ML20205L165
| ML20205L165 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/27/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| RTR-REGGD-01.052, RTR-REGGD-1.052 5211-86-2047, NUDOCS 8604030246 | |
| Download: ML20205L165 (46) | |
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GPU Nuclear Corporation Nuclear a=e=gr8o-o Middletown, Pennsylvania 17057 0191
'17 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
March 27, 1986 5211-86-2047 Office of Nuclear Reactor Regulation Attn: John F. Stolz, Director PWR Projects Directorate No. 6 U.S. Nuclear Regulatory Commission Washi ngton, D.C.
20555
Dear Mr. Stolz:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Fuel Handling Area Engineered Safety Feature Ventilation System In response-to the Commitnent in reference 1 and 2, GPU Nuclear Corporation is currently in the engineering design stage to modify the Fuel Handling Building ventilation _ system. GPU Nuclear is proceeding on a two-phase ventilation separation program. The first phase, already complete, involved a modification to the TMI-l Fuel Handling Building (FHB) layout. Additionally, the first phase also included the installation of isolation dampers in the ventilation supply and exhaust main ducts that serve the operating floor of the FHB. These dampers are interlocked to shut concurrent with shutting down the FHB supply fan on detection of high radiation on the FHB operating floor.
.The second phase of the ventilation separation program is to install a separate ESF ventilation system prior to the Cycle 6 refueling outage per GPUN commitment. The modification will consist of the following:
A.
Two 100% capacity filtration units will each consist of an electric heating coil, pre-filter, HEPA filter, charcoal adsorber, post-HEPA filter and exhaust fan instrumented locally, and at a control panel remote from the operating floor of the FHB.
Selt ted instrumentation will be provided in the control room.
The ESF filtration system components will be housed in an enclosure on the roof of the Auxiliary Building north of the chemical addition area.
B.
Ductwork to the inlet of the ESF filtration system will penetrate the north wall of the Fuel Handling Building.
Ductwork from the discharge of the filtration system will open directly to atmosphere through the side of the ESF Filtration Enclosure.
B604030246 860327 1
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PDR ADOCK 05000289 P
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation 1
5211-86-2047 The ESF ventilation system will operate continuously whenever TMI-1 spent fuel is being noved in the Fuel Handling Building.
Existing air monitors in the FHB exhaust duct will continuously sample the normal FHB HVAC exhaust.
The ESF filtration system discharge will be monitored by a high range noble gas monitor whenever this system is placed in operation.
Attachnent #1, excerpted from the System Design Description provides a detailed description of the modification. Tables A through C provide a point by point comparison of the requirements of Reg. Guide 1.52 and Standard Review Plans 6.5.1 and 9.4.2 with the THI-l FHB ESF ventilation systen design.
Included in the tables are notations where certain requirements are not applicable to the TMI-l design.
GPUN is presenting these project descriptions as information to the.NRC Staff. GPUN has initiated final engineering and begun procurement of various long lead. items during July,1985 and begun construction in Novenber,1985.
The current schedule for completion of the modification is prior to moving fuel during the Cycle 6 refueling outage.
t Sincerely, 1
D.bucill Director, TMI-1 HDH/MI/spb cc:
J. Thoma R. Conte Reference 1: Partial Initial Decision (PID)Section III.8, paragraph 1265, Vol. I dated December 14, 1981.
2:
GPUN Letter 5211-83-103, R. C. Arnold to J. F. Stolz
" Engineered-Safety-Feature (ESF) Filter System" dated March 31, 1983.
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Attachment No.1 Description of TMI-1 ESF Ventilation System for the Fuel Handling Building PURPOSE & SCOPE The normal TMI-l Auxiliary and Fuel Handling Building Ventilation System was designed in accordance with criteria in use at the time of the plant's design and construction. This system was designed to mitigate the consequences of a TMI-l postulated fuel handling accident. This design was deemed acceptable by the NRC in the Plant's Safety Evaluation Report dated July 11, 1973.
'The Fuel Handling Building ESF Ventilation System, however, is being added to TMI-l in accordance with a' commitment to the NRC. This commitment has been included in the NRC TMI-1 restart report, amendment 9, response to question -
52, supplement one, part two, and in accordance with the requirements of Short Term Order Item 4 of the THI-l Restart Safety Evaluation Report for the ventilation systems. See also memorandum and order modifying and approving NRC staff's Plan of Implementation dated April 5,.1982 and NRC list of conditions for the restart of TMI-1 (H.R. Denton letter dated October 2,1985).
The Fuel Handling Buildir;g ESF Ventilation System is being installed to contain, confine, control, mitigate, monitor and record radiation release resulting from a TMI-l postulated spent fuel accident in the Fuel Handling Building as described in FSAR, Section 14.2.2.1, Update 4, 7/85.
Normal operation of the Fuel Handling Building ESF Ventilation System will be during TMI-l spent fuel movements in the Fuel Handling Building. The system design shall include adequate air filtration and exhaust capacity to ensure that no uncontrolled radioactive release to atmosphere occurs. The system shall include effluent radiation monitoring capability powered from a reliable electrical power supply.
Existing TMI-1 radiation monitors are adequate for detection of the referenced fuel accident and initiation of a signal for automatic isolation of the TMI-l FHB operating floor ventilation system and tripping of the FHB supply fans.
As necessary, following an accident, the TMI-l Auxiliary and Fuel Handling Building Ventilation exhaust fans will be tripped manually by the TMI-l operator. This action will, under such conditions, stop any uncontrolled leakage to the Auxiliary Building.
TMI-2 normal ventilation exhaust will include Iodine filtration capability during THI-l spent fuel handling activities.
Should a TMI-1 Spent Fuel Accident occur in the FHB, the TMI-2 operator will manually trip the TMI-2 normal FHB ventilation fans after being notified by THI-1 operator about the accident.
Isolation dampers shall be provided in the TMI-2 supply and exhaust
ducts leading to and from the fuel handling operating floor. These will effectively isolate the TMI-2 FHB ventilation system from the fuel handling floor.
~
The manual isolation of the TMI-2 FHB Ventilation System is solely to provide the capability to discriminate between effluents resulting from Unit 1 and Unit 2 operations.
Operation of the TMI-2 FHB Ventilation System is not necessary for the proper functioning of the TMI-1 FHB ESF Ventilation System.
Since the Unit 2 Ventilation System will include iodine filtration capability, its operation during a fuel handling accident will mitigate the effects of the accident if it is operating at the time of the fuel handling accident and therefore its isolation need not be immediate.
Isolation of the Unit 1 and Unit 2 norral ventilation ducts from the fuel handling floor of the Fuel Handling Building as well as sealing of certain identified penetrations is necessary to enable the ESF ventilation system to maintain a negative pressure in the fuel handling floor with respect to adjacent surrounding areas. This will ensure a controlled, filtered and monitored release to atmosphere.
FUNCTIONS & DESIGN RE0VIREMENTS The functions of the Fuel Handling Building ESF Ventilation System are as follows:
1.
Reduce the possibility of airborne radioactive releases to the emironment by discharging the fuel handling floor exhaust air through a filtered, monitored, and controlled path.
2.
Serve as a means of collecting the radioactive release and processing the radioactive iodine and particulates from the postulated fuel handling accident to levels acceptable for the release to the environnent.
The Fuel Handling Building ESF Ventilation System shall be designed in accordance with the requirements of NRC Reg. Guide 1.52 and applicable sections of Reg. Guide 8.8 using the guidelines indicated in SRP Sections 6.5.1, 9.4.2 a nd 15. 7.4.
Specific design features shall be as contained in ANSI /ASME N 509.
In accordance with the TMI-l FSAR, Section 14.2.2.1.b, the design basis accident shall consist of damaging 56 rods. Based on this criteria, the theoretical radioactive isotope release for the design basis fuel handling accident is listed in Table 1.
The ESF Ventilation System is designed to monitor and mitigate the consequences of the effluent resulting from a 208 rod accident using RG 1.25 guidelines, as shown in Table 2.
The ESF Ventilation System shall be operated continuously whenever fuel handling operations are in progress. The critical operating parameters of the system shall be alarmed, indicated, and recorded at locations remote from the system filter components. Additionally, fuel handling accident indication by the Effluent Radiation Monitor shall be alarmed, indicated, and recorded in the TMI-l Control Room.
r Components of the ESF Ventilation System, including the filtration unit, fan, ductwork, dampers, damper operators, and associated instrumentation and controls shall be designed to function in the event of a loss of offsite power.
PROCESS REQUIREMENTS The process air entering the carbon adsorber section of the ESF Filtration Unit shall be maintained at or below 70% relative humidity. The components located in the ESF Ventilation System Enclosure and provided as part of the ESF ventilation system shall be designed for the following ambient conditions:
Temperature 120*F Max./10*F Min.
Pressure Atmospheric Relative Humidity 0-100%
40 Yr. Radiation Dose 6.7 x 105 Rads Equipment qualification aging temperature shall be based on the maximum ambient temperature stated above.
The heating and ventilating system for the ESF Ventilation System Enclosure shall be of sufficient capacity to maintain the enclosure environment within the range of 70*F to 120*F.
The ESF ventilation system components located in the Auxiliary Building shall be designed for the following ambient conditions:
Temperature 120*F Max./50*F Min.
Pressure Atmospheric Relative Humidity 0-100%
40 Yr. Radiation Dose 2.5 x 105 Rads The ESF Ventilation System shall be designed for a 150*F entering process air temperature from the fuel pool area. The design relative humidity of the process air shall be 100% at 150*F.
The carbon adsorber in the Filtration Unit shall be capable of retaining the organic iodines and elemental iodine radioactive isotopes generated as a result of the design basis fuel handling accident as specified herein.
