip subsystem means that the automatic arotection function of the chlorine detection / isolation system is lost.

31 acing the CBHVAC System in the Chlorine Protection Mode, through the use of control switches to close the appropriate dampers, ensures todt the control room envelope is protected, while at the same time allowing a valid radiation or smoke signal to initiate appropriate protective actions. Operation in this mode is not limited in duration provided that either trip system remains t

functional to ensure that the override function of the Chlorine Protection 1

Mode is not lost.

Smoke Protection Automatic detection / isolation of the control room envelope in response to an external smoke event is dependent on the response of ionization detectors in Zones 4 and 5 of the Control Building. Multiple detectors in each of the zones provide the detection / isolation capabilit :

detectorinbothzonesisrequiredtoinitiate{heisolationfunctionhowever detection by one Havinc less than two detectors OPERABLE in a zone means the system reliability is recuced due to the loss of redundant detection capability in that zone.

Allowine continued operation for up to 7 days with less than two OPERABLE detectors in either or both zones is an acceptable out of service time considering the low probability of an external smoke event and the failure of

.the remaining detector during this time period, and the capability of the remaining instrumentation to provide the required isolation. The out of service time is consistent with the out of service times allowed for loss of redundancy at the system level.

With less than one detector OPERABLE in either or both zones the automatic detection / isolation function of the external smoke protection system is lost.

Placing the CBHVAC System in the Radiation / Smoke Protection Mode is a suitable compensatory action to ensure that the automatic external smoke protection function is not lost.

BRUNSWICK - UNIT 1 B 3/4 3-3c Amendment No. I

INSTRUMENTATION l BASES 3/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Surveillances Radiation Protection Performance of the CHANNEL CHECK once every day ensures that a "oss failure  ;

of the instrumentation has not occurred: thus. it is key to ver fying the instrumentation continues to o)erate properly between each CHANNEL CAllBRAT10N. The CHANNEL CHECC frequency is consistent with that performed for other radiation monitors with isolation functions.

The CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will perform the intended function. The Control Building HVAC DBD (Reference 6) defines the specific actions to be satisfied by the radiation actuation instrumentation. The guarterly frequency of the '

CHANNEL FUNCTIONAL TEST was established based on Reference 7 and is Consistent with that performed for other radiation monitors with isolation functions.

The CHANNEL CALIBRATION verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRA110N leaves the channel adjusted to ensure consistency with the system assumptions (Reference 5). The frequency of the calibration is consistent with the frequency of calibration of other radiation monitors with isolation functions.

Chlorine Protectica The CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will aerform the intended function. The Control Building HVAC DBD (Reference 5) defines the s)ec1fic actions to be satisfied by the chlorine isolation instrumentation. 11e monthly frequency of the CHANNEL FUNCTIONAL TEST is consistent with the testing frequencies performed by other utilities with this type of instrumentation.

The CHANNEL CAllBRATION of the trip units provides a check of the instrument loop and the sensor when the sensor is replaced. The test verifies the 4 calibration of the existing sensor prior to removal and performs an <

i installation calibration of the new sensor, including a complete channel calibration with the new sensor installed, to verify the channel responds to the measured parameter within the necessary range and accuracy. The CHANNEL CALIBRATION leaves the channel adjusted to ensure consistency with the system

assumptions (Reference 6).

1 The chlorine detectors use an am)erometric sensor consistinc of a platinum cathode and silver anode joined )y an electrolytic salt briige, all enclosed in a permeable membrane. This design eliminates the majority of the maintenance required on previous detectors. The detectors have been in service at oti " facilities and have provided reliable service. The annual replacement 6 :libration are based on a manufacturer recommendation. The adequacy of th; elacement interval has been confirmed through discussions

. with other util m es.

Smoke Protection The CHANNEL FUNCTIONAL TEST for the Smoke Protection instrumentation is consistent with the testing performed in accordance with the existing Fire Detection Instrumentation requirements. CHANNEL CALIBRATION is performed in accordance with the requirements of the CREVS specification (4.7.2).

BRUNSWICK - UNIT 1 B 3/4 3-3d Amendment No. l

O PLANT SYSTEMS-BASES 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM Backaround One of the principal design objectives of the Control Building Heating.

Ventilation and Air Conditioning (CBHVAC) System is to permit continuous occupancy of the Control Room Emergency Zone under normal operating conditions and under the postulated design bas 1s events throughout the life of the plant.

The Control Building HVAC System must function to provide protection to the operators for Accident e

three typ(e. events: a radiation event u) to and including a Design Basis g., Main Steam Line Break MS B] Accident. Refueling Accident, Control Rod Drop Accident, or loss of Coo ant Accident (LOCA]). a toxic-gas event (complete rupture of the 55 ton chlorine tank car located near the Service Water Building, or a slow leak lasting for an extended period of time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

The CREVS is designed to meet General Design Criterion (GDC) 19 (Reference 1),

in addition, the system ir designed using the guidance of Regulatory Guide-l.95. Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE 279-1971, and the chlorine detection and isolation logic to single f ailure criteria, both with approved exceptions (Reference 12. Section 3.6).

During implementation of the Control Room Air Conditioning System re)lacement modification, the CREVS may be considered OPERABLE with a temporary aarrier installed in the duct as part of the control room pressure boundary. The tem)orary ductwork barriers are required to be constructed to preserve the leatage characteristics of the control room pressure boundary however, these temporary barriers are not required to be seismically qualif'le;d. in addition.

adjacent ductwork may be considered OPERABLE 1f not seismically qualified while work is actively in progress.

Also, during the installation of the Control Room Air Conditioning System replacement modification, the temporary condensing units which su) port the operability of the Control Room HVAC System may be considered OPEMBLE as long as two of the three units are functional.-even though they are not protected

, from severe natural phenomena such as seismic events and tornadoes, or radioactive sabotage. Single failure criteria do not apply to the Control Room Air Conditioning System during this time.

