ML20203B136

Proposed Tech Specs Changing Setpoint for Radiation Monitor EMF-39 & Increasing Allowed Outage Time for Auxiliary Bldg Filtered Exhaust Sys

ML20203B136
Person / Time
Site:	Catawba
Issue date:	04/09/1986
From:	DUKE POWER CO.
To:
Shared Package
ML20203B128	List: ML20203B124 ML20203B136
References
NUDOCS 8604180026
Download: ML20203B136 (6)

Text

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TABLE 3.3-6 (Continued)

TABLE NOTATIONS With fuel in the ' fuel storage pool areas. c)

• • • Withirradiatedfuelinthefuelstoragepoolareas.J:t:b!!:h4 Trip Setpoint concentration value (pCi/ml) is to be,. m.. 3;t

..m....., -__4._ 2 .. .... ...o

... ____ 2 e _ o n. 4 . .'-mu-hiidi + The Setpoint value may be 'r:r::::d ggfo the equivalent limits of Specification 3.11.2.1 in accordance with the methodology and parameters in the 00CM during containment purge or vent provided the Setpoint value does not exceed twice the maximum concentration activity in the containment determined by the sample analysis performed prior to each release in accordance with Table 4.11-2.

ACTION STATEMENTS ACTION 30 - With less than the Minimum Channels OPERABLE requirement, operation may continue provided the containment purge and exhaust valves are maintained closed.

ACTION 31 - With the number of operable channels one less than the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> isolate the affected Control Room Ventilation System intake from outside air with recirculating flow through the HEPA filters and carbon adsorbers.

ACTION 32 - With less than the Minimum Channels OPERABLE requirement, opera- <

tion may continue for up to 30 days provided an appropriate l portable continuous monitor with the same Alarm Setpoint is provided in the fuel storage pool area. Restore the inoperable monitors to OPERABLE status within 30 days or suspend all l operations involving fuel movement in the fuel building. 1 ACTION 33 - Must satisfy the ACTION requirement for Specification 3.4.6.1.

ACTION 34 - With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, operation may continue provided the Fuel Handling Ventilation Exhaust System is operating and discharging through the HEPA filters and carbon adsorbers.

Otherwise, suspend all operations involving fuel movement in the fuel building.

ACTION 35 - With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirement, operation may continue provided the Auxiliary l Building Filtered Exhaust System is operating and discharging through  ;

the HEPA filter and carbon adsorbers.

ACTION 36 - With the number of OPERABLE channels less than the Minimum Chan als OPERABLE requirement, operation may continue for up to 30 days provided that, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, grab samples are collected and analyzed for radioactivity (gross gamma) at a lower limit of detection of no more than 10 7 pCi/ml.

8604180026 860409 PDR ADCCK 05000413 '

p PDR CATAWBA - UNITS 1 & 2 3/4 3-53 l

6 ATTACHMENT 2 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM ALLOWED OUTAGE TIME

DISCUSSION OF AMENDMENT REQUEST I

, The requested change to the ACTION statement for Technical Specification 3/4.7.7 Auxiliary Building Filtered Exhaust (VA) System would change the allowed outage time from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days and to show that the VA System consists of two independent trains. These changes would make the Catawba I

Specification consistent with the wording in the NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors (STS).

There have been several recent incidents at Catawba involving the inoperability of one train of the VA System. In each case, Duke Power requested Discretionary Enforcement from NRC/ Region II to allow the unit to continue to operate beyond the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ACTION time.

During each incident, the VA System was returned to service within 7 days.

} It is clear that the requirements for VA System operability should not be so strict. The STS allow for VA System inoperability for up to 7 days.

! The STS bases also contains the following statement concerning the STS ventilation system: "The operation of this system and the resultant effect on offsite dosage calculations was assumed in the safety analyses."

Catawba's VA System is not taken credit for in the accident analyses (see FSAR Section 15.6.5.4.1). The bases should be changed accordingly and the VA System Specification should therefore not be any more restrictive than the STS.

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. EN ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION 10 CFR 50.92 (c) states that "a proposed amendment... involves no significant hazards considerations, if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin cf safety".

