ML20206T739

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Requests Review of Exception to FSAR App A,Reg Guides 1.52 & 1.140,to Allow Use of Silicon Sealant on ESF & non-ESF HVAC Ductwork as Permanent Sealant & Preclude Filter Housing Tests for post-LOCA Purge Filter Units
ML20206T739
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 07/02/1986
From: Miosi A
COMMONWEALTH EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.052, RTR-REGGD-01.140, RTR-REGGD-1.052, RTR-REGGD-1.140 1812K, NUDOCS 8607080216
Download: ML20206T739 (17)


Text

. - - _. - -.

_ Commonwealth Edison 72 West Adams Street, Chictgo, Illinois

' *' g/ Address Reply to: Post Offics Box 767

\j Chicago, Illinois 60690-0767 July 2, 1986 ROU !

Mr. Harold R. Denton, Director

! Office of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission J 'll '

Washington, DC. 20555 /

1 /

t mWMAN HOLTZINGM. P.C.

Subject:

Braidwood Station Units 1 & 2 s Exceptions to FSAR Appendix A [

Regulatory Guides 1.52 and 1.140 ,

NRC Docket Nos. 50-456 and 50-457

Reference:

August 26, 1985 H.L. Thompson Memo to J.A. Hind

Dear Mr. Denton:

! We are requesting a review o'. an exception to FSAR Appendix A. Regulatory Guides 1.52 and 1.140. These exceptions would allow the use of silicone sealant on ESF and non-ESF HVAC ductwork as a i permanent sealant and preclude filter housing tests for the post-LOCA purge filter units. Additionally clarification is made for carbon testing.

On the issue of silicone sealant is a general discussion of the appropriate sections of the Regulatory Guides, interpretation of the referenced NRC memorandum, technical justification of the use of sealants on Braidwood's ductwork, and proposed FSAR revisions.

Filter housing testing is no longer necessary as a result
of a design change at Byron Station coupled with administrative control by procedure for the operation of the Post-LOCA Purge Exhaust Fan. This has precluded positive pressure on the filter housing. The Post-LOCA purge housing will be a negative pressure housing. A housing leak test per the requirements of ANSI N510-1980 is not necessary. Included are FSAR Revisions.

h' 8607080216 860702 6 a

PDR ADOCK 0500 A

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4

, _ . , . _ _ . . . _ m .._ _. . . _ . , . _

Please address any questions that you or your staff may have concerning this matter to this office.

One signed original and fifteen copies and attachments are i

Provided for your review.

i Very truly yours,

,, k A. D. Miosi i

Nuclear Licensing Administrator

/klj cc: J. Stevens A

1812K 1

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ATTACHMENT Use of Silicone Sealant Discussion Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Position 3.n states that ESF ductwork should be designed, constructed and tested in accordance with the provisions of Section 5.10 of ANSI N509-1976. ANSI N509-1976, Subsection 5.10.4 states i

that longitudinal seams shall be either all welded, seal welded

! mechanical, or in accordance with SMACNA - High Velocity Duct Construction Standards (Pittsburgh Lock or Acme Lock Seam which utilize sealant) as required to meet structural and leak-tightness requirements of Paragraphs 5.10.3 and 4.12, respectively.

! Section 4.12 of ANSI /ASME N509-1976 states that ducts for 4

ESF Systems shall be welded, but Section 4.12 of ANSI /ASME N509-1980 l allows welded or flanged duct transverse joints and mechanical lock type longitudinal seams.

I Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Position 5.c states that the use of silicone sealants or any other temporary patching material on the ESF filters, housings, mounting frames, or ducts should not be allowed. i l

Regulatory Guide 1.140, Revision 0 (March 1978), Regulatory

) Positions 3.f and 5.c have the same wording as Regulatory Guide

1.52, Revision 2 (March 1978), Regulatory Positions 3.n and 5.c, i respectively (which are discussed above).

Regulatory Guides 1.52 and 1.140 prohibit the use of silicone sealants as " temporary patching material" to meet in -place DOP test requirements for HEPA filters. The Braidwood air cleaning ducts do not utilize silicone sealant for the purpose of meeting in-place DOP test requirements for HEPA filters.