LCD -

Operability of the CREVS ensures that the control room will remain habitable for operations personnel-during and following all credible hazard event scenarios external to the control room, consistent with the assumptions in the various analyses. Two redundant subsystems of the CREVS are required to be OPERABLE to ensure that at least one 1s available, assuming a single failure disables the other subsystem. The CREVS is considered OPERABLE when the -

individual components necessary to control operator exposure are operaole in.

both subsystems. For the Radiation / Smoke Protection Mode, a subsystem is considered OPERABLE when its associated:

1. Fan is OPERABLE.
2. HEPA filter and charcoal adsorbers are not excessively restrictinc

- flow and are c'dpable of performing their filtration functions and BRUNSWICK --UNIT 1 B 3/4 7-Ic- Amendment No. l

ENCLOSURE 6 HRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKETNOS.50 325 AND 50 324 LICENSE NOS. DPR 71 AND DPR 62 REQUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM TYPED TECilNICAL SPECIFICATION PAGES UNIT 2

INSTRUMENTATION CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION

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-3.3.5.5 The Control Room Emergency Ventilation System instrumentation shown in Table 3.3.5.5 1 shall be OPERABLE.* I ,

APPLICABILITY: As shown in Table 3.3.5.5-1.

ACTION:

, a. With one or more detectors inoperable, take the ACTION required by

Table 3.3.5.5-1.

1 4 b. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.5.5 Each of the above required control room emergency ventilation j

instruments shall be demonstrated OPERABLE by performance of the testing at the frequency required by Table 4.3.5.5 1.

d i

q.

4 a

i BRUNSWICK - UNIT 2 3/4 3-64 Amendment No. l L ,--

, ELA3L.515.T.f15 3/4.7.2 CONTROL R(QLDi[RGENCY VENTil ATION SYSTEM LIMITING CONDITION FOR OPERATION

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3.7.2 The Control Room Emergency Ventilation System shall be OPERABLE ***I with:

a.

An OPERABLE Radiation / Smoke Protection Mode consisting of two OPERABLE control rocm emergency filtration subsystems, b.

An 09ERABLE Chlorine Protection Mode.

APPLICABIL ITY: OPERATIONAL CONDIT10f15 1, 2, 3, 4, 5, *. and **

ACTION-a.

In OPERATIONAL C0tIDITIONS 1 and 2:

1.

With one control room emergency filtration unit inoperable, restore the ino3erable control room emergoncy filtration unit to OPERABL E status within 7 days or be in at least HOT SHUTDOWN within within24 the following thehours.

next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN

2. With bcth control room emergency filtration units 1loperable, he in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
b. In OPERATIONAL CONDITION 3:

1.

With one control room emergency filtration unit inoperable, restore the ino)erable control room emergency filtration unit to OPERABLE status within 7 days or be in COLD SHUT 00WN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2. With both control room emergency filtration units i

ino)erable , be in COLD SHUlDOWN within the following 24 aours During movement of irradiated fuel assemblies in the secondary containment.

The Chlorine Protection Mode is required to be OPERABLE at all times when the ulorine tank car is within the exclusion area.

The Control Room Emer considered OPERABLE, gency Ventilation System (CREVS) ductwork may be for one or more periods totaling up to 16 days.

characteristics of the control room pressure boundary under normalus oper6tional conditions, during the iitglementation of the Control Room

) Air Conditioning System replacement modification.

shall be are removed The chlorine ductworktank car barriers beingfrom the exclusion area while temporary used.

to 9 weeks controls with installed. temporary condensing units and associated piping and normal operational conditions.Two of these units shall be functional during period from January 30. 1998 to May 1. I MB.Thisisab-)plicableduringthetime the system is not considered to be in an ACTION statement for theIn this configuration.

purposes of Technical Specif1 cation 3.0.4.

BRUNSWICK - UNIT 2 3/4 7-3 Amendment No. I

O SYSTEMS 1/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTION (Continued):

c. In OPERATIONAL CONDITIONS 4. 5. and *:
1. With one control room emergency filtration unit inoperable, restore the ino)erable control room emergency filtration unit to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control -

building emergency filtration unit in the Radiation / Smoke Protection Mode.

' 2. With both control room emergency filtration units ino)erable, suspend all operations involving CORE ALTERATIONS. handling of irradiated fuel in secondary containment, and operations with a potential for draining the reactor vessel.

d. With the Chlorine Protection Mode inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> remove the chlorine tank car from the exclusion area. If the tank car physically can not be removed from the exclusion area, take the ACTIONS required in items a.2. b.2. and c.2 above.

SURVEILLANCE REQUIREMENTS

=

4.7.2 The control room emergency ventilation system shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating flow, from the control room, through the HEPA filter and charcoal adsorbers in each filtration unit and verifying that the system operates for at least 15 minutes,
b. At least once per 18 months or (1) after any structual maintenance on the HEPA painting, fire, filter or charcoal or chemical adsorber release in anyhousing,lation venti zoneor (2) following communicating with the system by:

4 1. Verifying that the cleanup system satisfies the in-place testing acceptance criteria of > 99 percent efficienc the test procedures of Regulatory Positions C.5.a. C.yS.c.

using and C.5.d of Regulatory Guide 1.52. Revision 1. July 1976, and the system flow rate is 2000 cfm 10%.

BRUNSWICK - UNIT 2 3/4 7-3a Amendment No. I

, INSTRUMENTATIGJ BASES 3/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Backaround (Continued) the Service Water Building, or a slow leak lasting for an extended period of time) and an external smoke event. These events form the basis for the I

design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

During a radiation event, the CBHVAC System is required to automatically isolate and enter the Radiation / Smoke Protection Mode on a Control Room Intake High Radiation signal frum the Area Radiation Monitoring System. Upon receipt of a high radiation signal. the CBHVAC Syst c is automatically realigned to the emergency mode of operation. The normal fresh air inlet closes. and, at approximately the same time, the emergency air filtration units begin operation, recirculating control room air and providing filtered makeup air to minimize contamination build-up and provide positive pressure in the Control Room Envelope. The CBHVAC System responds to an external smoke event in the same manner as it does for a radiation event.