This amendment request will not-involve any increase in the probability or consequences of an accident previously evaluated. Operation of the Auxiliary Building Filtered Exhaust (VA) System was not taken credit for in the Catawba FSAR (see FSAR Section 15.6.5.4.1).

This amendment request will rot create the possibility of a new or different kind of accident from any accident previously evaluated since the design and operation of the plant will not be affected.

The proposed amendment will not involve a significant reduction in a margin of safety. The proposed change to the ACTION statement would make Catawba's Technical Specifications consistent with the NRC's Standard Technical Specifications. The Staff has determined that 7 days is an appropriate allowed outage time for this system. Catawba's VA System does not involve a unique or unusual design and therefore, the Staff's generic Specification is applicable.

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a, Q;.4 ons 4ren of the Auiliary b bj Fdtarsc(. Exhurf Spfsm Enoperdle , ccM 4hc (noparah train to oPER48tE dabs WiNN 7 day 5 oc be. W a4 leasf hot Imo6Y db ne wexf lo ho-s and in COLb 14uTbouw w&in ne followinj 30 ho urs .

PLANT SYSTEMS 3/4.7.7 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM LIMITING CONDITION FOR OPERATION

%o inJenn dent +cens of 3.7.7 d he Auxiliary Building Filtered Exhaust System shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION: ,

,p ,f lees Y ene frWa

b. Withhhe Auxiliary Building Fil.tered Exhaust System inoperable, restordh

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,. _ to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY 30 hours. within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following SURVEILLANCE REQUIREMENTS 6 4 drain a f 4.7.7Jhe Auxiliary Building Filtered Exhaust System shall be demons,trated OPERABLE:

a.

At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters

operating;

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

1) 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) and uses the test proce-dure guidance in Regulatory Positions C.S.a. C.S.c. and C.S.d*

of Regulatory Guide 1.52, Revision 2 March 1978, and the system

flow rate is 30,000 cfm i 10%;

2) Verifying, within 31 days af ter removal, that a laboratory analysis of a representative carbon sample obtained in accor-dance 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 Revi-sion 2, March 1978, for a methyl iodido penetration of less than 1%; and i

"The requiremant for reducing refrigerant concentration to 0.01 ppm may be satisfied by operating the system for 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.

CATAWBA - UNITS 1 & 2 3/4 7-17

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1 PLANT SYSTEMS I

BASES '

l l j 3/4.7.7 AUXILIARY BUILDING FILTERED EXHAUST SYSTEM l i

! The OPERA 8ILITY of the Auxiliary Building Filtered Exhaust System ensures i j that radioactive materials leaking from the ECCS equipment within the auxiliary i

building following a LOCA are filtered prior to reaching the environment.

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 reduce the buildup of moisture on the adsorbers and HEPA filters.

The operation of this system and the resultant effect on offsite dosage calcu-i lations wa esemmed in the safety analyses. ANSI N510-1980 will be used as a

procedura uide for surveillance testing.

nd e crede b bear, b eeerde d As spf<a 4J Ne 3/4.7.8 SNUB 8ERS f*5M Nt m Oe dC StaD N5'N M" '*I'd"8 I uos assumed a We. %4's SU..MWtG4-o954. '

All snubbers are required OPERA 8LE to ensure that the structural integrit of the Reactor Coolant System and all other safety-related systems is main

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] tained during and following a seismic or other event initiating dynamic loads.  !

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size. Snubbers are classified and grouped by design and manufacturer but not by For example, mechanical snubbers utilizing the same design features of the 2-kip, 10-kip, and 100-kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by Company "8" for the purposes of this Technical Specification would be of a different type

• as would hydraulic snubbers from either manufacturer. '

i A list of individual snubbers with detailed information of snubber location

! and size and of system affected shall be available at the plant in accordance with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber shall

) be determined and approved by the Catawba Safety Review Group.

The determination shall be based upon the existing radiation levels and the expected time to per-

{;, form a visual inspection in each snubber location as well as other factors asso-ciated with accessibility during plant operations (e.g., temperature, atmosphere,

! location etc.), and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletions of any hydraulic or mechanical snubber shall be made in j accordance with Section 50.59 of 10 CFR Part 50.  :

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1 CATAW8A - UNITS 1 & 2 8 3/4 7-4 l I

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