The silicone sealant (GE SCS1200) which is used in the Braidwood air cleaning duct systems are primarily used to seal i mechanical lock type longitudinal seams and other locations listed  :

in Attachment A-1.

l The use of sealant to seal longitudinal seams has long been

' a recommended practice of SMACNA (Attachment A-2). The silicone sealants are not intended to be " temporary patching material". The

, sealants have demonstrated their resistance to high radiation

environments of up to 1 x 107 rads (Attachment A-3). In addition, j based on data from the Wyle Lab Data Bank, similar types of silicone l
sealants have a qualified life of more than 40 years in an.

! environment of 2000F (Attachmenta A-4 and A-5). The sealants at l Braidwood will be exposed to temperatures and radiation levels well

! below these conditions.

1

i 3

Justification ,

Based on the review of the reference memorandum, the

! primary concern seems to be the degradation of sealant used in systems that are to be leak-tested and the effect of leakage through degraded sealant on control room operator dose. Following is justification on the use of sealants on Braidwood ductwork of safety and non-safety-related systems which address this concern. ,

Ductwork in Safety-Related Systems The Auxiliary Building HVAC System (VA) and the Control Roon HVAC System (VC) are the only two safety-related systems that

consist of atmospheric clean-up filter systems. No leak tests are required for VA system ductwork as discussed in Appendix A of.FSAR,
exceptions to Regulatory Guide 1.52. No laak tests are required for VC System ductwork, as the entire control room HVAC system is within the protected boundary of the control room. Therefore, sealant degradation will have no impact on control room operator dose since I control room dose is not affected by air cleaning system duct leakage.

However, portions of radwaste Building HVAC System (VW)

Duct and Laboratory HVAC System (VL) duct which are under. positive 1

j i pressure are located in the Control Room boundary. Both VL and VW are non-safety related and are air cleaning systems. There is no sealant used on VW system ductwork portion that is within the i Control Room boundary. Based on radiological and health physics evaluation for normal operating mode, the maximum allowable leakage  ;

from the VL duct located in the Control Room boundary is determined to be 500 cfa. The actual leak test results of existing duct with

sealants showed a leakage of less than 65 cfm. As can be seen, there is considerable margin between tested and allowable leakage values that can be taken into account for any effects of potential degradation of sealant.

I In addition, on detection of high radiation at the Control Room intakes, all non-safety related systems that have duct work inside the Control Room boundary are automatically shutdown and hence, there is no impact on releases to the Control Room.

Ductwork in-Non-Safety-Related Systems Portions of ducts of the following systems are required to be leak-tested per the FSAR commitments in Appendix A for Regulatory l Guide 1.140 (Amendment 47).

l.- Positive pressure ductwork for the laboratory HVAC System (VL) exhaust filter unit outside the laboratory HVAC equipment room.

- - , - - , , - - . - r - - - - - , , - , - . - - _ _ . _ , ...-_m _, ,,,_m._,.m-.,y.,....,,.,,____,,,,.y-,._y_...% , -- - . , . , ,we.,,rw_..

2. The positive pressure ductwork from the Radwaste Building HVAC System (VW) exhaust filter unit in the Auxiliary Building.
3. The positive pressure ductwork from the volume reduction system area ventilation exhaust filter that is located in the Radwaste Building.
4. The positive pressure duct work from the post-LOCA purge filter unit.
5. All non-safety-related air cleaning system ductwork that is under positive pressure within the Control Roon boundary discussed under Ductwork in Safety-Related Systems.
6. TSC negative pressure duct sections outside the protected space where inleakage would not normally be filtered.

Sealante are used in duct sections in Items 1 through 5, and portions of ductwork of non-safety-related air cleaning systems that are not required to be leak tested. No sealant is used in TSC ductwork (Item 6), as well as portions of the Tnt duct system (Item 2) that is located within the Control Room boundary. The effect of leakage from VL ductwork into the Control Room was already discussed. All other non-safety system ductwork have no impact on Control Room operator dose. The positive pressure ductwork is after the filter units. Therefore, the exhaust air which may leak out of the ductwork has already been filtered. To impact the adjacent area,.the sealant would have to degrade and the filter unit would have to malfunction. This is highly unlikely, however, any potential degradation of sealant and coincidental increase in exhaust air radioactivity levels, would be detected by station personnel as part of CECO's station ALARA Monitoring Program. Station administrative procedures will be used in monitoring the ALARA Levels and provide any needed corrective action should excessive. leakage result in higher levels in areas of the plant severed by these ducts.