In the event of a chlorine release, the CBHVAC System enters a full recirculation mode (Chlorine Protection Mode), with no outdoor air intake The emergency filtration trains do not start, since they do not effectively remove chlorine and may be damaced by the presence of chlorine. Protection for chlorine cas events "overrices" any concurrent ongoing, and any subsequent rac tation or smoke initiation signals. ,The override design offers-protection to operations personnel in the Control Room by providing protection against potentially fatal chlorine gas releases. This protection is required any time the chlorine tank car is within the exclusion area.

The CREVS is designed to meet the criteria of General Design Criterion (GDC) 19 (Reference 1). In addition, the system is designed using the guidance of Regulatory Guide 1.95. Revision 1 (Reference 2). Commitments haw also been made to design the radiation protection function of the CBHVAC-System to meet the single failure criteria described in IEEE 279-1971, and the chlorine detection and isolation logic to single failure criteria, both with approved exceptions (Reference 6. Section 3.6).

ACTION Statements 90. 91. and 92 require isolating the control room and operating Radiation / Smoke Protection Mode, as appropriate.the CREVS These ACTIONS in either presume that the Chlorine !rotec the CREVS is OPERABLE. During implementation of the Control Room Air Conditioning System replacement modification, the CREVS instrumentation may be considered OPERABLE. with a temporary barrier installed in the duct, or during use of temporary condensing units for the Control Room Air Conditioning System, as described in Bases 3/4.7.2.

LCD

' Operability of the CREVS instrumentation ensures that the control room operators will be protected from hazards external to the control room, consistent with the assumptions in the various analyses, through the prompt detection and initiation of the necessary protective actions of the system.

BRUNSWICK - IINIT 2 B 3/4 3-3a Amendment No. l

> 1

INSTRUMENTATION BASES a

3/4 3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Anolicability The instrumentation associated with the Radiation / Smoke Protection Mode of the CREVS is required to be operable to automatically detect and initiate the Radiation / Smoke Protection Mode of operation during times when the potential exists for events which may result in the release of radioactive n terials to the environment up to and including design basis accidents. The specific radiological release events for which the system must provide a mitigating I function are discussed in the bases of Technical Specification 3.7.2 and '

0B0-37 (Reference 6).

The instrumentation associated with the Chlorine Protection Mode of the CREVS is required to be OPERABLE to automatically detect and initiate the internal recirculation mode of operation any time the chlorine tank car is within the exclusion area.

The instrumentation associated with the External Smoke Protection function e' the CREVS is required to be OPERABLE to automatically detect and initiate uie Radiation / Smoke Protection Mode of operation during the same conditions as the Radiation Protection function. This ensures that habitability of the control room is maintained during times when a radiological release could potentially occur, ections Radiation Protection Two control room air inlet radiation detectors measure radiation levels in the inlet ducting of the main control room. A high radiation level automatically initiates L radiation protection mode of operation. Both channels are required to be OPERABLE to ensure that no single instrument failure can preclude the initiation of the radiation protection function of the control room emergency ventilation system. The loss of a single detector means that the CREVS reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced or lost system capability. The 7 day out of service time is based on the low arobability of a design basis accident and a single failure occurring during t11s time period, and the capability of the remaining instrumentation subsystem to provide the reguired isolation and is consistent with the out of service times allowed for loss of redundancy at the system level.

The loss of both detectors means that the automatic detection / isolation function of the radiation protection system is lost. Placing the CBHVAC System in the Radiation / Smoke Protection Mode is a suitable compensatory action to ensure that the automatic radiation protection function is not lost, Chlorine Protection The chlorine detection / isolation instrumentation is organized into two trip systems, with one trip system (remote) located near the chlorine tank car and the other located in the control building intake plenum (local). Each trip system contains two trip subsystems, with two detectors-(one from each BRU"SWICK - UNIT 2 B 3/4 3-3b Amendment No. I

0 c 1NSTRUMENTATLOU BASES

?

3/4.3.6.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) i Actions (Continued) division) in each tria subsystem. Both trio subsystems in each trip system i are required to be OPERABLE any time the chlorine tank car is within the .

i exclusion area to ensure adequate protection for the control room under  !

postulated toxic gas events. ,

The chlorine detectors in each trip system are arranged in a one-out of-two-

, taKen twic configuration. One detector from each of the trip sussytems ina i trip system must actuate to initiate the automatic detection / isolation I function. The loss of a-single chlorine detector means that the CREVS t 4

reliability is reduced because a single failure in the remaining OPERABLE trip

. subsystem detector could result in reduced or lost system capabilit . The 7 day out of service time is based on the low probability of a desi n basis I chlorine gas event and a single active failure occurring during thi time  ;

period, and the capability of the remaining detectors to provide the required

  • 1 solation capabilities. The out-of service time is consistent with the out of service time allowed for loss of redundancy at the system level.

'The loss of both detectors in any trip subsyst?m means that the automat M 3rotection function of the chlorine detection / isolation-system is lost.

) lacing the CBHVAC System in the Chlorine Protection Mode, through the use of '

control switches to close the appropriate dampers, ensures that the control room envelope is protected, while at the same time allowing a valid radiation or smoke signal to initiate appropriate protective actions. Operation in  ;

this mode is not limited in duration provided that either trip system remains i functional to ensure that the override function of the Chlorine Protection  !