STRUCTURAL REQUIREMENTS The ESF Ventilation System shall be located in an enclosure on the roof of the Auxiliary Building. The enclosure shall meet the applicable requirements of the Uniform Building Code and B0CA.
The Auxiliary Building structure has been evaluated for the additional loadings resulting from components of the ESF ventilation system under Seismic class I conditions as defined in the THI-1 FSAR Section 5.1.2.1.1.
No additional structural supports are required to accommodate the installation of the ESF ventilation system.
The components of the ESF Ventilation System and their enclosure are not required to be seismically qualified since their failure during a design basis seismic event would result in on-site and off-site doses below those of the criteria of.SRP 15.7.4 (25% of 10CFR 100 limits).
The following loads shall be considered in the support design for the ESF Ventilation System Enclosure and for the ductwork, conduit and tubing supports ~.
Dead Load:
Weight of equipment, components, conduits, tubing and structures Wind Load, Snow Load:
As defined in the TMI-l FSAR, Section 5.2.1.2.5 Seismic Load:
Not required Tornado Load:
Penetrations for ESF Ventilation System ductwork and conduit into the Fuel Handling Building wall shall be tornado missile protected and aircraf t hardened in accordance with Regulatory Guide 1.76, SRP Section.3.5.1.14 and SRP Section 3.5.3.
Natural phenomena velocity shall be per the FSAR, Section 5.2.1.2.5.
Loading combinations and. acceptance criteria shall be as defined in the applicable paragraphs of USNRC SRP Section 3.8.4.
Regulatory Guide 1.29 shall also apply as discussed in Table C.
Structural steel shall be designed in accordance with AISC, Specification for the Design, Fabrication and Erection of Structural. Steel for Buildings using ASTM A36 steel. Welding of steel shall be per AWS Dl.l.
Concrete work shall be in accordance with ACI 318.
Installation of concrete -
anchors shall be in accordance with GPUN. Specification SP-9000-33-001.
The redundant atmosphere filtration units shall be physically separated from each other with a heavy ~ gauge sheet metal wall to prevent direct flame impingement and limit fire damage to the second system.
The internal generation of missiles from rotating machinery failure shall be considered in the design for separation and protection.
SYSTEM CONFIGURATION AND ESSENTIAL FEATURES The ESF ventilation system shall consist of the components stated in NRC Reg.
Guide 1.52, Section C2a with the exception of demisters and cooling coils which are not required because saturated steam is not expected in the FHB operating floor.
Equipment features for the ESF vcntilation system shall be in conformance with ANSI /ASME N509.
A low flow air bleed system shall be provided in lieu of a water spray deluge system for the adsorber section of. the filtration unit.
The adsorber section shall use potassium iodide and triethylene diamine (TEDA) treated activated carbon.
Electric ~ resistance heaters shall be provided af ter the prefilters in the filtration unit. The heaters shall be sized to ensure that the relative humidity of the process air entering the carbon adsorber is a maximum of 70%.
Two redundant filtration trains shall be provided with a single effluent ductwork discharge point located just outside the ESF Filtration Enclosure at elevation 348'.
The system shall be capable of continuous operation whenever fdel handling operations are in progress.
The air intake for the ESF ventilation system from elevation 348' of the Unit 1 Fuel Handling Building (fuel handling floor) shall consist of two penetrations into the Fuel Handling Building north wall with each penetration provided with a 3-hour rated fire damper.
Each penetration shall be sized for the design system flow rate in case of inadvertent closure of one fire damper. Fire dampers shall meet the requirements of UL 555 for a three
-(3)-hour fire rating.
Each of the fire dampers shall be provided with an electro-thermal link actuated by its associated combustible gas detector.
The design flow rate of the ESF Ventilation System shall be nominally 6000 CFM. This flowrate shall consist of 5000 cfm being drawn from the fuel handling floor and 1000 cfm being drawn from outdoors for a low-flow air bleed for the inoperative filter train and for ventilation of the ESF Ventilation System. The 5000 cfm draw from the fuel handling floor is based on calculations reflecting the effect of the known infiltration paths as uncovered by walkdowns. This 5000 cfm flow will maintain the floor at a negative pressure with respect to the outside atmsphere. The above criteria has been established considering loss of the normal TMI-1 and TMI-2 Fuel Handling Building Ventilation Systems-and isolation of elevation 348' of the Fuel Handling Building from both the Unit 1 and Unit 2 Normal Ventilation Systems.
Isolation dampers are provided in the normal ventilation ducts of Unit 1 and shall be provided in the ventilation ducts of Unit 2 Fuel Handling Building Ventilation Systems wherever the ducts penetrate into elevation 348".
The 6000 scfm flow rate shall be maintained by modulating the fan inlet vanes..
r MECHANICAL REQUIREMENTS The requirements of ANSI /ASME H509 for an Engineered Safety Feature Ventilation System shall be met.
All new ductwork for the ESF ventilation system shall be designed, fabricated and installed in accordance with the SMACNA High Pressure Duct Construction Standards.
The SMACNA " Guidelines for Welding Sheet Metal" and AWS Dl.3, " Structural Welding Code-Sheet Metal", shall supplemnt the ductwork construction welding requirements of ANSI /ASME H509.
All electrically operated dampers, gravity dampers and the filtration unit cross-tie butterfly. damper shall be provided with position indicators for remote resdout of damper position at the local control panels.
The filtration unit housing shall be designed for a pressure of 20" w.g.
positive or negative and shall be fabricated of carbon steel, ASTM A569.
All drain piping for the filtration unit shall be fabricated in accordance with the requirements of ANSI B31.1 Prefilter and HEPA filter media shall be Class 1 Underwriters' Laboratories (UL) listed or Factory Mutual approved.
To prevent possible desorption and adsorbent auto ignition that may result from iodine induced heat in the adsorbent and concomitant temperature rise, an interconnecting duct between the two redundant filtration units shall be provided to bleed low-flow cool air to the inoperative unit.
The ESF ventilation system shall be a constant air volume system capable of maintaining a negative pressure on the operating floor of the FHB of both units and shall also be capable of continuous operation with or without the TMI-l and TMI-2 Auxiliary and Fuel Handling Building H&V Systems operating.
The ESF Ventilation System enclosure heating and ventilation system shall be designed to maintain the building environment in accordance with the criteria established in, " Process Requirements". Louvers, propeller fans and unit heaters of standard industrial non-reismic quality shall be utilized for heating and ventilating the enclosure.
In addition to the low flow air bleed system feature for the filtration units, the following fire protection / detection system features shall be provided in order to meet the general guidelines of-Appendix A to BTP 9.5-1:
(1) A non-combustible shield wall constructed of minimum 16 gauge steel shall be provided separating each ESF redundant filtration train. The purpose of this wall is to prevent direct flame impingement from one train to the other train.
(2) - A continuous thermistor thermal detection system shall be provided in accordance with ANSI /ASME N509 for sensing the airstream temperature immediately downstream of the carbon adsorber. The continuous thermistor thermal detection system shall provide for high and high-high fire detection temperature alarms.
(3) Manual hose stations are available in adjacent TMI-l Chemical Addition Building Area.
(4) The ESF ventilation system ductwork penetrations into the 348' elevation of the TMI-l Fuel Handling Building north wall shall be provided with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire dampers with electro-thermal links actuated by combustible gas analyzers.
(5) One (1) dry chemical portable fire extinguisher shall be provided in each ESF ventilation system enclosure room to meet the requirements of the Pennsylvania Fire Panic Code.
The ESF ventilation system is not required to meet 10CFR50, Appendix R requirements since the system is not required in order to achieve or maintain hot or cold shutdown conditions.
The enclosure housing the ESF ventilation system equipment'shall meet the requirements of the Pennsylvania Fire panic Code relative to means of egress.
INSTRUMENTATION AND CONTROL Train "A" or "B" equipment of the ESF Ventilation system shall be manually placed into service prior to and operated continuously during fuel handling operations. Manual starting of the ESF Ventilation, under this operating philosophy, is in compliance with Regulatory Guide 1.52.
The system shall be interlocked to shutdown automatically on receipt of an ES signal.
In accordance with Regulatory Guide 1.52, all instrumentation and controls
- essential to operation of the ESF Ventilation System, excluding the effluent radiation monitor, shall be designed to the criteria for protection systems set forth in IEEE-STD-279.
The ESF Ventilation System shall provide means to evaluate releases which result due to a Fuel Handling Accident. A continuous noble gas radiation detector shall be provided to monitor the ESF Ventilation System effluent.
The eff* uent monitoring system shall include provisions for continuous sampling of particulates and fodines and grab sampling for tritium. The effluent radiation monitor shall be designed in accordame with the requirements of Regulatory Guide 1.21 and Regulatory Guide 1.97 as applicable to Type E Variables / Category 2 Design and Qualification Criteria. Sampling techniques for airborne radioactive materials shall be in accordance with ANSI N13.1.
q A flow controller shall be incorporated in the system design in order to provide a constant system flow rate as the HEPA and prefilters load.. The controller shall modulate the inlet vanes on the exhaust fan to maintain the constant system flow rate. The maintenance of a constant flow rate shall facilitate effluent dose assessment; verification of actual flow rate is available via recording instrumentation at the Renote Control Panels.
In addition to the ANSI /ASME N509 required local and remote instrumentation, the following critical parameters shall be alarmed, indicated or recorded as indicated below, at redundant remote control panels located in the Auxiliary Buil ding:
(1) Recording and high/ low alarms for flow measurement.
(2) Position indication for automatic dampers.
In addition, high radiation in the effluent monitor shall be indicated, recorded and alarmed on Panel PRF in the Control Room.
Instrumentation and controls essential to the operation of the ESF Ventilation System shall be designated as Class 1E instrumentation and shall be qualified in accordance with IEEE-STD-323 and IEEE-STD-383 subject to the provisions of Regulatory Guide 1.89.