1812K-

I ATTACHMENT A-1 Typical duct locations where silicone sealants are used.

1. Fittsburg lock type longitudinal seams.
2. Companion angle joints in some locations.

i

3. S-clip type of traverse joint for ducts gauges 20, 22 and 24 i

(round duct).

4. Duct and fire damper sleeves connection.
5. Ductwork tee joints.

i

! 6. Access door attachment to duct plate.

I

7. Duct and fan connections to flexible connections.
8. Flexible. connections seams.
9. Instrument penetration into ductwork.
10. Duct pin hole repairs or duct opening patch plates.

I ,

, l l

l l

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ATTACHMENT A-2 CHAPTER 5 SEALANTS

'Nith the exception of continuously welded joints marketed specifically for ductwork, good quality and the machine-made spiral lock seam, all high curtain wall sealants are recommended for this velocity joints and seams must be made airtight application. Oil base caulking and glaring com-with some form of sealant. There is no single pounds should not be used since they lose their sealant which will be the best for all applications. bond and elasticity in as little as one year.

The selection of the most appropriate sealant will depend primarily on the basic joint design and Gaskets dso on application conditions such as joint posi- ,;f,  ;,,, g ,g, tion, clearances, etc. There are four general types truded forms of curtain wall sealants should be f sealants. used in flanged joints. Extruded sealants should have a cloth filler so that they will not be forced completely out of the joint by air pressure. For Many manufacturers market liquid sealants com- ease of application, gaskets should have adhesive pounded specifically for high pressure ducts. backing or otherwise be tacky enough to adhere They have the consistency of heavy syrup and can to the metal while assembling the joint.

be applied either by brush or with a hand or powered pump. Liquid sealants contain 40 to 60 Tapes per cent volatile solvents, therefore they shrink Adhesive backed cloth, plastic, or foil tapes are considerably when drying. They are recommended not recommended as the primary sealer for high for slip-type joints where the sealant fills the pressure joints. Tape should never be applied to small space between the overlapping pieces of bare metal nor to dry sealant The major value of metal. Where metal clearances exceed 1/16 inch, tape is in conjunction with a sealant. Its function teveral applications may be necessary to fill the is to prevent the liquid sealant from being blown voids caused by shrinkage or runout of the seal- out of the joint. If the duct is not be be pressurized ent. They are normally brushed on to round sfip _

y ,

joints and are pumped into rectangular slip joints. a lied, the use of tape is not absolutely neces-If a welded joint is to be used in conjunction with sary. The tape must be compatible with the wet a mechanical seam, a non-flammable sealant is sealant, that is, the tape's adhesive backing and recommended for the mechanical seam. the sealant must not react with each other so as to decrease their bonding abilities. As a practical Mastics matter, tapes can only be successfully applied to flat surfaces such as the round slip joint.

Heavy mastic type sealants are more suitable for application as a fillet or in grooves. Whenever Attempts to cover flanged joints with tape result possible, they should be applied by a pressure in folds and wrinkles which are very difficult to gun to the inside of the assembled joint so that make airtight.

the internal air pressure tends to force the sealant S ecific recommendations for the application of into the joint. sealants to various joints accompany the joint Mastics used on high velocity systems must have details in Chapters 2, 4 and 8.

excellent adhesion and elasticity. Although not PRECAUTION: USE LIQUIDS AND MASTICS IN WELL VENTILATED AREAS AND OBSERVE PRINTED PRECAUTIONS OF MANUFACTURERS!

SMACNA High Pressure Ovet Stenderde-Sed. Ed.

41

t ,

ATTACHMENT A-3 Table. Radiation Tolerance of HVAC Seal and Flexible Connection Material Radiation Generic Name/ Tolerance, Material Composition rad (C) Ref.