Mode is not lost. i Smoke Protection Automatic detection / isolation of the control room envelope in response to an external smoke event is dependent on the response of ionization detectors in i Zones 4 and 5 of the Control Room. Multiple detectors in-each of the zones provide the detection / isolation capability however, detection by one detector in both zones is required to initiate the Isolation function.

Havinc less than two detectors OPERABLE in a zone means the system reliability is reiuced due to the loss of redundant detection capability in that zone, Allowing continued operation for up to 7 days with less than two OPERABLE detectors in either or both zones is an acceptable out of service time considering the low probability of an external smoke event and the failure of the remaining detector during this time period, and the capability of the remaining instrumentation to provide the required isolation. The out >f service time is consistent with the out of service times allowed for loss of redundancy at the system level.

With less than one detector OPERABLE in either or both zones, the automatic detection / isolation function of the external smoke protection system is lost.

Placing the CBHVAC System in the Radiation / Smoke. Protection Mode is a suitable compensatory action to ensure that the automatic external smoke protection r function is not lost.

1 i

BRUNSWICK - UNIT 2 B'3/4 3-3c Amendment No. I s

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, INSTRUMENTATION BASES 1

3/4.3.5 5 CONTR01 ROOM EMERGENCY VENTllATION SYSiEM (Continued)

Surveillances Radiation Protection i

Performance of the CHANNEL CHECK once every day ensures that a gross failure of the instrumentation has not occurred: thus, it is key to verifying the

instrumentation continues to o)erate properly between each CHANNEL 4

" CAllBRATION. The CHANNEL CHECC frequency is consistent with that performed 4

for other radiation monitors with isolation functions.

. 1

' The CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will aerform the intended function. The Control Building HVAC DBD (Reference 5) defines the specific actions to be satisfied by the radiation actuation instrumentation. The quarterly frequency of the CHANNEL FUNCTIONAL TEST was established based on Reference 7 and is consistent t

with that performed for other radiation monitors with 1 solation functions.

The CHANNEL CAllBRATION verifies the channel responds to the measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to ensure consistency with the system assumptions (Reference 5). The frequency of the calibration is consistent with the a frequency of calibration of other radiation monitors with isolation functions.

! Chlorine Protection i The CHANNEL FUNCTIONAL TEST is performed on each required channel to ensure that the entire channel will oerform + h intended function. The Control-Building HVAC DBD (Reference 5) defit t the s)ecific actions to be satisfied by the chlorine isolation instrumentation. T1e monthly frequency of the CHANNEL FUNCTIONAL TEST is consistent with the testing frequencies performed i by other utilities with this type of instrumentation. ,

l The CHANNEL CAllBRATION of the trip units provides a check of the instrument loop and the sensor when the sensor is replaced. The test verifies the calibration of the existing sensor prior to removal and performs an installation calibration of the new sensor. including a complete channel calibration with the new sensor installed, to verify the channel responds to L the measured parameter within the necessary range and accuracy. The CHANNEL CAllBRATION leaves the channel adjusted to ensure consistency with the system i assumptions (Reference 6).

- The chlorine detectors use an am]erometric sensor consisting of a platinum cathode and silver anode joined )y n electrolytic salt bridge, all enclosed in a permeable membrane. This design eliminates the majority of the maintenance required on previous detectors. The detectors have been in service at other facilities and have provided reliable service. The annual replacement and calibration are based on a manufacturer recommendation. The adequacy of the replacement interval has been confirmed through discussions with other utilities.

~

Smoke Protection

. The CHANNEL FUNCTIONAL TEST for the Smoke Protection instrumentation is consistent with the testing performed in accordance with the existing Fire Detection Instrumentation requirements. CHANNEL CAllBRATION is performed in accordance with the requirements of the CREVS specification (4c7.2).

r BRUNSWICK - UNIT-2 B 3/4 3-3d- . Amendment No. l

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c PLANT SYSTEMS BASES 3/4.7 2 CCNfROL ROOM EMERGENCY VENTILATION sis 1EM Backnround One of the principal d%1gn objectives of the Control Building Heating.

Ventilation and Air Conditioning (CBHVAC) System is to permit continuous occupancy of the Control Room Emergency lone under normal operating conditions and under the postulated design basis events throughout the life of the plant.

The Control Building HVAC System must function to provide protection to the operators for Accident e

three typ(e. events: a radiation event, u) to and including a Desicn Basis g.. Main Steam Line Break [MS_B] Accident. Refueling Accicent. Control Rod Orop Accident. or Loss of Coolant Accident [LOCA]) a toxic gas event (complete rupture of the 55 ton chlorine tank car located near the Service Water Building, or a slow leak lasting for an extended period of time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

The CREVS is designed to meet General Design Criterion (GDC) 19 (Reference 1).

In addition the system is designed using the guidance of Regulatory Guide 1.95. Revis1or 1 (Reference 2). Commitments have also been made to design the radiation protection function of the C8HVAC System to meet the single failure criteria described in IEEE 279-1971, and the chlorine detection and isolation logic to sin le failure criteria, both with approved exceptions (Reference 12. Section 3.6 .

During implementation of the Control Room Air Conditioning System re)lacement modification, the CREVS may be considered OPERABLE with a temporary Jarrier installed in the duct as part of the control room pressure boundary, The tem)orary ductwork barriers are required to be constructed to 3 reserve the leacage characteristics of the control room presure boundary lowever, these temporary barriers are not required to be seismically qualified. In addition, adjacent ductwork may be considered OPERABLE if not seismically qualified while work is actively in progress.

Also, during the installation of the Control Room Air Conditioning System replacement modification, the temporary condensing units which su) pert the operability of the Control Room HVAC System may be considered OPERABLE as long as two of the three units are functional even though they are not protected from severe natural phenomena such as seismic events and tornadoes, or radioactive sabotage. Single failure criteria do not apply to the Control Room Air Conditioning System during this time.