Class lE instrumentation shall be. qualified to operate in the environment of the ESF Ventilation System structure or the Auxiliary Building as applicable.
Test conditions shall envelope those environmental requirements specified as applicabl e.
Class lE. instrument and control cables shall be routed in seismically.
supported cable trays and/or conduit when located in structures which house equipment that must function af ter a seismic event.
Where appropriate, a suitable isolation device will be provided when portions of a Class lE system are connected to non-seismic components.
Local instrumentation and controls not essential for ESF Ventilation System operation shall not be required to be qualified as Class lE equipment. This instrumentation shall be of commercial grade and shall be installed so as not to create a missile hazard during a Safe Shutdown Earthquake (SSE).
The effluent radiation monitoring system shall be designed to meet the Category 2 qualification requirements of Regulatory Guide 1.97.
In accordance with Regulatory Guide 1.52, instrumentation and controls shall be designed to IEEE-STD-279; therefore the requirements of the Single Failure Criteria shall' apply.
In accordance with Regulatory Guide 1.97, the single failure criterion does not apply to the effluent radiation monitoring system.
As accepted in Regulatory Guide 1.53, the guidance in IEEE-STD-379 for applying the single failure criteria to the design and analysis of protection systems shall be followed for the system.
The instrumentation and controls essential for operation of the ESF Ventilation System shall be designed in accordance with the requirements of physical separation and electrical isolation of circuits as set forth in IEEE-STD-384.
Each ESF Ventilation System instrument channel essential for operation shall be energized from an independent vital power source.
Instrument installation, where applicable, shall meet the requirements of GPUN Specification SP-9000-44-001.
ELECTRICAL REQUIREMENTS The electrical power and control system shall meet the requirements of USNRC Regulatory Guide 1.52, Section 2h. All electrical equipment associated with the ESF Ventilation System shall be Class lE and shall be qualified for operation in the associated environments specified in accordance with the requirements of IEEE-STD-323. The following ESF Ventilation System Class lE electrical equipment shall meet the requirements of the respective IEEE
~ Standards as follows:
Fan Motors
- IEEE-STD-334 Damper Operators - IEEE-STD-382 Wiring
- IEEE-STD-383 All Class lE electrical equipment which must function af ter a seismic event shall be seismically qualified in accordance with IEEE-STD-344 as modified by Reg. Guide l.100. Standard criteria for independence of Class lE electrical equipment and circuits shall be in accordance with IEEE-STD-384.
In addition to the above stated requirements, the redundant power circuits for each _ESF fan and filter preheater as well as instrumentation circuits shall be designed and installed per the. requirements of GAI Specification 5616 and GPUN SDD-772A Electrical Cable and Raceway Routing.
The effluent radiation monitor shall be provided with a reliable power supply.
~
Loss of offsite power during a fuel handling accident shall not automatically cause the ESF ventilation system to be powered from the emergency diesel power supply. Manual loading capability shall be provided^in the local control panel remote from the FHB area.
' Due to-limitations on the 480 volt bus loading, both station auxiliary transformers and 4160 volt ESF buses must be operational during fuel handling operations.
Based on the above, there are no restrictions on the ESF ventilation system operability while Unit.1 is in operation other than when one of the station auxiliary transformers (or 4160V ESF bus) i.s out of -
service. This restriction does not apply if the reactor is shut down. -.
Controls shall be provided to automatically trip both ESF ventilating units upon actuation of an ES signal or loss of offsite power.
Emergency lighting and red paging communications system shall be provided at the local control panels.
The motors for the centrifugal fans shall meet the design requirenunts of GPUN Specification SP-9000-ll-001.
A ground loop shall be provided in the ESF Ventilation system building enclosure. All equipment and metallic structures shall be electrically connected to the ground loop.
The ground loop shall be connected to the plant ground grid by at least two separate connections.
The illumination levels in the ESF Ventilation System building enclosure during normal plant operation shall be at least 20 foot candles. Fluorescent lighting fixtures shall be utilized for the lighting system.
INTERFACING SYSTEMS The ESF Ventilation System will interface with the following systems:
1.
TMI-l Auxiliary and Fuel Handling Building H&Y System 2.
TMI-2 Fuel Handling Building H&V System 3.
THI-l Electrical Distribution System 4.
TMI-l Control Room Annunciators 5.
TMI-l Radiation Monitoring System The ESF Ventilation System electric power interface was described previously.
Any control systems affected by this modification shall be reviewed and evaluated by Human Factors Engineering for adequacy of man-machine interface (MMI).
The inlet duct of the ESF ventilation systen shall be connected through the north wall of the TMI-l Fuel Handling Building operating floor. Fire dampers shall be provided at the Fuel Handling Building which will automatically close upon detection of combustible vapors from a TMI-l postulated airplane accident. The ESF ventilation system discharge duct shall discharge directly to atmosphere.
The initial design bases with respect to Auxiliary and Fuel llandling Building integrity shall be maintained.
MAINTENANCE The maintenance requirements of NRC Reg. Guide 1.52 Section C4 shall be applicabl e.
In addition, to maintain radiation exposures to operating personnel as low as is reasonably achievable (ALARA) during plant maintenance, the ESF atmosphere cleanup system shall be designed to control leakage and facilitate maintenance in accordance with the guidelines of Reg. Guide 8.8.
SURVEILLANCE AND IN-PLACE TESTING Surveillance during' normal operation and post accident operation shall be accomplished by observation of the instrumentation in the remote control panel and at the filtration unit.
In-place testing shall be accomplished as discussed in USNRC Reg. Guide 1.52 Rev. 2 Sections C5 and C6.
Design requirements shall include the appurtenances and connections described therein. Sampling and injection ports shall also be provided.
TESTING REQUIREMENT The ESF ventilation system filtration unit, centrifugal fan, dampers and ductwork system shall be tested in accordance with the requirements of ANSI-N510-1980 for both initial testing as well as subsequent periodic functional testing.
Sufficient space / access shall be provided for maintenance and tes~ ting of ESF ventilation system components.
The filtration unit housing shall be leak tested at the manufacturer's facility to a negative pressure of 25 inches of water.
Fan and motors shall be tested as a complete assembly to provide characteristic performance curves and sound power level data.
Ratings shall be in accordance with AMCA Standards 210 and 300.
SAFETY, HEALTH, AND SECURITY REQUIREMENTS
~
The impact on the safety and health of the public and plant personnel shall be minimized by meeting the requirenents of NRC Regulatory Guide 1.52, Rev.' 2, especially Sections Cla, b, c and C2j.
The system does not impact the security of the plant.
The rules and regulations of 10 CFR 73 Section 73.55 shall be adhered to as specified in the Three Mile Island Security Plan.
A fire hazards analysis shall be performed to evaluate the impact of this addition to the existing fire hazards analysis and to the safe shut 6own capability of the plant.
A nuclear safety and environmental impact evaluation shall be performed for the addition of this system. _.
QUALITY ASSURANCE The ESF Ventilation System Motor Control Centers (MCCs) shall be classified as
" Nuclear Safety Related (NSR)". As the circuit breakers of these MCC's serve as the isolation devices between NSR/non-NSR systems, all work associated with their' procurement, installation, and wiring is also classified as "NSR."
The work related to the new penetrations in the Fuel Handling Building / Auxiliary Building, (which is a Safety Related Class I Structure), shall be classified as " Nuclear Safety Related (NSR)." All other work necessary to implement the ESF Ventilation System, except as noted below, shall be classified as "Important to Safety (ITS)".
All work associated with the ESF Ventilation System Enclosure Heating and-Ventilating System, the Enclosure Lighting and the combustible gas detectors associated with the fire: dampers shall be classified as "Not Important to
- Safety (NITS)".
Based on the above, the quality assurance requirements shall be in accordance with the "GPUN Operational Quality Assurance Plan" LICENSING AND REGULATORY REQUIREMENTS This system shall be designed and installed to comply with the NRC Regulatory Guide 1.52, Rev. 2 as amplified in the body of this document and to satisfy TMINS Unit i restart report amendment 9, response to question 52, supplement one,'part two. This system will also satisfy the requirements of Short Term Order Item 4 of the TMI-l Restart Safety Evaluation Report for the ventilation systems.
The enclosure housing the ESF ventilation system equipment shall meet the applicable requirements of UBC, BOCA and the Pennsylvania Fire and Panic Code.
HLMAN FACTORS A Human Factors engineering review of all controls, instrumentations and alarms shall be performed prior to construction to assure that man-machine interface 'MMI) is adequate.
TABLE 1 FSAR SOURCE TERMS (a)
ISOTOPE
' ACTIVITY (Ci)(b)
KR-85m 1.45E-3(c)
-85 1.78E+3
-87 Negligible
-88' Negligible Xe-131m 1.75E+2
-133m 9.45E+1
-133 1.48E+4'
-135m Negligible
-135 4.01E-1 1-1 31 2.61 E+3
-132 Negligible
-133 6.78E+1
-1 34 Negligible
-136
- 1. 73 E-1.
(a) FSAR source term: The source term consists of the fuel rod gap activity of 56 rods from the hottest fuel assembly 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> af ter reactor shutdown.
.(b) Activity in the gap (100% gap activity in 56 rods).
(c)- Read as 1.45 x 10-3 l
i 1
TABLE 2 MECHANICAL DAMAGE ~TO ALL 208 RODS IN AN ASSEMBLY ISOTOPE ACTIVITY (Ci){b)
KR-85m 2.39E+0(c)
-85
-7.60E+3
-87 Negligible
.-88 Negligible Xe-131m 4.42E+3
-133m 1.17E+4
-133 8.41 E+5
-135m Negligible
-135 1.12E+3 I-1 31 4.78E+5
-132 Negligible
-133
- 1. 29 E+5
-134 Negligible
-135 9.43 E+2
'(a) FSAR source term combined with R.G.1.25 guideline: The source term consists of fuel rod gap activity combined with the noble gases and iodine inventory of all 208 rods from the hottest assembly 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> af ter reactor. shutdown.