Silicone Construction Silicone 1 x 10 7 1 Sealant #SCS 1200 Elastomer Silastic 9732 994 Silicone 1 x 10 7 1

, Ventglas DuPont Neoprene 6 x 10 6 i Neoprene Neoprene 6 x 10 6 1 Style R-59241-0348 EDPM S x 107

  • 2 sheet Nylon reinforced **
  • EDPM displays a 50-60% decrease in " elongation at break point" when

, irradiated to this dose level.  ;

    • Nylon tolerance limit of 5 x 10 reinforcement, provgdedwithinthismaterial,hasaradiation (Ref. 1). It is not known how the overall mechanical properties are affected at a higher dose level.

References

1. W. A. Greenhow and J. H. Lewis, " Evaluation of Insulation Materials and Components for Use in Nuclear Radiation Environment, Phase I," NASA CR-2045, 1972.
2. R. F. Mattia and D. R. Luh, " Radiation Resistance of EPDM, Polychloroprene and Chlorosulfonate Polyethylene," presented at the Tri-State Regional Meeting of the Massachusetts, Connecticut and R.

I. Rubber Groups of the E. I. DuPont i Company, 1971.

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ATTACRMENT A-4 ..

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  • KEY 00510 WYLE LABORATORIE5 DATABAC-(

. MATERIAL AGING DATA GENERIC NAME SILICONE RUBBER RTV -

THIC<NE55 ,

SILASTIC 732 BRAND NAME - - SLODE 8956.635654

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INTERCEPT -11.499774E2 GENERIC ABB SIR .' 1A0 DOW CCRNING MAX AGE TEMP MANUFACTUEER .

1. .sce 0.77

. RAD XnGuD ACTV ENERGY' '

  • ACT ENG A.L.# 0295300 'l PARA.wETE9 50% ELONGATIGN '

028650

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REMARKS r .

033081 DRESS E. STER TO VIEW NEXT SCREEN ,

DATE . .

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2 TO RETURN TC SEEK MODE c.

DELETE

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WYLE LABORATORIES DATABANK

. MATERIAL AGING DATA 0295 63 A TEMPERATURE U.b. FILE E 40195, AUGUST 15. 1973. DOW CORNING.

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. 0285 80 RADIATICN "THE EFFEC ~ O~ NdCLEAR RADI'ATION ON ELA570*ERIC AND DLA5 TIC %-

TERIAL5." R. W. KING. ET AL.. BATTE6.uE RADIAT*C.N ET.ECT5 CE%TER.

REIC ' .8.EPORT NO. 21, SEDTEMBER 1. 1961.

DRESS. ENTER TO RETURM TO MATE 4*A_ D " 5 P'_ A -

ENTER ?

1 TO RETU~e! TO SEEK MODE DRINT KEY.TO P;I.NT DIS:_AY e

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B/B-FSAR AMENDMENT 47

.' APRIL 1986

, REGULATORY GUIDE 1.52

Revision 2, March 1978 DESIGN, TESTING AND MAINTENANCE CRITERIA FOR ENGINEERING-SAFETY-FEATURE ATMOSPHERE CLEANUP SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS i

The Applicant complies with the Regulatory Position with the following comments and exceptions keyed to paragraph numbers in Section C of the Position:

1.e (Deleted) (Note 1) 2.a Entrained water droplets are not considered credible due to significant quantities of ductwork with elbows.

Water droplets, if present, will impinge on ducts and drop out of vertical duct risers as the air enters exhaust plenums. However, the auxiliary building exhaust system does contain prefilters which can serve as demisters.

2.d (Deleted) (Note 1) 2.f The auxiliary building non-accessible area exhaust filter system consists of three built-up filter trains (one standby) with a capacity of 66,900 cfm each. For maintenance l purposes each train is divided into three banks with each bank sized for seven filters wide and three high. l The auxiliary building accessible area exhaust filter system has a capacity of 162,300 cfm. This system consists i of four built-up filter trains (one standby), and each train is divided into three banks. Each bank is sized l

for seven filters wide and three filters high.

2.g All ESF filter systems have local control panel airflow indication. In addition, the flow rate in each of the stacks is recorded at the local control panel. The airflow rate through the control room emergency makeup air filter units and_the auxiliary building and fuel handling building exhaust charcoal booster fans is continuously sensed.