LCQ Operability of the CREVS ensures that the control room will remain habitable for operations personnel during and following all credible hazard event scenarios external to the control room, consistent with the assumptions in the various analyses, Two redundant-subsystems of the CREVS are required to be

-OPERABLE to ensure that at least one is available. assuming a single failure disables the other subsystem. The CREVS is considered OPERABLE when the individual- components necessary to control operator exposure are operable in both subsystems, For the Radiation / Smoke Protection Mode, a subsystem is considered OPERABLE when its associated:

1, Fan is OPERABLE.

2, HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and BRUNSWICK.- UNIT 2 8 3/4 7-Ic Amendment No. l

l.

ENCLOSURE 7 11RUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR 62 REQUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM I

MARKED UP SPECIFICATION PAGES - UNIT 1 l

.I

. INSTRUMENTATION CONTROL ROOM EMERGENCY VENTILATION SYSTEM l

f' '- LIMITING CONDITION FOR OPERATION

, s. >

3.3.5.5 The Control Room Emergency Ventilation Sys em instrumentation shown in Table 3.3.5.5-1 shall be OPERABL ,

ADD APPLICABILITY: As shown in Table 3.3.5.5 1.

i ACTION:

a. With one or more detectors inoperable, take the ACTION required by_

Table 3.3.5.5-1.

b. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.5.5 Each of the above required control room emergency ventilation instruments shall be demonstrated OPERABLE by performance of the testing at the frequency required by Table 4.3.5.5-1.

l l

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BRUNSWICK UNIT 1 3/4 3-64 Amendment No. J41"* -

O INSERT FOR TECilNICAL SPECIFICATION 3.3.5.5:

The Control Room Emergency Ventilation System (CREVS) instrumentation may be considered OPERAllLE, consistent with the conditions specified in footnote *" to Technical Specification 3.7.2, during the time period from January 10,1998, to May 1, 1998, in this configuration, the CREVS instrumentation is not c4 dered to be in an ACTION statement for the purposes of Technical Specification 3.0.4.

5 s

PLANT SYSTEMS 3/4.7.2 CONTROL ROOM Et<ERGENCY VENTILATION SYSTEM

!\ LIMITING CONDITION FOR OPERATION 3.7.2 The Control Room Emergency Ventilation System shall be OPERABL h:

a. An OPERABLE Radiation / Smoke Protection Mode consisting of two OPERABLE control room emergency filtration subsystems,
b. An OPERABLE Chlorine Protection Mode.

APPLICABILITY: OPERATJONAL CONDITIONS 1, 2, 3, 4, 5, *, and **

ACTION:

a. In OPERA'l10NAL CONDIlIONS I and 2:
1. With one control room emergency filtration unit inoperable, restore the inoperable control room emergency filtration unit to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2'l With both control roci emergency filtration units inoperable, be in at least HOT SHUTOOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHlffDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

5. In OPERATI,0NAL CONDITION 3:

1 With one control room emergency filtration unit inoperable, restore the inoperable centrol room emergency filtration unit to OPERABLE status within 7 days or be in COLD SHUTDOWN within the following 24 hcurs.

2. With both control room emergency filtration units e inoperable, be in COLD SHUTDOWN within the following I to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. __

D J

[c. In OPERATIONAL CONDITIONS 4, 5, and *:

[4" 1. With one control room emergency filtration unit ,'. operable, Y" restore the inoperable control room eniergency filtration of) 1 unit to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control building emergency filtration unit in the Radiation / Smoke Protection Mode.

During movement of irradiated fuel assemblies in the secondary containment.

The Chlorine Protection Mode is required to be OPERABLE at all times when the chlorine tank car is within the exclusior. area.

SEE NSERT BRUNSWICK - UNIT 1 3/4 7-3 Amendment No. JF

=

l.-

'n INSERT FOR TECIINICAL SPECIFICATION 3.7.2: j The Control Room Emergency Ventilation System (CREVS) ductwork may be considered -

OPERABLE, for one or more periods totaling up to 16 days, using temporary ductwork barriers constructed to preserve the leakage characteristics of the control room pressure boundary under normal operational conditions, during the implementation of the Control Room Air Conditioning System replacement modification. The chlorine tank car shall be removed from the exclusion area while temporary ductwork barriers are being used. The CREVS may also b: considered OPERABLE up to 9 weeks with temporary condensing units and associated piping and controls installed. Two of these units shall be functional during normal opei tional conditions. This is applicable during the time period from January 30,1998, to May 1,1998. In this configuration, the system is not considered to be in an ACTION statement for the purposes of Technical Specification 3.0.4.

C,

._. _, .. . _. . _ _ _ . __ _ _. _ _ ~ _ _. _ . _ _ .-

SYSTEMS

~

3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM l LIMITINGCONDITIONFOROPERATION(ContinueO ACTION (Continued):

2. With 'ooth control--room emergency filtration units 4

inoperable, suspend all operations involving CORE ALTERATIONS,: handling of irradiat?d fuel in secondary

, containment, and operations with a potential for draining the reactor vessel.- .

2

d. With the Chlorine Protection Mode inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> remove the chlorine tank car from the exclusion area. If the tank car physically can not be removei trom the exclusion area, take the ACTIONS required in items a.2 b.2, and c.2 above.

SURVEILLANCE REQUIREMENTS 4.7.2 The co5 trol room emergency ventil.' tion system shall be demonstrated l OPERABLE:

-a. At least. once per 31 days by initiating flow, from the controi room, through the HEPA filter and charcoal adsorbers in each filtration unit and verifying that the system operates for at least 15 minutes, b.- -At least once per 18 months or (1) after any structual maintenance on the HEPA filter or charcoal adsorber housing, or (2)-following-painting, fire, or chemical release in any ventilation zone-communicating with the system by:

1. Verifying that the cleanup ' system satisfies the in-place' testing acceptance criteria of > 99 percent efficiency using -l the test' procedures of Regulatory Positions C.5.a, C.S.c, and C.5.d of Regulatory Guide 1.52, Revision 1, July 1976, and the system flow rate is 2000 cfm
  • 10%.