(b) 100% activity in the gap and fuel matrix.
0 (c) Read as 2.39x10,
n SRP 9.4.2 - Review Requirement Page 1 of 3 Per SRP Section 9.5.1 FIRE PROTECTION The following is a discussion of the fire protection philosophy to be ertployed in the construction of the ESF filtration units.
Regulatory Requirements 1.
Appendix A to BTP APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants Docketed refor to July 1,1976," para. D.l(a)(2) (Plants Under Construction or Operating) requires that A.
" Redundant safety related systems that are subject to damage f rom a single fire hazard should be protected by a combination of fire retardant coatings and suppression systems, or (b) a separate system to perform the safety functions should be provided." OR B.
" Separate redundant safety related. systems from each other such that both are not subject to damage from a single fire hazard."
2.
Appendix R to 10CFR50 covers general fire protection requirements in two locations with respect to the ESF ventilation system.
A.
Introduction and Scope
" Redundant systems used to mitigate the consequences of other design basis accidents but not necessary for safe shutdown shall be provided so that a fire within only one such system will not damage the redundant system."
B.
Section IIIG1
" Fire protection features shall be provided for structures, systems and components important to safe shutdown. These systems shall be capable of limiting fire damage so that a) One train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station is free of fire damage; and, b) Systems necessary to achieve and maintain cold shutdown from either the Control Room or emergency control station can be repaired within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />."
Discussion It is clear from the above requirements that Section IIIG1 of Appendix R is not applicable as the Fuel Handling Area ESF ventilation system is not required to achieve hot and/or. cold shutdown.
L
Page 2 of 3 The Introduction and Scope section of Appendix R is not applicable either since operating plants with previous SERs from the NRC against Appendix A to BTP 9.5-1 are required to conform to the requirements of Sections IIIG, IIIJ and III0 of Appendix R.
However, the discussion below will describe how features of the design will achieve this end.
TMI is required to comply with Appendix A to BTP 9.5-1.
The requirement as specified in l A above is applicable because TNI Unit I was operating in 1976.
The principal combustible of the ESF filtration system is the charcoal which is utilized for iodine retention.
Each filtration unit will be equipped with an adsorber section. The design of each adsorber section incorporates a low flow air bleed system over the inactive bed to prevent charcoal auto-ignition that may result from radioactivity-induced heat in the bed as required by Reg.
Guide 1.52, section 3K.
In addition, each bed will be equipped with thermal detectors set to alarm below the iodine desorption temperature of the charcoal.
Note that desorption temperature is approximately 300*F below the ignition temperature.
Since charcoal is contained within a housing, and filtration units will be separated by a heavy gage sheet metal wall, it is not credible to assume that a fire in one unit induced by conditions other than iodine decay can cause damage to its redundant counterpart.
The wall.will act as a flame impingement shield.
In addition, the walls of the charcoal bed serve as an additional shield should the charcoal ignite.
A fire in the fan will be less severe than a charcoal fire since combustibles associated with the fan and its motor will be less than the charcoal loading.
Therefore, the wall between the filtration units need not be a rated fire barrier. The planned arrangement of the ESF filtration system therefore meets the intent of Appendix R in that a fire originating in one train of the system will limit damage to the other train.
The requirement of Appendix A to BTP 9.5-1 as specified in l A above is met because a separate system is available to perform the safety function if a single fire hazard impacts both ESF filtration systems.
The existing auxiliary and fuel handling exhaust ventilation system, while not meeting the requirenents of an ESF system, will mitigate the consequences of a fuel handling accident assuming that a fire damaging both ESF units does not occur concurrent with a loss of offsite power.
Note that these units will be located on the roof of the Auxiliary Building away from any fixed hazards.
The wall of the chemical addition area adjacent to one of the filtration units is a rated fire barrier. The likelihood of a single fire hazard impacting both units is remote.
Also note that an airplane crash which could create a single fire hazard for both units has been considered and dismissed because the system is not required for safe shutdown of the plant in the event of an aircraf t impact, and an aircraf t impact concurrent with a fuel handling accident is not considered a credible accident.
Page 3 of 3
'Concluston The features design to preclude a fire in one unit from impacting its
' redun' dant unit are adequate; namely, the design of a flow air bleed system to prevent auto-ignition of charcoal induced by iodine decay, thermal detection on the charcoal beds, containment of. charcoal in a filter housing and separation of each filtration unit by a physical (though unrated) barrier.
In addition, the potential for a single fire hazard to impact both units is
? remote due to the location of the units remote from fixed fire hazards.
1 TABLE A
PAGE 1 of.16 4
ESF VENTILATION FILTER UNITS C0pFLIANCE TO REG.' GUIDE 1.52 REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA C0f9LIANCE DESIGN-ALTERNATE DESIGN /REMRHKS 1.
Environmental Design Criteria a) The design of an engineered-safety-feature a) ESF ventilation system is designed to the atmosphere cleanup system should be based on following environmental conditions:
5 rads the maximum pressure differential, radiation 40 yr. rad dose - 6.7 x 10 dose rate, relative humidity, maximum minimum Asb. Temp. - 120'F max.
10*F min.
temperature, and other conditions resulting from the postulated DBA and on the duration Rel. Humidity 100%
of such conditions.
Process Temp. - 165*F max.
b) The design of each ESF system should be based b) The ESF filtration units are housed in a on 'the radiation dose to essential' services in separate enclosure located on the roof the vicinity of the adsorter section, inte-of aux. bldg. No other ESF systems share grated over the 30-day period following the the same enclosure, therefore shielding postulated DBA. The radiation source term to protect other ESF systems is not should be consistent with the assumptions found required.
in R.G.1.3,1.4 and 1.25.
Other engineered safety feature including pertinent components of essential services such as power, air, and control cables, should be adequately shielded from the ESF atmosphere cleanup systems.
c) The design of each adsorter should be based on c) The charcoal adsorters will be designed the concentration and relative abundance of the based on the iodine concentration iodine species (elemental, particulate, and
. released during fuel handling accident.
organic), which should be consistent with the assumptions found in R.G.1.3,1.4, and 1.25.
r
' TABLE A-
' PAGE 2 of 16 4
ESF VENTILATION FILTER UNITS COPPLIANCE TO REG. GUIDE 1.52. REV. 2 REG.' GUIDE 1.52 ACCEPTANCE CRITERIA C0ffLIANCE DESIGN ALTERNATE DESIGN / REMARKS d) The operation of any ESF atmosphere cleanup d) Since the FHB ESF ventilation system is system should not deleteriously affect the a completely separate system, operation operation of other engineered safety features of this system will. not deleteriously such as a containment spray system, nor should effect other safety systems. Upon ES the operation of other engineered safety signal receipt, this system is automatically features such as a containment spray system cutoff from emergency diesel power.
deleteriously affect the operation of any ESF Manual loading onto diesel power is required atmosphere cleanup system.
when sufficient power is determined to be available, e) Components of systems connected to compartments. e) The enclosures for the ESF ventilation that are unheated during a postulated accident system are provided with heaters to main-s>ould be designed for post-accident effects tain a minimum temp. of 70*F. The maximum of both the lowest and highest predicted amb. design temp. is 120*F. However, r
temperatures, all safety related components will be quali-fled at 10*F min. ano 120*F max.
2.
System Design Criteria
-).
i a) ESF atmosphere cleanup systems designed and a) The ESF filter units are not provided installed for the purpose of mitigating accident with desisters because the presence of doses should be redundant. The systems should water droplets is not anticipated in consist of the following sequential components:
the air stream during a fuel handling -
(1) demisters, (2) prefilters (demisters may accident. All other system components service this function),'(3) HEPA filters before as listed in R.G.1.52 are provided.
the adsorters, (4) iodine adsorters (impregnated activated carben or equivalent adsortent such as-metal zeolites), (5) HEPA filters after the adso6ers, (6) ducts and valves, (7) fans, and (B) related instrumentation. Heaters or cooling cofis used in conjunction with heaters should be used when the humidity is to be controlled before filtration.
.i
TABLE A PAGE 3 of 16 ESF VENTILATION FILTER UNITS COWLIANCE TO REG GUIDE 1.52. REY 2 REG. GUIDr 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS b) The redundant ESF atmosphere cleanup systems b) The. redundant ESF filter units are physically b) There is no high energy pipe near should be physically separated so that damage to separated by a sheet metal. wall and spatial the ESF filter system. The only one system does not also cause damage to the distance of 10 feet '
rotating machinery nearty is the second system. The generation of missiles from fan of the ESF system enclosure, high pressure equipment rupture, rotating Missiles generated by the rotating machinery failure, of natural phenomena should fan will be stopped by the fan be considered in the design for separation and.
casing. Natural phenomena was protection.
considered by stopping fuel move-ment activity in the event of hurricane or tornado warnings.
Therefore, no protection for. high energy rupture and natural phenomena is provided, c) All components of an engineered-safety-feature c) Since a seismic failure of ESF components atmosphere cleanup system should be designated during a design basis accident would result as Seismic Category I (see R.G.1.29 (Ref. 8))
in onsite and offsite doses below the if failure of a component would lead to the criteria of SRP 15.7.4 (25% of 10CFR100 release of significant quantitles of fission limits), it is not required that the ESF products to working or outdoor environments, vent system be designated Seismic Category I.
d) If the ESF atmosphere cleanup system is subject d) Not applicable, d) There is no pressure surge associ-to pressure surges resulting from the postulated ated with the design basis fuel accident, the system should be protected from handling accident.
such surges. Each component should be protected with such devices as pressure refef valves so that the overall system will perform its intended function during and after the passage of the pressure surge.