A1.52-1 .

i '59 QM4-id-L-

, B/B-FSAR AMENDMENT 47 APRIL 1sB6 The differential pressure across all of the ESF filter unit fans is indicated on local control panels. High and low differential pressure, and fan trip annunciation is provided on the main control panel. The setpoints i

' for low and high differential pressure alarms will be such that flows at +10% of design flow will be alarmed at the main control panel in the form of low or high '

differential pressure.

The differential pressures across all HEPA filters are indicated on local control panels. In addition, the pressure drop across HEPA filters upstream of charcoal filters is recorded in the main control room. High differ-ential pressure across all HEPA filters is annunciated on the main control panel and on local control panels.

Upset conditions will therefore be identified to the '

control room operator allowing him to take appropriate action.

The auxiliary building exhaust flow rate and fuel handling building exhaust flow rate is continuously sensed by the exhaust stack airflow measuring equipment and recorded in a local control panel and by the plant computer.

2.j Filter trains are not designed to be removable from the building as an intact unit. The size of the train precludes shipment off-site and there are no facilities for on-site disposal of the intact unit. The filter elements are removable and can be disposed of through the solid radwaste system.

2.1 Filter Housings All of the auxiliary building and fuel handling building exhaust system filter housings are designed in accordance with ANSI N509-76. The housings are at negative pressure with respect to their surroundings and are located in auxiliary building general area which is a low airborne radiation environment. Any in-leakage from the general area will not adversely affect Appendix I releases.

Hence, the housings will not be leak tested to the ANSI

,N509 requirements. However, filter mounting leak tests will be performed in accordance with ANSI N510-80.

The control room emergency makeup air system filter housings are designed in accordance with ANSI N509-76. The filter housings are at negative pressure with respect to their surroundings, and are located within the control room boundary which is a habitable environment the same as the control room.- Any in-leakage will be from the control room environment and, therefore, will not adversely affect the quality of that environment; hence, the housings will not be leak tested to ANSI N509 requirements. However, filter mounting frame tests will be performed in accordance with ANSI N510-80.

A1.52-2

&a;dmod

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/

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/ g-FSAR AMENDMENT 47 i APRIL 1986 Ductwork All auxiliary building and fuel handling building exhaust system ductwork upstream of the filter units is under negative pressure with respect to its surroundings and .

is located in the same areas of the buildings served by the exhaust systems. Any in-leakage will be filtered  !

prior to discharge to the atmosphere, hence, this ductwork will not be tested to ANSI N509 requirements. l However, prior to the final system turnover, the non-accessible exhaust system of the auxiliary building HVAC system and the fuel handling building exhaust system j will be operated and the ductwork will be visually and audibly checked for leaks. Leaks will be sealed.

i All control room emergency makeup' air system ductwork is located within the control room boundary which is i a habitable environment. Any ductwork leakage will not 1 adversely affect the habitability of the environment,  !

4 hence, requirements. However this ductwork will not be tested to ANSI N509 i prior to final system turnover, '

the control room emerge,ncy makeup air system will be operated and visual and audible leaks in ductwork will

.be sealed.

The design airflow quantities for each system will be verified during testing, adjusting and balancing of the systems.

Deviations of more than + 10% of the design flow quantities will be evaluated and any disposition will be documented.

2.m r- 3. n . Due+~or k is des; pas, coat <,sa, (Deleted) (Note 1) I ,,,g m fg 7,  % fj,, .g  ;

3.b (Deleted) (Note 1) o Su #e n S. i D of AN.5I l NS0*n - m % . De to ,)itudio'sI sea,$

3.d (Deleted)' (Note 1) h o *t * , will be ti+her S t.I welde 3.e (Deleted) (Note 1) or mecha nica/ /oeg fyj, (p;ff, g, I*'k *'Ith S**len p ), l 3.h (Deleted) (Note 1) S;j,cos,e Sealois t l i5 Wd e c. Fred 3.1 w%p (Deleted) (Note 1) E#' N "4' d"' N8'k .