1.

BRUNSWICK'- UNIT 1 3/4 7-3a Amendment No. 161

INSTRUMENTATION BASES -

B 6 3/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Backaround(Continued)

, the Service Water Building, or a slow leak lasting for an extended period of 3

time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

During a radiation event, the CBHVAC System is required to rutomatically ,

isolate and entor the Radiation / Smoke Protection Mode on a Control Room Intake High Radiation signal from the Area Radiation Monitoring System. Upon receipt

} of a high radiation signal, the CBHVAC System is automatically realigned to the emergency mode of operation. The normal fresh air inlet closes, and, at approximately the same time, the emergency air filtration units begin operation, recirculating control room air and providing filtered makeup air to minimize contamination build-up and provide positive pressure in the Control Room Envelope. The CBHVAC System responds to an external smoke event in the same manner as it does for a radiation event.

) In the event of a chlorine release, the CBHVAC System enters a full E recirculation' mode (Chlorine Protection Mode), with no outdoor air intake.

E The emergency filtration trains do not start, since they do not effectively remove chlorine and may be damaged by the presence of chlorine. Protection for chlorine gas events " overrides" any concurrent, ongoing, and any subsequent radiation or smoke initiation signals. The override design offers

" protection to operations personnel in the Control Room by providing protection against potentially fatal chlorine gas releases. This protection is required E- any time the chlorine tank car is within the exclusion area.

The CREVS is designed to meet the criteria of General Design Criterion (GDC) 19 (Reference 1). In addition, the system is designed using the guidance of Regulatory Guide 1.95, Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE 279-1971, and the chlorine detection ano isolation logic to single failure criteria, both with approved exceptions (Reference 6, Section 3.6).

~

7 LCO EE NSERT r Operability of the CREVS instrumentation ensures that the control room operators will be protected from hazards external to the control room, consistent with the assumptions in the various analyses, through the prompt detection and initiation of the necessary protective actions of the system.

Applicability The instrumentation associated with the Radiation / Smoke Protection Mode of the CREVS is required to be operable to automatically detect and initiate the Radiation / Smoke Protection Mode of operation during times when the potential exists for events which may result in the release of radioactive materials to i_ the environment, up to and including design basis accidents. The specific radiological release events for which t.1e system must provide a mitigating

=

( ~ function are discussed in the bases of Technical Specification 3.7.2 and DBD-37 (Reference 6).

1 BRUNSWICK - UNIT 1 B 3/4 3-3a Amendment No..lA P

___.__U

t; INSERT FOR TECHNICAL SPECIFICATION BASES SECTION 3/4.3.5.5:

ACTION Statements 90,91, and 92 require isolating the control room and operating the CREVS

' in either the Chlorine Protection Mode or the Radiation / Smoke Protection Mode as appropriate These ACTIONS presume that the CREVS is OPERABLE. During implementation of the-Control Room Air Conditioning System replacement modification, the CREVS instntmentation

- may be considered OPERABLE, with a temporary barrier installed in the duct, or dunng use of temporary condensing units for the Control Room Air Conditioning System, as described in Bases 3/4.7.2.

O

. PLANT SYSTEMS BASES -

(

3/4 7.2 CONTROL R00H EMERGENCY VENTILATION SYSTEM Backoround One of the principal design objectives of the Control Building Heating. -

Ventilation and Air Conditioning (CBHVAC) System is to permit continuous t

' occupancy of the Control Room Emergency Zone under normal operating conditions and under the postulated dasign basis events throughout the life of the plant.

The Control Building HVAC System must function to provide protection to the operators for three type events: a radiation event, u3 to and including a Design Basis Accident (0.g., Main Steam Line Break [MS.B] Accident, Refueling Accident, Control Rod Dron Accident, or Loss of Coolant Accident [LOCA]), a toxic gas event (complete rupture of the 55 ton chlorine tank car located near the Service Water Building, or a slow leak lasting for an extended period o' time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

The CREVS is designed to meet General Design Criterion (GDC) 19 (Reference 1).

In addition, the system is designed using the guidance of Regulatory Guide 1.95, Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE 279 1971, and the chlorine detection and isolation logic to sing'le f6;1ure criteria, both with approved exceptions (Reference 12. Section 3.6).

g (SEE NSERT Operability of the CREVS ensures that the control room will remain habitable for operations personnel during and following all credible hazard event scenarios external to the control room, consistent with the assumptions in the various analyses. Two redundant subsystems of the CREVS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other subsystem. The CREVS is considered OPERABLE when the individual components necessary to control operator exposure are operable in both subsystems. For the Radiation / Smoke Protection Mode, a subsystem is considered OPERABLE when its associated:

1. Fan is OPERABLE,
2. HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and Pi BRUNSWICK UNIT 1 B 3/4 7 Ic Amendment No. 1 [ l I l

.... -- -_ _ . - -- ~_. - . -

r' ,

N INSERT FOR TECHNICAL SPECIFICATION BASES SECTION 3/4.7.2:-

i During implementation of the Control Roorn' Air Conditioning System replacement modification. . ,

- the CREVS n.ap be considered OPERABLE with a temporary barrier installed in the duct as part  ;

- of the control room pressure bo'endary. The temporary ductwork barriers are required to be - .

constructed to preserve the leakage characteristics of the control room pressure boundary; -

however, these temporary barriers are not required to be seismically qualified. In addition, ,

. adjacent ductwork may be considered OPERABLE if not seismically qualified while work is i

actively in progress; Also, during the installation of the Control Room Air Conditioning System replacement

-modification, the temporary condensing units which support the operability of the Control Room HVAC System may be considered OPERABLE as long as two of the three units are functional, even though they are not protected from severe natural phenomena such as seiemic events and tomadoes, or radioactive sabotage. Single failure criteria do not apply to the Control Room Air Conditioning System during this time.

