ML20203B417

Amends 191 & 222 to Licenses DPR-71 & DPR-62,respectively, Consisting of Changes to TSs & Associated Bases in Response to 971106 Application & Suppl

ML20203B417
Person / Time
Site:	Brunswick
Issue date:	02/06/1998
From:	Bill Dean NRC (Affiliation Not Assigned)
To:
Shared Package
ML20203B421	List: ML20203B417 ML20203B445
References
NUDOCS 9802240283
Download: ML20203B417 (22)

Text

________ _ _

n atog e

,y

'a UNITED STATES g

,g NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. So66Hm01

't, *.. +,6 CAROLINA POWER & LIGHT COMPANY. et al.

DOCKET NO. 50-325 BRUNSWICK STEAM ELECTRIC PLANT. UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.191 License No. DPR-71 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by Carolina Power & Light Company (the licensee), dated November 6,1997, as supplemented by letter dated January 28,1998, complies with the standards and requirements of the Atomic Energy Act cf 1954, as amended (the Act), and the Commission's rules and regulations :,et forth in 10 CFR Chapter I; B.

Tne facility will operate in conformity with the application, the provisions of the A::t, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and ali applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. DPR-71 is hereby amended to read as follows:

M.

'j.fjj:/

9802240283 980206 l

PDR ADOCK 05000324 l

P PDR J

s i

2-(2)

Technical Soecifications The Technical Specific 6tions contained in Appendices A and B, as revised through Amendment No. 191, are hereby incorporated in the license Carolina Powe ' Light Company shall operate the facility in accordance with the Techna.1 Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION William M. Dean, Director Project Directorate ll-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of lasuance:

February 6,1998 A

s ATTACHMENT TO LICENSE AMENDMENT NO.141 FACILITY OPERATING LICENSE NO DPR-71 DOCKET NO. 50-325 Replace the following pages of the Appendix A Technical Specifications with the enclosed pages. The revised areas are indicated by marginallines.

Remove Pages insert Pages 3/4 3-64 3/4 3-64 3/4 7-3 3/4 7-3 3/4 7-3a 3/4 7-3a B3/4 3-3a B3/4 3-3a B3/4 3-3b B3/4 3-3b B3/4 3 3c B3/4 3-3c B3/4 3-3d B3/4 3-3d B3/4 7 ic B3/4 7-ic

INSTRUMENTATION CONTROL ROOM EMERGENCY VENTil ATION SYSTEM LIMITING CONDITION FOR OPERATION 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:

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

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, i

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 February 6, 1990, 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.1911

PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.2 The Control Room Emergency Ventilation System shall be OPERABLE *** with: I An OPERABLE Radiation / Smoke Protection Mode consistir.g of two a.

OPERABLE control room emergency filtration subsystems, b.

An OPERABLE Chlorine Protection Mode, e

l APPLICABILITY:

OPERATIONAL CONDITIONS 1. 2. 3. 4. S. *. and **

ACTION:

a.

5 OPERAil0NAL CONDITIONS 1 and 2:

1.

With one control roon emergency filtration unit inoperable, restore the ino>erable 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 SHUTDOWN witiin 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 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 Loth control room emergency filtration units ino3erable, be in COLD SHUTDOWN within the following 24 lours.

I 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 exclusion area.

The Control Room Emergency Ventilation System (tREVS) 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 be considered OPERABLE up to 9 weeks with tem controls installed.porary condensing units and associated piping and Two of these units shall be functional during normal operational conditions.

This is applicable during the time period from February 6,1998, 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 7-3 Amendment No.191 1

-_ _Y

SYSTEMS s

3/4 7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITJWG CONDITION FOR OPERATION (Continued)

ACTION-(Continued):

c.

In OPERATIONAL CONDITIONS 4. 5. and *-

1.

With one control room emergency filtration unit inopere~

restore the ino)erable control room emergency filtr-unit to OPERABLE status within 7 days or initia' maintain operation of the remaining OPERABLE com building emergency filtration unit in the Radiation / Smoke Protection Mode.

2.

With both control room em rgency filtration units ino)erable. suspend all operations involving CORE ALTERATIONS, handling of irradiated fue' in secondary containment, and operations with a pote'itial for draining the reactor vessel.

i 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 exc hsion 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 W autes, 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 communicoting 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.S.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.191 l

9 w

l INSTRUMENTATION BASES 3/4 3.6.5 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 9 sign 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 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 responas to an external smoke avent-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 chlorire gas events "overriies" eny 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 i

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).

ACTION Statements 90. 91 and 92 require isolatin the control room and operating / Smoke Protection Mode, as appropriate.the CREVS in either Radiation 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.

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 - UNIT 1 B 3/4 3-3a Amendment No.1911 l

j

INSTRUMENTATION BASES 3/4.3 5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

ADolicability 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 radiologicalreleaseeventsforwhichthesystemmustprovideamitigating 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 I

Two control room air inlet radiation detectors measure radiation' levels in the i

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 reliability is reduced because a single failure in the OPERABLE subsystem could result in reduced or lost systent capability.