I
w,,~
m f
5
-TABLE A'
' PAGE 4 of 16
- y ESF VENTILATION FILTER UNITS C0rLIANCE :TO REG. GUIDE 1.52, REY. 2
-REG. GUIDE 1.52 ACCEPTANCE CRITERIA
- COWLIANCE DESIGN
' ALTEMATE DESIGN / REEKS e) In Je mechanical design'of the ESFl system the e) ~All components of the ESF filter system high radiation levels that may be associated iwill be designed and fabricated to with-
- with buildup of radioactive materials on the ESF stand the postulated radiation levels system components should be given particular -
that may be associated with the buildup consideration. ESF system construction of radioactive materials in the filter, materials should effectively perform their.
. intended function under the postulated radiation l evel s.
The effects of radiation should be con-.
sidered not only for the deelsters, heaters, HEPA filters, adsorbers, and fans, but also for any electrical insulation, controls, joining -
compounds, dampers, gaskets, and other organic -
containing materials that are necessary for operation during a postulated DBA.
f) The volumetric air flow rate of a single
. f) The air flow capacity lof the ESF venti-cleanup train should be limited to approxi-lation system is 6000 cfm. The HEPA mately 30,000 ft.3/ min. If a total-system filter layout is 3 high'and 2' wide air flow in excess of this rate is required,
. (sufficient for 6000 cfe),
multiple trains should be used. For ease of maintenance, a filter layout 3 HEPA filters high and 10 wide is preferred, g) The ESF atmosphere cleanup system should be g) High radiation recorder, indication and g): The ESF ventilation system will be -
instrumented to signal alam and record per-alarm,are provided in the control room.
provided with minimum instrumenta.
tinent pressure drops and flow rates in the tion indicated in Table 4-1 of control room.
ANSI-N509-1980 LA remote manual control panel is provided in Ifeu of monitoring the ESF ventilation system in the control room. '
TABLE A PAGE 5 of 16 ESF VENTILATION FILTER UNITS COPFLIANCE TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA C0ffLIANCE DESIGN ALTERNATE DESIGN / REMARKS h).The power supply and electrical distribution h) Complies: The redundant class lE power h) When one of the station aux. trans.
system for the ESF atmosphere cleanup system circuits for each ESF fan and filter (or' 4160V ESF bus) is out of described in Sec. C.2.a above should be de-preheater as well as instrumentation circuits service, and Unit 1 is operating, signed in accordance with R.G.1.32 (Ref. 9).
seet R.G. 1.52 requirements where applicable.
there will be no Unit 1 irradiated -
All instrumentation and equipment controls fuel movement. The ESF ventilation should be designed to IEEE Standard 279system will not be operated. Manual
( Ref. 10 ). The ESF system should be qualified loading capability onto the diesel and tested under R.G. 1.89 (Ref. 11). To the is provided in the event of a loss of extent applicable.
R.G.1.30 (Ref.12),1.100 offsite power.
(Ref.13) and 1.18 (Ref.14) and IEEE Stand.
334 (Ref.15).
f) Unless the applicable engineered-safety-feature
- 1) Automatic isolation of the FHB operating floor atmosphere cleanup system operates continuously is initiated by a signal from the 2 existing during all times that a DBA can be postulated to radiation monitors - one located in the FHB occur, the system should be automatically acti-exhaust duct and the other located under the vated upon. the occurrence of a DBA by 1) a fuel post bridge. The ESF filter system will redundant engineered-safety-feature signsi operate continuously when irradiated fuel is (i.e., temperature, pressure) or 2) a signal being moved in the FHB. Since the system will from redundant Seismic Category I radiation already be operating in the event of a DBA, monitors.
automatic actuation from a redundant high radiation signal is not required.
j) To maintain radiation exposures to operating j) To facilitate maintenance in accordance personnel as low as is reasonably achievable with R.G. 8.8 (ALARA), the ESF cleanup during plant maintenance, ESF atmosphere units are entirely enclosed and can be cleanup systems should be designed to control removed as a whole unit, leakage and facilitate maintenance in accordance with the guidelines of R.G. 8.8 (Ref.16). The ESF atmosphere cleanup train should be totally enclosed. Each train should be designed and installed in a manner that permits replacement of the train as an ' intact unit or as a minimum nunter of segmented sections without removal of individual components.
TABLE A PAGE 6 of 16' ESF VENTILATION FILTER UNITS C0FFLIANCE TO REG. GUIDE 1.52, REY.12 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COPFLIANCE DESIGN ALTERNATE DESIGN / REMARKS k) Outdoor air intake openings should be equipped k) For the makeup or intake air for room with louvers, grills, screens, or similar pro-ventilation, louvers are provided in tective devices to minimize the effects of high the wall of the building enclosure, winds, rain, snow, ice, trash and other contami-nants on the. operation of the system. If the atmosphere surrounding the plant could contain significant environmental contaminants, such as dusts and residues from smoke _ cleanup systems from adjacent coal burning power plants or.
industry, the design of the system should con-sider these contaminants and prevent them from affecting the cperation of any ESF atmosphere cleanup systea.
- 1) ES atmosphere cleanup system housings and duct-1) The leakage rate of the ESF filter housing work should be designed to exhibit on test a and ductwork will be in accordance with maximum total leakage rate as defined in Section Sec. 4.12 of ANSI-N509-1980. Leak testing 4.12 of ANSI-N509-1976 (Ref.1). Duct and of duct and housing will be in accordance housing leak tests should be performed in with Sec. 6 of ANSI-N510-1980.
accordance with the provisions of Sec. 6 of ANSI-N510-1975 (Ref. 2).
3.
Component Design Criteria and Qual. Testing a) Demisters should be designed, constructed, and
-a) Demisters are not provided since tested in accordance with the requirements of no water droplets are expected in Section 5.4 of ANSI-N509-1976 (Ref. ;l).
the air stream during a fuel handling Demisters should meet Underwriters' Laboratories accident.
(UL) Class 1 (Ref.17) requirements, b) Air heaters should be designed, constructed,' and b) Air heaters _ will be sized to maintain 701 tested in accordance with the requirements of
_ RH or less in the air entering the charcoal Section 5.5 of ANSI-M509-1976 (Ref.1),
adsorbers. Design and fabrication will be in accordance with Section 5.5 of ANSI-N509-1980.
TABLE A PAGE 7 of 16 ESF VENTILATION FILTER UNIT 3 COW LIANCE TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS.
c) Material used in the prefilters should with-c) Prefilters will be designed to withstand a stand the radiation levels and environmental temperature of 165'F and expected radiation conditions prevalent during the postulated DBA.
levels during a fuel handling accident.
Prefilters should be designed, constructed and Design fabrication and testing will be in tested in accordance with the provisions of accordance with Section 5.3 of Section 5.3 of ANSI-N509-1976 (Ref.1).
ANSI-N509-1980.
d) The HEPA filters should be designed, constructed d) The HEPA filter will be designed,' fabri-and tested in accordance with Section 5.1 of cated and constructed in accordance with ANSI-N509-1976 (Ref.1). ' Each HEPA filter Section 5.1 of ANSI-N509-1980. Acceptance should be tested for penetration of dioctyl
' testing of HEPA will be in aacordance with phthalate (DOP) in accordance with the pro-ANSI-N510-1980.
visions of MIL-F-51068 (Ref.19) and HIL-STD-282 (Ref. 20).
e) Filter and adsorter mounting frames should be e) HEPA filter and charcoal adsorter mounting constructed and designed in accordance with the frames will be designed and fabricated in provisions of Section 5.6.3 of ANSI-N509-1976 accordance with the provisions of (Ref. 1).
Section 5.6.3 of ANSI-N509-1980.
f) Filter and adsorter banks should be arranged f) The filter and adsorter banks will be in accordance with the recommendations of arranged in accordance with the recommen-Section 4.4 of ERDA 76-21 (Ref. 3),
dation of Section 4.4 of ERDA 76-21.
g) System filter housing, including floors and g) System filter housing, including floors and doors, should be constructed and designed in doors will be designed in accordance with accordance with the provisions of Section 5.6 the provisions of Section 5.6 of of ANSI-N509-1976 (Ref.1).
ANSI-N509-1980.
h) Water drains shoJld be designed in accordance h) Each compartment of ESF filter units will be with the recommendations of Section 4.5.8 of provided with'a drain. The drain from each of ERDA 76-21 (Ref. 3).
compartment will be valved and each drain will be piped to a common drain pipe which will be sealed with a bronze pipe plug. The
. plug can easily be removed when needed.
TABLE A PAGE 8 of 16 ESF VENTILATION FILTER UNITS COPFLIANCE TO REG. GUIDE 1.52 REV. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA C0pFLIANCE DESIGN
. ALTERNATE DESIGN / REMARKS i) The adsorter section of the ESF atmosphere
- 1) The charcoal adsorber will meet the qualiff-cleanup system may contain any adsorbent cation and batch test results sumarized in material demonstrated to remove gaseous iodine Table 5.1 of ANSI-N509-1980 The adsorber.