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ENCLOSURE 8.

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS CONTROL BUILDING EMERGENCY VENTILATION SYSTEM l

6 s

. MARKED-UP TECHNICAL SPECIFICATION PAGES - UNIT 2 - )

i

0 INSTRUMENTATION L CONTROL ROOM EMERGENCY VENTILATION SYSTEM l

t .- LIMITING CONDITION FOR OPERATION 3.3.5.5 The Control Room Emergency Ventilation SysJ*qm instrumentation shown in Table 3.3.5.5-1 shall be OPERABLM ADO APPLICABILITY: As shown in Table 3.3.5.5-1.

ACTION: .

a. With cne or more detectors inoperable, take the ACTION required by Tabl e 3.3.5.5-1.
b. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.5.5 Eac.h of the above required control room emergency ventilation instruments shall be demonstratej OPERABLE by performance of the testing at the frequency required by Table 4.3.5.5-1.

BRUNSWICK - UNIT 2 3/4 3-64 Amendment No. W

4 INSERT FOR TECHNICAL SPECIFICATION 1.3.5.5:

The Control Room Emergency Ventilation System (CREVS) instrumentation may be considered OPERABLE, consistent with the conditions specified in footnote *" to Technical Specifier tion 3.7.2, during the tinie period from January 30,1998; to May 1, 1998. -In this confituration, the CREVS instrumentation is not considered to be in an ACTION statement for the purposes of Technical Specification 3.0.4.

4 i

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0 a< , PLANT SYSTEMS 3/4,7,2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM l

l ,3 LIMITING CONDITION FOR OPERATION f ^**

3.7.2 The Control Room Emergency Ventilation System shall be OPERABLN:

a. An OPERABLE Radiation / Smoke Protection Mode consisting of two OPERABLE control room emecgency filtration subsystems,
b. -An OPERABLE Chlorine Protection Mode.

APPLICABILITY: OPERATIONAL CONDITIONS 1, 2, 3, 4, 5, *, and **

ACTION:

a. In OPERATIONAL CONDITIONS 1 and 2:
1. With one control room emergency filtration unit inoperable, ,

restore the inoperable control room emergency filtration unit to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2? With both control room emergency filtration units inoperable, be in at least HOT SHUT 00WN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and i in COLD SHUTOOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

b. In OPERATIONAL CONDITION 3:
1. With one cont'rol room emergency filtration unit inoperable, restore the inoperable control room emergency filtration unit to OPERABLE status within 7 days or be in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2. With both control room emergency filtration units inoperable, be in COLD SHUTDOWN within the following

/ 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

E C In OPERkTIONAL CONDITIONS 4, 5, and *:

g"t' --

1. With one control room emergency filtration unit inoperable, g

> w restore the inoperable control room emergency filtration 2 unit to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control building emergency filtration unit in the-Radiation / Smoke Protection Pode.

% _/

During movement of irradiated fuel asse-blies in the secondary containment.

- when the chlorine tank car is within the exclusion area.

segr BRUNSWICK - UNIT 2 3/4 7-3 Amendment No. F

.- . - . . - - - - -.. . . .- . - - _ - . .~.-. _ . - . . - . _ . - . - . . . - . - -

f 1

1NSERT FOR TECHNICAL SPECIFICATION 3.7.2:

"* ~Ihe Control Room Emergency Ventilation System (CREVS) ductwork may be ,

considered OPER ABLE, for one or more periods totaling up to 16 days, using temporary

. ductwork barriers constructed to preserve the leakage characteristics of the control room pressure boundary under nonnal operational conditions, during the implementation of the - ,

Control Room Air Conditioning System replacement modification. The chlorine car shall be removed from the exclusion area while temporary ductwork barriers are being used.

The CREVS may also be considered OPERABLE up to 9 weeks with temporary condensing units and associated piping and controls installed. Two of these units shall be functional during normal operational conditions.- This is applicable during the time period from January 30,1998, to May 1,1998. In ths configuration, the system is not -

considered to be in an ACTION statement for the purposes of Tect;nical Specification 3.0.4.

3 o

l-

... . SYSTEMS

'3/4,7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM l

6 LIMITING _ CONDITION FOR OPERATION (Continued)

ACTION (Continued):-

2. With both control _ room emergency filtration units inoperable, suspend all operations involving CORE-ALTERATIONS, handling of irradiated fuel in secondary containment, and operations with a potential- for draining-the reactor vessel. ,
d. With the Chlorine Protection Mode inoperable, within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> remove the chlorine tank car from the exclusion area. If the tank car. physically can not be removed from the exclusion area, take the ACTIONS required in items a.2, b.2, and c.2 above.

SURVEILLANCE REQUIREMENTS 4.7.2 The cont'rol room emergency ventilation system shall be demonstrated l OPERABLE:

a. At least once per 31 days by initiating flow, from the control' room, through the HEPA filter and charcoal adsorbers in each.-

filtration unit and verifying that the system operates for at least 15 minutes,

b. At least once per 18 months or (1).after any structual maintenance on the HEPA filter or charcoal adsorber housing, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:
1. Verifying that the cleanup system satisfies the in place testing acceptance criteria cf > 99 percent efficiency using l the test proceoures of Regulatory Positions C 5.a C.5.c, and C.5.d of Regulatory _ Guido 1.52,. Revision 1, July 1976, and the system finw rate is 2000 cfm i 10%.

-Q; BRUNSWICK - UNIT 2 3/4 7-3a Amendment No. 192

e

! a INSTRUMENTAT10tj BASES -

l' ' }/4.3.5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Background (Continued) the Service Water Building, or a slow leak lasting for an extended period of time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS)~ function of the CBHVAC System.