The 7 day out of-service time is based on the low arobability of a desion basis accident and a single failure occurring during t11s time period and the capability of the remaining instrumentation subsystem to provide the required 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 subsy.,tems, with two detectors (one from each BRUNSWICK - UNIT 1 B 3/4 3-3b Amendment No.191 l

INSTRUMENTATION BASES i

3/4.3.5 5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Actions (Continued) division) in each tri) 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 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-twice configuration.

One detector from each of the tri trip system must actuate to initiate the automatic detection /p subsystems in a isolation 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 probabiiity 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 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 subsystem means that the automatic 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 functional to ensure that the override function of the Chlorine Protection 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 ion 1zation detectors in.

Zones 4 and 5 of the Control Building. Multiple detectors in each of the zones provide the detection / isolation capability: however, detection b detector in both zones is required to initiate.the isolation function.y one Having less than two detectors OPERABLE in a zone means the system reliability is reduced 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, end the capability of the remaining instrumentation to provide the requirea 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 e% ure that the automatic external smoke protection function is not lost.

BRUNSWICK - UNIT 1 B 3/4 3-3c Amendment No.1911

^

]NSTRUMENTATION BASES 3/4.3 5.5 CONTROL R00,M EMERGENCY VENTILATION SYSTEM (Continued)

Surveillance Radiation Protection 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 ocerate properly between each CHANNEL CAllBRATION. The CHANNEL CHECK 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 quarterly frequency of the CHANNEL FUNCTIONAL TEST was establisned based on Reference 7 and is consistent with th U performed for other radiation monitors with isolation functions.

The CHANNEL CAllBRATION verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANNEL CAllBRATION leaves the channel adjusted to ensurc consistency with the system assumptions (Reference 5).

The frequenc s Se calibration is consistent with the frequency of calibration of radiation monitors with isolation functions.

Chlorine Protection 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 s)ecific actions td be satisfied by the chlorine isolation instrumentation.

T1e monthly frequency of the CHANNEL FUNCTIONAL TEST is consistent with the testing frequencies performed by other utilities with this type of instrumentation.

The CHANNEL CALIBRATION 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 existino sensor prior to removal and performs an installation cMibration of the new sensor. inclu' ding a complete channel calibration wiu 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).

The chlorine detectors use an am)erometric sensor consisting of a olattnum cathode and silver anode joined )y an 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 raplacement 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 CALIBRATION is performed in accordance with the requirements of the CREVS specification (4.7.2).

BRUNSWICK - UNIT 1 B 3/4 3-3d Amendment NoI91l l

1

_ ____ _ )

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 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 Desu n Basis Accident (e.g., Main Steam Line Break [MS.B] Accident. Refueling Accicent. Control Rod Drop 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. 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).

During implementation of the Control Room Air Conditioning System re)lacement modificat1on. the CREVS may be considered OPERABLE with a temporary )arrier

_ installed in the duct as part of the control room pressure boundary.

The tempc,rary 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 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 OPERABLE as long as two of the three units are functional. even though they are not proteu.ed frc;a 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, assumina 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 1 B 3/4 7-Ic Amendment No.191 l

pus:o y'

'4 UNITED STATES g

,j NUCLEAR REGULATORY COMMISSION e

f WASHINGTON, D.C. 3084H001

$9.....,o CAROLINA POWER & LIGHT COMPANY. et al.

DOCKET NO. 50 324 BRUNSWICK STEAM FAECTRIC PLANT. UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 222 License No. DPR-62 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment filed by Carolina Power & Light Company (the licensee), dated November 6,1997, as supplemented by letter dated January 28,1998, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to ths Technical Specifications as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Facility Operating License No. DPR-62 is hereby amended to read as follows:

2 (2)

Technical Soecifications The Technical Specifications contained in Appenuces A and B, as revised through Amendment No. 222, are hereby incorporated in the license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

~

William M. Dean, Director l

Project Directorate 11-1 Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation

Attachment:

Chances to the Technical dpecifications Date of Issuance:

February 6,1998 w

6TTACHMENT TO LICENSE AMENDMENINO. 222 FACil !TY OPERATING LICENSE NO. DPR-62 DOCKET NO. 50-324 Replace the following pages of the Appendix A Technical Specifications with the enclosed pages. The revised areas are indicated by marginallines.

Remove Paoes Insert Paoes 3/4 3-64 3/4 3-64 3/4 7-3 3/4 7 3 3/4 7 3a 3/4 7 3a B3/4 3-3a B3/4 3 3a B3/4 3-3b B3/4 3-3b B3/4 3-3c B3/4 3-3c B3/4 3 3d B3/4 3-3d B3/4 7-1c B3/4 7-1c I

1NSTRUMENTAT104 CONTROL ROOM EMERGENCY VENTIL ATION SYSTEM LIMITING CONDITION FOR OPERATION

- 3.3.5.5 The Control Room Emergency Ventilation System instrumentation shoc in Table 3.3.5.5-1 shall be OPERABLE

• 1 1

APPLICABILITY:

As shown in Table 3.3.5.51.