(elemental iodine and organic fodides) from air banks will be designed for an average atmos-at the required efficiency. Since impregnated phere residence time of 0.25 sec, per 2 inches activated carbon is commonly used, only this of adsortent bed.
adsortent is discussed in this guide. 'Each original or replacement batch of impregnated activated carbon used in the adsorber section should meet the qualification and batch test results summarized in Table 5.1 of ANSI-N509-1976 (Ref.1). In this table, a " qualification test" should be interpreted to mean a test that establishes,the suitability of a product for a general application, normally a one-time test reflecting historical typical performance of material. In this table, a " batch test" should be interpreted to mean a test made on a produc-tion batch of product to establish suitability for a specific application. A " batch of acti-wated carton" should be interpreted to mean a quantity of material of the same grade, type, and series that has been horogenized to exhibit within reasonable tolerance, the same performance and physical characteristics and for which the manufacturer can demonstrate by acceptable tests and quality control practices such uniformity.
q L
TABLE A PAGE 9 of 16-ESF VENTILATION FILTER UNITS COWLIANCE TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS i) All material in the same batch should be acti-(Cant'd) wated, impregnated, and otherwise treated under the same process conditions and procedure? in the same process equipment and should be pro-duced under the same manufacturing release and instructions. Material produced in the same charge of batch equipment constitutes a batch; material produced in differe1t charges of the same batch equipment should be included in the same batch only if it can be homogenized as above.
If an adsorbent other than impregnated activated carbon is proposed or if the mesh size distribu-tion is different from the specifications in Table 5.1 of ANSI-N509-1976 (Ref.1), the pro-posed adsortent should have demonstrated the capability to perform as well as or better than activated carbon in satisfying the specifica-tions in Table 5.1 of ANSI-N509-1976 ((Ref.1).
If impregnated activated carton is used as the adsorbent, the adsorber system should be designed for an average atmosphere residence time of 0.25 sec. per 2 inches of adsortent bed. The aasorbent unit should be designed for a maximum loading of 2.5 mg of total fodine (radioactive plus stable) per gram of activated carbon. No more than 5% of-impregnant (50 mg. of impregnant per gram of carton) should be used. The radiation stability of the type of carbon specified should be demon-strated and certified (see Section C.l.b of this guide for the. design source tern).
TABLE A PAGE 10 of 16 ESF VENTILATION FILTER UNITS COWLIANCE TO REG. GUIDE 1.52, REY. 2 ~
REG. GUIDE 1.52 ACCEPTANCE CRITERIA COW LIANCE DESIGN ALTERNATE DESIGN / REMARKS-j) Adsorter cells should be designed., constructed, j) The adsorber cells will be designed, and tested in accordance with the requirements contructed and tested in accordance of Section 5.2 of ANSI-N509-1976 (Ref.1).
with the requirements'of Section 5.2 of ANSI-N509-1980.
k) The design of the adsorter section should con-k) In the design of the adsorber section, sider possible iodine desorption and adsortent a low-flow air bleed system is provided auto-ignition that may result from radio-to prevent. iodine desorption and auto-activity-induced heat in the adsortent and ignition of adsortent. Low-flow air concomitant temperature rise. Acceptable bleed is effected by providing inter-designs include a lowflow air bleed system, connecting ducts with heaters between cooling coils, water sprays for the adsorber the suction plenums of each redundant section, or other cooling mechanisms. Any system.
cooling mechanisms should satisfy the single-failure criterion. A low-flow air bleed system should satisfy the single-failure criterion for.
providing low-humidity (less than 707, relative humidity) cooling air flow.
- 1) The system fan, its mounting and the ductwork
- 1) The system fan, its mounting and the duct-connections should be designed, constructed, work connections will be designed, con-and tested in accordance with the requirements structed and tested in accordance with of Section 5.7 and 5.8 of ANSI-N509-1976 the requirements of Section 5.7 and 5.8 (Ref. 1).
of ANSI-N509-1980 u) The fan or blower used on the ESF atmosphere m) The fan of the ESF ventilation system cleanup system should be. capable of operating will be designed to function during under the environmental conditions postulated, the postulated environmental. conditions including radiation.
and radiation.
TABLE A PAGE 11 of 16 ESF VENTILATION FILTER UNITS COMPLIANCE TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COMPLIAMCE DESIGN ALTERNATE DESIGN / REMARKS n) Ductwork should be ' designed, constructed, and n) Ductwork will be designed, constructe'd tested in accordance with thc provisions of and tested in accordance with the pro-Section 5.10 of ANSI-N509-1976 (Ref.1).
visions of Section 5.10 of ANSI-N509-1980 and SMACNA Standards.
c) Ducts and housing should be laid out with a o) Ledges, protrusions and crevices that could minimum of ledges, protrusions and crevices collect dust and moisture and that could that could collect' dust and moisture and that impede personnel and create a hazard to them could impede personnel or create a hazard to in the performance of their work will be them in the performance of their work, minimized in the fabrication of the ductwork.
Straightening vanes should be installed where required to ensure representative air flow measurement and uniform flow distribution through cleanup components, p) Dampers should be designed. constructed, and p) Dampers will be designed, constructed and tested in accordance with the provisions of tested in accordance with the provisions of Section 5.9 of ANSI-N509-1976 (Ref.1).
Section 5.9 of ANSI-N509-1980.
4.
Maintenance a) Accessibility of components and maintenance a) Accessibility and maintenance of the ESF should be considered in the design of ESF ventilation system will be designed in atmosphere cleanup systems in accordance with accordance with the provisions of the provisions of Section 2.3.8 of ERDA 76-21 Section 2.3.8 of ERDA 76-21 and Section 4.7 (Ref. 3) and Section 4.7 of ANSI-N509-1976 of ANSI-N509-1980.
(Ref.1).
1 TABLE A PAGE 12 of 16 ESF VENTILATION FILTER UNITS COWLIANCE TO REG. GUIDE 1.52. REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS b) For ease of maintenance, the system design b) Each component of the ESF filter unit will should provide for a minimum of 3 f t from be provided with maintenance access of mounting frame to mounting frame between banks 3 ft. plus the length of the component.
of components. If components are to be replaced, the dimension to be provided should be the maximum length of the component plus a minimum of 3 ft.
c) The system design should provide for permanent c) A permanent halide and DOP sampling ports test probes with external connections in accord-and injection ports will be provided to ance with the provisions of Section 4.11 of facilitate in place testing of HEPA ANSI-N509-1976 (Ref.1).
filter and charcoal adsorbers, d) Each ESF atmosphere cleanup train should be d). The ESF filter unit will be operated 10 hrs, operated at least 10 hrs. per month, with the per month and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to fuel movement heaters on (if so equipped), in order to reduce to remove / reduce the buildup of moisture in the build-up of moisture on the adsorbers and the adsorbers.
HEPA filters.
e) The cleanup components (i.e., HEPA filters, e) Filtration components will not be prefilters and adsorbers) should not be in-installed while construction is in progress.
stalled while active construction is still in progress.
5.
In-Place Testing Criteria a) A visual inspection of the ESF atmosphere a) The in-place testing specification will cleanup system and all associated components indicate that visual inspection of the should be made before.each in-place airflow cleanup unit will be performed prior distribution test, DOP test, or activated to in-place testing per ANSI-N510-1980.
carbon adsorter section leak test in accord-ance with the requirements of Section 5 of ANSI-N510-1975.
TABLE A PAGE 13 of 16 ESF VENTILATION FILTER UNITS COPPLIANCE-TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS b) The airflow distribution to the HEPA filters b) The airflow distribution to the HEPA and and iodine adsorbers should be tested in place iodine filters will be in-place tested in for uniformity initially and after maintenance accordance with ANSI-N510-1980 and with affecting the flow distribution.' The distri-the provisions of Section 9 of Industrial bution should be within +20% of the average flow Ventilation.
per unit.- The testing should be conducted in accordance with the provisions of Section 9 of "In<1ustrial Ventilation" (Ref. 21) and Section 8 of ANSI-N510-1975 (Ref. 2).
c) The in-place DOP test for HEPA filters should c) The in-place acceptance DOP test for HEPA -
conform to Section 10 of ANSI-N510-1975 filters will be in accordance with ANSI-(Ref. 2). HEPA filter sections should conform N510-1980. The requirements to DOP test to Section 10 of ANSI-N510-1975 (Ref. 2).
prior to use if not tested within the last HEPA filter sections should be tested in place 18 months and prior to use following a (1) initially, (2) at least once per 18 months fire, chemical release, or significant thereaf ter, and (3) following 9ainting, fire, painting will be included in the Tech. Specs.
or chemical release in any ves.tilation zone communicating with the system to confirm a penetration of less than 0.05% at rated flow.
An er.gineered-safety-feature air filtration system satisfying this condition can be con-sidered to warrant a 99% removal efficiency for particulates in accident dose evaluations.
HEPA filters that fail to satisfy this condi-tion should be replaced with filters qualified pursuant to regulatory position C 3.d of this guide. If the HEPA filter bank is entirely or only partially replaced, an inplace D0P test should be conducted. If any welding repairs are necessary on, within, or adjacent to the ducts, housing or mounting frames, the filters
4 j
TABLE A PAGE 14 of 16 ESF YENTILATION FILTER UNITS COWLIANCE TO REG. GUIDE 1.52, REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS c) and adsorters should be removed from the housing (C:nt'd) during such repairs. The repairs should be com-pleted prior to periodic testing, filter inspec-tion and in-place testing. The use of silicone sealants or any other temporary patching material on filters housing, mounting frames or ducts should not be allowed.
d) The activated carbon adsorter section should d) The activated carbon adsorter section will be leak tested with a gaseous halogenated be leak tested in accordance with ANSI-N510-
- iydrocarbon refrigerant in accordance with 1980. The requirements for later halide Section 12 of ANSI-N510-1975 (Ref. 2) to ensure testing will be satisfied as per Sc) that bypass leakage through the adsorber previously, section is less than 0.05%. After the test is completed, air flow through the unit should be maintained until the residual refrigerant gas in the effluent is less than 0.01 ppm. Adsorter leak testing sho.1 be conducted (1) initially, er 18 months thereaf ter, (2) at least once c (3) following removal of an adsorber sample for laboratory testing if the integrity of the adsorber section is affected, and (4) following painting, fire or chemical release in any ventilation zone conmiunicating with the system.