4.b The space provided between components is 3 feet from the front (or rear) of the components to the nearest {

obstacle (filter frame or other filter component) . This allows 3 feet of access between components.

4.c (Deleted) (Note 1) i A1.52-3 '

- --r.-- - - . . - _ _ _ - , , . _ , . _ , , . - _ , . . _m.,..-..-....__.._._.,,,,,_.._._,.,_,,.,,.,,,....._w.,m,., ._.m., ,.....m._._.m._.,,... . , . . -

9 - ~...

, . ~

Brnlchwasel

' ~

AMENDMEN2 47

. /f-FSAR APRIL 1986 5.b Airflow distribution tests will be performed to ensure that the airflow through any individual filter element does not exceed 120% of the element's rated capac!.ty. I 5.c Sil;<one sealant or 0+Mr

    • t*(lat win eat se usag ;, ntemporary p e esp .to,ta4,pu) naas.ns s. sis,aa-a so.ia 1 ;s
a. pei .na,,2 i

Further discussions 9.4.1.2 and 12.3.1.7. on this subject can be found in Subsectionsus.4, sa ma<, a s sta/** 69 Hvdc Note 1: dm+merk.

Exception to this section is no longer required because

.the Regulatory Guide has been revised to eliminate the criteria to which exception was originally taken.

i (p . < (a)

All catkon fv/nished Priet to 19 6 **3

+he ori insI P*'+ O S g sfec;flcs tlon fat *ft"*3/heric clean- up 4iIfMi*n u ni+3 wi11 be testad of Tshle 5-1 to the tagulernanf.s t

carhon 0f ANSE N509 19 9(o. All refhcemen f or orip ineI cubon laint w;)I be ts2 tad hinia had in 1955 ce

+c the Table 5-1 of rg uiresnese h af AN.sr Als pt- 1980 (o. a {3) La hote+ory ~ tts t.s will be pl<n F ferfarend pe< affmed Technl cal SpsciNeo tims.

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A I. 5) - L{

l

' . ,._ .... ~ ...._..

'. Era,%)

.~.~ .

)qt$-FSAR AMENDMENT 47 APRIL 1986 REGULATORY GUIDE 1.140 Revision 0, March 1978 DESIGN, .

TESTING AND MAINTENANCE CRITERIA FOR NORMAL VENTILATION EXHAUST SYSTEM AIR FILTRATION AND ADSORPTION UNITS OF LIGHT-WATER-COOLED NUCLEAR POW The design of the non-safety-related filter systems meet the requirements of this guide, except as noted below. The excep-tions are keyed to paragraph -numbers in the Regulatory Position la and lb

- The equipment and components (excluding charcoal, filter pads and separator pads) are designed to withstand a maximum of 40-year integrated radi-ation dose and worst-case anticipated continuous service, rather than 40 years of continuous service.

2a -

All of the HEPA exhaust filter systems contain prefilters filters, ,

Charcoal adsorbers fan and areassociated only used wheninstrumentation.

iodine is anticipated to be present, with heaters for over 70% relative humidity air streams.

2b -

The43,900 for purgecfm. system exhaust filter train is designed at this capacity. Filter efficiency will be tested of two banks with aThe banks.

filterbetween grating train consists the filter t

i and seven wide.Each filter bank is three filters high i

2f and 3f , Filter Housings pefefe All non-ESF filter housings, exclusive of the TSClandpost-LOCApurge[unitgareatnegative

[

pressure wirn respect to their surroundings, and are located radiation in areasAny environments. which are low airborne in-leakage will not adversely N509 requirements.affect Appendix I releases, hence,the h '

I However, all of the filter mounting with frames will be leak tested in accordance ANSI N510-80.