ACTION:.

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

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.

i 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 February 6,1998, to May 1.1998.

In this configuration. the CREVS instrumentation is not considered to be in an ACTION statement for the purposes of Technical Specification -3.0.4.

BRUNSWICK - UNIT 2 3/4 3-64 Amendment No.2221

__......_.,.....__.m J l

PLANT SYSTEMS s

3/4 7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3,7.2 The Control Room Emergency Ventilation System shall be OPERABLE *** with: I An OPERABLE Radiation / Smoke Protection Mode consisting of two a.

OPERABLE control room emergency 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 ino)erable 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 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 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

.24 lours.

I 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 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 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 be considered OPERABLE up to 9 weeks with tem controls installed.porary condensing units and associated piping and Two of these units shall be functional during normal-operational conditions.

This is applicable during the time period from February 6,1998, 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 2 3/4 7-3 Amendment No. 222 l

SYSTEMS 3/4 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 involvino 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 1

on the HEPA filter or charcoal adsorber housing,lation zoneor (2) following painting, fire, or chemical release in any venti 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.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. 222 l

l I

',i INSTRUMENTATION 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 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 from the Area Radiation Monitoring System.

Upon receipt of a high radiation signal, the CBWVAC System is automatically realigned to o

the emergency mode of operation. ihe 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.

Protectica for chlorine gas events "overriles" 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 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).

ACTION Statements 90. 91, and 92 require isolating the control room and operating / Smoke Protection Mode, as appropriate.the CREVS in either the Chlorine Prot Radiation 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.

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 - UNIT 2 B 3/4 3-3a Amendment No.222l i

INSTRUMENTATION BASES 2!4.3.5 5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) l Acolica9ility 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 cnd initiate the Radiation / Smoke Protection Mude 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 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 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 required 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 chiorine 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 2 B 3/4 3-3b Amendment Nt.222)

INSTRUMENTATION BASES 3/4.3 5.5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Actions (Continued) division) in each tri) 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 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 trip system must actuate to initiate the automatic detection / isolation funct10n. The loss of a single chlorine detector means that the CREVS reliability is reduced beceuse 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.

Placing 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 valici radiation or smoke signal to initiate appropriate protective actions.

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

Multi le detectors in each of the zones provide the detection / isolation capabilit : however, detection by one detector in both zones is required to initiate th isolation function.

Having less than two detectors OPERABLE in a zone means the system reliability is reduced 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 rernaining 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 Radia+1on/ Smoke Protection Mode is a suitable compensatory action to ensure that the automatic external smoke protection function is not lost.

BRUNSWICK - UNIT 2 B 3/4 3-3c Amendment No.2221 6

INSTRUMENTATION BASES 3/4.3,5 5 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Syrvei llances Radiation Protection 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 CAllBRATION.

The CHANNEL CHEC( freauency is consistent with that performed for other radiation monitors with 1 solation 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 quarterly 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 CAllBRATION verifies the channel responds to the measured parameter within the necessary range and accuracy.

CHANE L CAllBRATION leaves the channel adjusted to ensure consistency with the system assumptions i

(Reference 5). The frequency of the calibration is consistent with the i

frequency of calibration of other radiation monitors with isolation functions, Chlorine Protection L

The CHANNEL FUNCTIONAL TEST is performed on each required chan:

( to ensure that the entire channel will perform the intended function. The Control Building HVAC DBD (Reference 5) defines 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 by other utilities with this type of instrumentation.

The CHANNEL CALIBRATION 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 the measured parameter within the necessary range and accuracy. The CHANNEL CAllBRATION leaves the channel adjusted to ensure consistency with the system assumptions (Reference 6).

The chlorine detectors use an amperometric sensor consisting of a olatinum cathode and silver anode joined by an 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 replaccment 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 CALIBRATION is performed in accordance with the requirements of the CREVS specification (4.7.2).

BRUNSWICK - UNIT 2 B 3/4 3-3d Amendment No222[

PLANT SYSTEMS s

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 basis events throughout the life of the plant.

The Control Building HVAC System must function to provide protection to the operators for three typ(e events:

a radiation event, u) to and including a Design Basis Accident e.g., Main Steam Line Break [MS B] Accident. Refueling Accident, Control Rod Drop Accident, or Loss of Coolant Accident [LOCA)). a toxic gas event (complete ru the Service Water Building, pture of the 55 ton chlorine tank car located near 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 C6HVAC 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).

During implementation of the Control Room Air Conditioning System re)lacement mooification, the CREVS may be considered OPERABLE with a temocrary 3arrier installed in the duct as part of the control room pressure boiandary.

The temporary ductwork barriers are required to be constructed to 3 reserve the leakage characteristics of the control room presure boundary:

10 wever, these i

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 Rcom 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 is available, assuming a single failure disables tne 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 OPEPABLE.

2.

HEPA filter and charcoal adsorbers are not excessively restricting flow and are capable of performing their filtration functions, and BRUNSWICK - UNIT 2 B 3/4 7-1c Amendment No. 222 l

9