6.
Laboratory Testing Criteria for Activated Carton a) The activated carton adsorter section of the a) Adsorter section testing will comply with the a) The laboratory test acceptance ESF atmosphere cleanup system should be assigned requirements of Sections C.3.1 and C.S.d of criteria for carbon adsorbers the decontamination efficiencies given in the Guide. Sample testing will be per is = 90% methyl iodide minimum Table 2 for elemental fodine and organic fodides Table 2 of the Guide.
efficiency. This is consistent.with
'if the following conditions are met: (1) The TMI-l Tech. Spec. requirements for adsorter section meets the conditions given in othar carton adsorters laboratory regulatory position C.S.d of this guide.
testing in cleanup systems in the (2) New activated carton meets the physical plant.
j
TABLE A
. PAGE 15 of 16 ESF VENTILATION FILTER UI(TS COWLIANCE TO REG. GUIDE 1.52 REY. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS a) property specifications given in Table 5.1 of (Cer.t'd) ANSI-N509-1976 (Ref.1), and (3) Representative samples of used activated carbon pass the laboratory tests given in Table 2.
If the activated carbon fails to meet any of the above conditions, it should not be used in engineered-safety-feature adsorbers, b) The efficiency of the activated carbon adsorber b) Test cannisters for the carbon adsorber See remarks under 6-a.
section should be determined by laboratory laboratory test will be design similar testing of representative samples of the acti-to Type 2 test cannister shown in wated carbon exposed simultaneously to the Appendix A of ANSI-N509-1976, same service conditions as the adsorber Testing will comply with requirements section. Each representative sample should be of R.G.I.52 as applicable, not less than 2 inches in both length and diameter, and each sample should have the same qualification and batch test characteristics as the system adsortent. There should be a suffi-cient number of representative samples located in parallel with the adsorber section to esti-mate the amount of penetration of the system adsortent throughout its service life. The design of the samplers should be in accordance with the provisions of Appendix A of ANSI-N509-1976 (Ref.1). Where the system activated carbon is greater than 2 inches deep, each representative sampling station should consist of enough 2 inch samples in series to equal tw thickness of the system adsortent. Once repre-sentative samples are removed for laboratory test, their positions in the sampling array should be blocked off.
TABLE A PAGE 16 of 16 ESF VENTILATION FILTER UNITS COWLIANCE TO REG. GUIDE 1.52. REV. 2 REG. GUIDE 1.52 ACCEPTANCE CRITERIA COWLIANCE DESIGN ALTERNATE DESIGN / REMARKS b) Laboratory tests of representative samples should (C:nt'd) be conducted, as indicated in Table 2 of this guide, with the test gas flow in the same direc-tion as the flow during service conditions.
Similar laboratory tests should be performed on an adsorbent sample before loading into the adsorters to establish an initial point for j
comparison of future test results. The acti-vated carton adsorber section shoJld be replaced with new unused activated carbon meeting the physical property specifications of Table 5.1 of ANSI-N509-1976 (Ref.1) if (1) testing in accordance with the frequency specified in Footnote c of Table 2 results in a representa-tive sample failing to pass the applicable test in Table 2 or (2) no representative sample is available for testing.
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TABLE B' Page 1 of 4 ESF VENTILATION FILTER UNITS C0pFLIANCE TO SRP 8.5.1 SRP ACCEPTANCE CRITERIA C0f9LIANCE DESIGN ALTERNATE ' DESIGN / REMARKS II. Acceptance Criteria
--The installed ESF atmosphere cleanup system is needed to mitigate the consequences of postulated accidents by removing from the atmosphere radio-active material that may be released in the event of an accident. ETSB acceptance criteria for the ESF atmosphere cleanup systems a% based on meeting the relevant requirements of the following regulations:
a) General Design Criterion 19 as it relates to a) _ Habitability of control room is maintained systems being designed for habitability of the during a FH accident; when high radiation control room under accident and LOCA conditions.
is detected in the Control Building Ventilation duct, the Control Building will be placed in the emergency mode, b) GDC 41 as it relates to the design of systems to b) GDC 41 is not applicable to FHB be used for containment atmosphere cleanup Ventilation System.
following postulated accidents and to control releases to the environment.
c) GDC 42 and GDC 43 as they relate to the inspec-c) The redundant ESF cleanup units meet -
tion and testing of containment ESF atmosphere GDC 42 & 43. Access to the_ units on cleanup systems, the roof is provided through the Aux. Bldg.
d) GDC 61 as it relates to the design of systems d) The ESF Ventilation System meets the for radioactivity control under normal and requirements of GDC 61 and limits the postulated accident conditions.
radiological'ralease below the require-ments of 10CFR100.
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-a TABLE B Page 2 of 4 ESF VENTILATION FILTER UNITS COWLI ANCE TO SRP 6.5.1 SRP ACCEPTANCE CRITERIA C0WLIANCE DESIGN ALTERNATE DESIGN / REMARKS II. e) GDC 64 as it relates to monitoring radioactive e) The local effluent radiation monitor of the releases under normal, anticipated operational ESF Ventilation is to monitor the ESF exhaust occurrences and postulated accident conditions at all times when the ventilation system is from ESF atmosphere cleanup systems, operating. The normal exh. duct from the FHB operating floor has an existing rad, monitor to monitor the exhaust from the FHB during normal operation.
R11evant requirements of the Commission's
' The ESF ventilation system is designed to operate Regulations identified above are met by using the continuously during the design basis FH accident regulatory positions contained in R.G.1.52 as it and retain radioactive material after the related to the design testing and maintenance of accident. Design of filter units is in accordance ESF atmosphere cleanup system air filtration and with R.G. 1.52, adsorption units.
Specific criteria necessary to meet the relevant rcquirements of the Commission's regulations are as follows:
The ESF atmosphere cleanup systems should be The ESF system has a provision to prefilter air Since steam and water droplets are not designed so that they can operate after a design and meet the requirements of R.G.1.52 for char-expected in the fuel handling accident, basis accident (DBA) and can retain radioactive coal adsorption. ' Redundant filter units and demisters for moisture removal are not material after a DBA. The systems should have fans have been purchased to Seismic Category I provided.
prcvisions to prefilter air, remove moisture and requirements. Since the ESF system is operated meet the R.G. 1.52 requirements for charcoal continuously whenever TMI-l irradiated fuel is adsorption. The systems should be redundant, being moved, automatic actuation during a DBA is be designed to Seismic Category I requirements, not required. Flow rate of the system is be able to actuate automatically..and be limited 6000 cfm.
to an air flow rate of approximately 30,000 cfa.
TABLE B Page 3 of 4 ESF VENTILATION FILTER UNITS COWLIANCE TO SRP 6.5.1 SRP ACCEPTANCE CRITERIA C0W LIANCE DESIGN ALTERNATE DESIGN / REMARKS Design of instrumentation for ESF atmosphere The ESF system is designed in accordance with cleanup systems should conform to the guidelines of.. ANSI-N509-1980. Minimum instrumentation will be R.G. 1.52 and to the recommendations of ANSI-N509.
in accordance with Table 4-1.of ANSI-N509, in-Minimum instrumentation, readout, recording and pl9ce testing will be-in accordance with ANSI-alcre provisions for ESF atmosphere cleanup systems N510-1980.
are given in Table 5.5.1-1 of this SRP section.
Environmental design guidelines for acceptability Environmental design conditions are as cre based on the conditions following a DBA.
follows:
~
5' rads Rtdiation source terms should be consistent with 40 yr. rad. dose - 6.7 x 10 the guidelines in R.G. 1.3, 1.4, 1.7, and 1.25 Amb. Temp. - 120*F max; 10*F min.
(RIf, l., 2., 3., and 4 ).
Rel. Humidity 100% RH Process Temp. - 165'F Max.
Components such as desisters, heaters, pre-filters, All components of the ESF filter units will be HEPA filters, mounting frames, filter housings, designed, constructed and leak-tested in adsorbent, fans, ductwork and dampers should be accordance with ANSI-N509-1980, designed, constructed and tested in accordance with ANSI-N509-1980 and qualification testing criteria.
Water drain design and the accessibility of compon-ents and ease of maintenance should be in accordance esith the recommendations of ERDA 75-21 (Ref. 8) and ANSI-N509-1980.
Acceptability with respect to inplace testing should In-place testing of ESF filter units will be in Same as Table A Item 6(a) Page 14 of include meeting the requirements of ANSI-N510-1980 in accordance with the requiremuits of ANSI-16 (R f. 7) for laboratory testing of activated carbon N510-1980.
used as an acceptability criterion.
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wn TABLE B Page 4 of 4 ESF VENTILATION FILTER UNITS COPFLIANCE TO SRP 6.5.1 SRP ACCEPTANCE CRITERIA COW LIANCE DESIGN ALTERNATE DESIGN / REMARKS -
ETSB will accept the following deviations from the
' Not applicable, above acceptance criteria for the post loss-of-coolant accident (LOCA) ESF atmosphere cleanup system:
1.
If the calculated dose (sum of the long-ters.
doses from the LOCA and the purge dose at the low population zone outer boundary) is less than the 1
guidelines of 10CFR Part 100, no filtration system is required.
2.
If a radiofodine decontamination factor of 10 or less is needed for the calculated dose to be be-low Part 100, an atmosphere cleanup system that meets the acceptance criteria listed in Item 5 of Acceptance Criter'a in SRP Sec.11.3 is acceptable.
3.
If a radiofodine decontamination factor of greater than 10 is needed for the calculated dose to be below Part 100, the ESF atmosphere cleanup system l
meeting all of the above acceptance criteria with the exception of Items 2.b and 2.c of Part C of -
R.G.1.52, is acceptable.