The TSC unit housing is located in an area where the airborne radiation level of the room air may exceed that of the air within

~

the housing; however, it is at positive with respect to the surroundings, hence,, pressure F not be tested to ANSI-N509 requirements. it The will .

filter mounting frames will be A ak tested in l~ ~L Iaccordance with ANSI N510-80.I The post-LOCA purge unit housing will be le~ak tested to ANSI- i N509-80 requirements.] L

( "

- - - -A1.140-1 1 3 l6 4 - - - - - - - - ~

~

Brn,Mwood pfq{-FSAR AMENDMENs' 47 APRIL 1986 2f and 3f - Ductwork All of the ductwork upstream of the non-ESF filter units is under negative pressure with respect to its surroundings. Ductwork upstream of the Dactwork is destP *d, W"$ **'*d , a ad fessa filter units, except ductwork upstream of the ia octo r.4.c c mag TSC filter unit, is located in areas of low airborne ,

radioactivity. Any in-leakage will not adversely f3e en fea t of 5 "* a affect Appendix I releases, hence, it will not CIO of ANsz ggo4 be tested to the ANSI N509 requirements.

ign' 7 # #* 'J ' * *** '

The ductwork upstream of the TSC filter unit

,* *S, ^'**", whl be is located in the HVAC Equipment Room. The quality of the equipment room environment is the same el+ 4 ce 3,, , ,,7j,g ,' as that of the outside air which is within the lo ck *yp <

duct. Any leakage will be filtered prior to its release to the TSC environment, hence, this (Pi#3 Augh /ack wir4 ductwork will not be tested to the ANSI N509 requirements.

M4/an+s). ' Silicon e se4'*af is used es e The following ductwork will be leak tested to P"**a*n t s tai %f the ANSI N509-80 requirements: .

in Hv4c duchewA. 1. Positive pressure ductwork for the laboratory exhaust fil*.cr unit outside the laboratory HVAC equipment room.

2. The positive pressure ductwork from the Rad-waste Building exhaust filter unit in the Auxiliary Building.
3. The positive pressure ductwork from the volume reduction system area ventilation exhaust filter that is-located in the Radwaste Building.
4. The positive pressure ductwork from the Post-LOCA purge filter unit.
5. All non-safety-related system ductwork that is required to operate and is under pressure within the Control Room boundary during an abnormal or accident condition.
6. TSC. negative pressure' duct sections outside 4

the protected space where in-leakage would not normally be filtered.

) All remaining ductwork meets the exception of ANSI N509 or has negligible impact on ALARA practices and therefore, will not be leak tested. Positive pressure Radwaste Building exhaust ductwork in the Auxiliary Building will be tested before the radwaste volume reduction system is put into operation.

A1.140-2

- - - , . . , , - - . . - - - , - - . , _ ,, --......__,,y.,.,,__,_.-r,--%. ,w,,.,,,,,,m,-w,%.,-e....,..,,---,

g6H0thl000 h-FSAR

.- ~~ AMENDMEFf 47 APRIL 1986 '

3a - The components of the heaters are. manufactured t and assembled as per Section 5.5 of ANSI N509-76, similar to the requirements of heaters in safety-related filter systems, but the traceability of the componen*.s is not established as it would .

be in the case of safety-related heaters. Thus, no complete qualification program is done.

5b - Airflow d'.stribution and air-aerosol mixing tests will not be performed on the non-entry type filter units. Airflow distribution tests will be per- l formed on all entry-type filter trains to ensure that the airflow through any individual filter element does not exceed 120% of the element's rated capacity.

1 3'c, - Silic.one Sealee b ce Other tro,perary pa+c hing oneh ueI will na+ & used in +bt Silicoat n0n- E55 filhe housings. '

stalen + is used, ho wsdet, 43 a pg,ma,, gg Stefan t for HVAc clacf work .

p(g_ gj{ carben gg g,;, ;,,affurnisbad spe rflce Won 4" prior to (9VC ab pad af fllf,*ntion mai+s d'"*3/ heric cleon- uja wlIl be tes ted to %e q uire rnen fs of TabIe 5-1 e4 MNSr jv509 19 % .

cucken or 411 replace,a,e,y ot;g io I ca rbon furn;3 nog Ic. fer will bt j,. pyg o, t'es ted to he fy uire sv,en t.s of tI~l of ANSI NSoq - Ta' b/r 7999, toei3) '  !

L.e bot

  • fe'y 1

+es+s wiil be Pt!leret4

' reg uire snen h o+

t3tr +he l.140 wi Hs Table at of Repulsiaty Guide th< epap;s,, pg,., +y, will be 30

  • c. taa ,,,gua

{

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