During a radiation event, the CBHVAC System is required to a'itomatically isolate and enter the Radiation / Smoke Protection Mode on a Lontrol Room Intake High Radiation signal from the Area Radiation Monitoring System. Upon receipt of a high radiation signal, the CBHVAC System is automatically realigned to the emergency mode of operation. The normal fresh air inlet closes, and, at approximately the same time, the emergency air filtration units begin operation, recirculating control room air and providing filtered makeup air to minimize contamination build-up and provide positive pressure in the Control Room Envelope. The CBHVAC System responds to an external smoke event in the same manner as it does for a radiation event.

In the event of a chlorine release, the CBHVAC System enters a full recirculation ihoda (Chlorine Protection Mode), with no outdoor air intake.

The emergency filtration trains do not start, since they do not effectively remove chlorine and may be damaged by the presence of chlorine. Protection for chlorine gas events " overrides" any concurrent, ongoing, and any subsequent radiation or smoke initiation signals. The override design offers r

protection to operations personnel in the Control Room by providing protection against potentially fatal chlorine gas releases. This protection is required any time the chlorine tank car is within the exclusion area.

The CREVS is designed to meet the criteria of General Design Criterion (GDC) 19 (Reference 1). In addition, the system is designed using the guidance of Regulatory Guide 1.95, Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE 279-1971, and the chlorine detection and isolation logic to single failure criteria, both with approved exceptions (Reference 6, Section 3.6),

g {SEE INSER T )

Operability of the CREVS instrumentation ensures that the control room operators will be protected from hazards external to the control room, consistent with the assumptions in the various analyses, through the prompt detection and initiation of the necessary protective actions of the system.

Applicability The instrumentation associated with the Radiation / Smoke Protection Mode of the CREVS is required to be operable to automatically detect and initiate the Radiation / Smoke Protection Mode of operation during times when tl.a potential exists for events which may result in the release of radioactive materials to the environment, up to and including design basis accidents. The specific radiological release events for which the system must provide a mitigating

'_ function are discussed in the bases of Technical Specification 3.7.2 and DBD-37 (Reference 6).

BRUNSWICK - UNIT 2 B 3/4 3-3a Amendment No. #

[: _g 4'

INSERT FOR TECHNICAL SPECIFICATION BASES SECTION 3/4.3.5.5:

ACTION Statements 90,91, and 92 require isolating the control room and operating the CREVS

' in either the Chlorine Protection Mode or the Radiation / Smoke Protection Mode, as appropriate.

These ACTIONS presume that the CREVS is OPERABLE, During implementation of the Control Room Air Conditioning System replacement modification, the CREVS instrumentation may be considered OPERABLE, with a temporary barrier installed in the duct, or during use of temporary condensing units for the Control Room Air Conditioning System, as described in Bases 3/4,7.2,

\

g

o PLANT SYSTEMS B5SES f - -  :

3/4.7.2 CONTROL R00H EHERGENCY VENTILATION SYSTEM Backaround One of the principal design objectives of the Control Building Heating, Ventilation and Air Conditioning (CBHVAC) System is to pemit continuous occupancy of the Control Room Emergency Zone under normal operating conditions and under the postulated design basis events throughout the life of the plant.

The Control Building HVAC System must function to provide protection to the operators for three type events: a radiation event, u) to and including a Design Basis Accident (e.g., Main Steam Line Break PiS B] Accident, Refueling Accident, Control Rod Drop Accident, or loss of Coolant Accides;t [LOCA)), a toxic gas event (complete rupture of the 55 ton chlorine tank car located near the Service Water Building, or a slow leak lasting for an extended period of time), and an external smoke event. These events form the basis for the design of the Control Room Emergency Ventilation (CREVS) function of the CBHVAC System.

The CREVS is designed to meet General Design Criterion (GDC) 19 (Reference 1).

In addition, the system is designed using the guidance of Regulatory Guide 1.95, Revision 1 (Reference 2). Commitments have also been made to design the radiation protection function of the CBHVAC System to meet the single failure criteria described in IEEE 279 1971, and the chlorine detection and isolation logic to single failure criteria, both with approved exceptions

(Reference 12. Section 3.6),  ;

] Q iNscRT]

-Operability of the CREVS ensures that the control room will remain habitable for operations personnel during and following all credible hazard event scenarios external to the control room, consistent with the assumptions in the various analyses. Two redundant subsystems of the CREVS are required to be OPERABLE to ensure that at least one is available, assuming a single failure disables the other subsystem. The CREVS is considered OPERABLE when the individual components necessary to control operator exposure are operable in both subsystems. For the Radiation / Smoke Protection Mode, a subsystem is considered OPERABLE when its associated:

1. Fan is OPERABLE,
2. HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and c

f BRUNSWICK UNIT 2 B 3/4 7-Ic Amendment No. 195 " l 1

o i

INSERT FOR TECIINICAL SPECIFICATION BASES SECTION 3/.t.7.2:

During implementation of the Control Room Air Conditioning System replacement modification, the CREVS may be considered OPERABLE with a temporary barrier installed in the duct as part of the control room pressure boundary. The temporary ductwork barriers are required to be

. constructed to preserve the leakages.:haracteristics of the control room pressure boundary;

- however, these temporary baniers are not required to be seismically qualified. In addition,-

adjacent ductwork may be considered OPERABLE if not seismically qualified while work is actively in progress.

Also, during the installation of the Control Room Air Conditioning System replacement modification, the temporary condensing units which support the operability of the Control Room

- HVAC System may be considered OPERABLE as long as two of the three units are functional, even though they are not protected from severe natural phenomena such as seismic events and tornadoes, or radioactive sabotage, Single failure criteria do not apply to the Control Room Air Conditioning System during this time.

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