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TABLE C Page 1 of 7 ESF VENTILATION FILTER UNITS COPFLIANCE TO SRP 9.4.2 SRP ACCEPTANCE CRITFRIA COPFLIANCE DESIGN ALTERNATE DESIGN / REMARKS I.
Argas of Review 1.
The ASB reviews the SFPAVS to determine the safety significance of the system. Based on this deterinination, the safety-related part of the system is reviewed with respect to functional performance requirements during normal operation, during adverse environmental occurrences, and subsequent to postulated accidents, including the loss of offsite power.
The ASB reviews safety-related portions of the system to assure that; a) A single active failure cannot result in a) Single failure of active components of atmos-a) When one of the station auxiliary loss of the system functional perfor1 nance phere cleanup units will not result in a loss transformers (or 4160V ESF bus) capability, of the system functional capability, is out of service and Unit 1 is operating, there will be no irra-diated fuel movement in the Unit 1 FHB. The ESF ventilation system will not be operated. The capability for manual loading onto the diesel is provided in the event of a loss of offsite power.
b) Failures of non-seismic Category I equipmer.t. b) Protection against seismic failure is not required for the ESF ventilation system (see Table C, II 2, page 5 of 7 Compliance Design).
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' TABLE C Page 2 of 7 ESF VENTILATION FILTER UNITS CoWLIANCE TO SRP 9.4.2 SRP ACCEPTANCE CRITERIA CoWLIANCE DESIGN '
ALTERNATE DESIGN /REERKS -
I.
2.
The ASB also reviews safety-related portions of the SFPAVS with respect to the following:
a) The capability to direct ventilation from a) In the event of a fuel hand 11pg accident areas of low radioactivity to areas of in Unit 1. Unit 2 FHB ventilation and Unit 1 potentially higher radioactivity.
FHB normal ventilation will be stopped.
Since the ESF exhaust is on the Unit 1. side, air movement will be from the Unit 2 side (cleaner area) to the Unit 1 side (contami-nated area) where the fuel handling accident occurred. In addition, Unit 1 Auxiliary Building normal ventilation will be manually stopped to prevent migration of contaminated air to the Auxiliary Building.
b) The capability to detect the need for isola b) The instrumentation and controls of the tion and to isolate portions of the system 2 redundant atmosphere cleanup units are in the event of failures or malfunctions, provided with the capability.to detect a malfunction and either automatically or manually isolate the malfunctioning system.
c) The capability to actuate components not c) - The ESF Ventilation System and its asso-norinally operating that are required to ciated controls and instrumentation will be operate during accident conditions and to operating during all movement of TMI-1 provide necessary isolation.
irradiated fuel in the FHB and will already -
be operating if an accident occurs. :The existing radiation monitors in the norinal FHB exhaust duct and in the Fuel Pool Bridge have the capability to initiate an isolation of the FHB operating floor during an accident.
7 TABLE C
-Page 3 of 7 ESF VENTILATION FILTER UNITS COWLIANCE TO SRP 9.4.2 SRP ACCEPTANCE CRITERIA C0W LIANCE DESIGN ALTERNATE DESIGN / REMARKS 3.
The ASB also perferns the following reviews under the SRP sections indicated:
a) Review of flood protection is performed a) The existing flood protection for the under SRP Section 3.4.1.
auxiliary and Fuel Handling Buildings is not changed.
b) Review of the protection against internally-b) There is no high energy pipe near the-generated missiles is performed under SRP ESF filter system. The only rotating Section 3.5.1.1.
machinery nearby is the fan of the ESF filter System. Missiles generated by the rotating fan failure will be stopped by the ESF system enclosure and fan casing, c) Review of the structures, systems and com-c) The existing external-missile protection for c) The ESF ventilation system is not ponents to be protected against externally '
the fuel handling building is.not changed, provided with externally-generated generated missiles is performed under SRP missile protection.
Section 3.5.2.
d) Review of high and moderate energy pipe d) There is no high and moderate energy.
breaks is performed under SRP Section 3.6.1, pipe located near the ESF ventilation system. Therefore, protection against high energy pipe break is -
not provided.
II. Acceptance Criteria Acceptability of the SFPAVS design, as described in the. applicant's Safety Analysis Report (SAR), is based on specific general design criteria and regulatory guides.
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TABLE C-Page 4 of 7 ESF VENTILATION FILTER UNITS COPFLIANCE TO SRP 9.4.2 SRP ACCEPTANCE CRITERIA C0pFLIANCE DESIGN ALTERNATE DESIGN / REMARKS II. The design of safety-related portions of the SFPAVS is acceptable if the integrated design of the system is in accordance with the following criteria:
1.
GDC 2, as related to the system being capable of withstanding the effects of earthquakes. Accept-ance is based on meeting the guidance of R.G.
1.29, Position C.l for safety-related portions and Position C.2 for non-safety-related portions.
Regulatory Position 1.
The following structures, systems and com-ponents of a nuclear power plant, including their foundations and supports are designed as Seismic Category I and should be designed to withstand the effects of the SSE and re:sain functional. The pertinent quality assurance requirements of Appendix B to 10CFR Part 50 should be applied to all activities affecting the safety-related functions of these structure, systems, and components.
1.p Systems other than radioactive waste manage-1.p There is no requirement to ment systems, not covered by items 1.a thru provide protection against 1.o above that contain or may contain radio-seismic failure (see Table A.
active material and whose postulated failure Item 2c Compliance Design),
would result in conservatively calculated potential offsite doses (using meteorology as recommended in R.G. 1.3, " Assumption's Used for Evaluating the Potential Radio-logical Consequences of A Loss of Coolant Accident for Boiling Water Reactors" and
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.I TABLE C
'Page 5.of 7 ESF VENTILATION FILTER UNITS COWLIANCE TO SRP 9.4.2 SRP ACCEPTAMCE CRITERIA COMPLIANCE DESIGN ALTERNATE DESIGN / REMARKS-1.p R.G.1.4 " Assumptions Used for Evaluat-(Cont'd) ing the Potential Radiological Conse-quences of a Loss of Coolant Accident for Pressurized Water Reactors" that are.
more than 0.5 rem to the whole body or its equivalent to any part of the body, 1.q The Class lE electric systems, including the 1.q The Class IE electrical components auxiliary systems for the onsite electric of the ESF filter unis are desig-power supplies, that provide the emergency nated as seismic Category I and electric power needed fo-functioning of designed to withstand the effects plant features included in items 1.a thru of a SSE and.0BE.
1.p above.
2.
Those portions of structures, systems, 2.
Since a seismic failure of ESF compo-or components whose continued function nents during a design basis accident would is not required but whose failure could result.in onsite and offsite. doses reduce the functioning of any plant below the criteria of SRP 15.7.4 (25% of feature included in items 1.a thru 1.q 10 CFR 100 limits), it is not required above to and unacceptable safety level or that the ESF vent system be designated could result in incapacitating injury to selsric category 1.
occupants of the control room should be designed and constructed so that the SSE would not cause such failure.
2.
GDC 5, as related to shared systems and compo-2.
The 2 redundant ESF ventilation units are 2.
However, since the Unit 1 operating nents important to safety.
dedicated to TMI-1 and are not shared floor will see the same atmosphere, with TMI-2.
operation of the Unit 2 FHB ventila-tion system will affect operation of the Unit 1 ESF ventilation system.
Upon_ detection of high radiation at the Unit 1 operating floor, the Unit 2 FHB ventilation system will ~
be manually shutdown.
w TABLE C
.Page 6 of 7-ESF VENTILATION FILTER UNITS C00FLIANCE TO SRP 9.4.2 SRP ACCEPTANCE CRITERIA C00FLIANCE DESIGN ALTERNATE DESIGN / REMARKS 3.
GDC 60, as related to the system capability to 3.
The ESF ventilation system of the FHB meets suitably control release of gaseous radioactive the provisions and guidance of R.G. 1.52.
effluents to the environment. Acceptance is based on meeting the guidance of R.G.1.52 and 1.40, as related to design, testing and main-tenance criteria for atmosphere cleanup system and normal ventilation exhaust system air.fil-tration and adsorption units of light-water-cooled nuclear power plants, Positions C.2, and C.1 and C.2, respectively.
4 GDC 61, as related to the systems capability to 4
The ESF ventilation system will be designed provide appropriate containment, confinament, and in accordance with the applicable sections of filtering to limit releases of airtorne radio-R.G. 1.25 and R.G. 1.52.
activity to the environment from the fuel stor-age facility under normal and postulated accident conditions. Acceptance is based on meeting the guidance of R. G. 1.13, as related to the design of the ventilation system for the spent fuel storage facility, position C.4.
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TABLE C Page 7 of 7 ESF VENTILATION FILTER UNITS COWLIANCE TO SRP 9.4.2 -
SRP ACCEPTANCE CRITERIA CO@LIANCE DESIGN ALTERNATE DESIGN / REMARKS Reg. Guide 1.13 C.
Regulatory Position 4
A controlled leakage building should C.4 The existing FHB meets all FSAR require-enclose the fuel pool. The building ments for the limitation of potential should be equipped with an appropriate radioactive material release. In addf-ventilation and filtration system to tion, the ESF Yentilation System has the limit the potential release of radio-capability of containing, mitigating, and active fodine and other radioactive measuring the releases of fission products materials. The building need not be from an accident in which the cladding of designed to withstand extremely high one complete fuel assembly (208 rods) is winds, but leakage sPould be suitably breached.
controlled during refueling operations.
The design of the ventilation and fil-tration system should be based on the assumption that the clattding of all of the fuel rods in one fuel bundle might be breached. The inventory of radio-active materials available for leakage from the building should be based on the assumptions given in R.G.1.25 "Assump-tions Used for Evaluating the Potential Radiological Consequences of a Storage Facility for Boiling and Pressurized Water Reactors."
.