ML20207D469

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Submits Addl Info Re Facility Control Room Habitability & Ventilation Sys,Per NUREG-0737,Item III.D.3.4
ML20207D469
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/19/1986
From: Brons J
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To: Muller D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM JPN-86-59, NUDOCS 8612310022
Download: ML20207D469 (33)
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    • 123 Main Street b '{ Wh>te Mains, New York 10601 914 681.6240
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December 19 , 1986 ,

JPN-8 6- 59 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Daniel R. Muller, Director BWR Project Directorate No. 2 Division of BWR Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 NUREG-0737 Item III.D.3.4 Control Room Habitability Reauirements

References:

1. NYPA letter, J. C. Brons to D. R. Muller, dated April 15, 1986 (JPN-86-18) submits proposed changes to the FitzPatrick Technical Specifications regarding Main Control Room Emergency Ventilation Syr, tem Air Supply Capacity Test (JPTS-82-01).
2. PASNY letter J. P. Bayne to T. A. Ippolito, dated August 13, 1981 (JPN-81-60) regarding NUREG-0737 Item III.D.3.4. Includes report evaluating habitability of the FitzPatrick Control Room.

Dear Sir:

In Reference 1, the Authority proposed changes to the FitzPatrick Technical Specifications that would require tests of the Control Room Emergency Ventilation System to verify its design flow rate every eighteen months. The Authority committed to submit this change as a result of the Control Room habitability evaluation (Reference 2) which was performed in accordance with NUREG-0737 Item III.D.3.4.

During recent telephone conversations to discuss these changes, the NRC staff requested additional information on the FitzPatrick Control Room habitability and ventilation gh 0

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% 1 systems. Specifically, the Authority was asked to compare the existing FitzPatrick Technical Specifications with the NRC's Standard Technical Specifications for General Electric Boiling Water Reactors NUREG-0123, Revision 3. Attachment 1 is this comparison.

The FitzPatrick Technical Specifications on control room habitability are different from the corresponding portions of the NRC's Standard Technical Specifications (STS). However, the differences do not result in a lower level of safety than that provided by the STS. NUREG-0737 does not require the Authority to adopt the STS, nor does the Authority consider it necessary to do so.

Attachment 1 also describes a control room auxiliary air supply system and provides details on how operating procedures will be revised for its use.

Should you or your staff have any guestions regarding this matter, please contact Mr. J. A. Gray, Jr. of my staff.

Very truly yours, 18 w, John C. Brons senior Vice President Tuclear Generation cc: Office of the Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 136 Lycoming, New York 13093

Q Attachment to JPN 59 NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT A Comparison of Control Room Habitability Technical Specifications - STS Compared to FitzPatrick I. Introduction and Background In Reference 1, the Authority proposed changes to the FitzPatrick Technical Specifications that would require tests of the Control Room Emergency Ventilation System to verify its design flow rate every eighteen months. The Authority committed to submit this change as a result of the control room habitability evaluation (Reference 2) which was performed in accordance with NUREG-0737, Item III.D.3.4.

Section II of this attachment reviews the criteria of NUREG-0737 and NUREG-0660 as it relates to the Standard Technical Specifications and the FitzPatrick plant.

During recent telephone conversations to discuss these changes, the NRC staff requested additional information on the FitzPatrick Control Room habitability and ventilation

systems. Specifically, the Authority was asked to compare i the existing FitzPatrick Technical Specifications with the i

applicable NRC Standard Technical Specifications for General Electric Boiling Water Reactors, (Reference 3). This comparison is included in Sections III and IV of this attachment.

Sections III and IV compare the FitzPatrick Technical Specifications with Section 3/4.7.2 " Control Room Emergency Filtration System," of the the NRC's Standard Technical Specifications (STS) for General Electric Boiling Water l Reactors (Reference 3).Section III compares the Limiting Conditions for Operation (LCOs) and Section IV compares surveillance requirements.

Section V describes an auxiliary bottled breathing air i supply system installed in the Control Room. Details on how operating procedures will be revised for its use are also included in Section V.

e Technical specifications, because of their hierarchical structure, do not lend themselves to quotation. Therefore, the sections below are accurate restatements of the technical specifications using as many of the actual words as possible.

The STS contain " blanks" for plant specific values; values dependent on plant unique analyses. Parentheses are used in the STS around these " blanks." So that parentheses can be used for other purposes, this attachment will use brackets, i.e. "[ ]", to identify plant specific values in the STS.

II. Criteria NUREG-0737 Item III.D.3.4, and its predecessor NUREG-0660, also Item III.D.3.4, both reference Standard Review Plan (SRP) Section 6.4 and Regulatory Guides 1.78 and 1.95 as the criteria for evaluating control room emergency ventilation systems.

NUREG-0737 Item III.D.3.4 states that " Changes to the

!- specifications will be required" without referring to the Standard Technical Specifications (STS).

Standard Technical Specifications are mentioned in Attachment 1 to Item III.D.3.4; they were used to describe what information should be included in the control room habitability evaluation. This reference to the STS indicated that control room habitability evaluation reports should include information concerning the following items: the chlorine

, detection system; the control room emergency filtration system (including the capability to maintain the control room pressurization at one-eighth inch water gauge);

verification of isolation by using test signals and damper

closure times; and, filter testing requirements.

Item III.D.3.4 does not, however, state that the STS will be used as criteria for evaluating existing technical specifications. Neither does it state that adoption of control room emergency ventilation STS is required.

NUREG-0737 also does not specifically mention Regulatory Guide 1.52 which is referenced extensively in the STS for filter and adsorber testing criteria. Two other Regulatory Guides (1.78 and 1.95) are specifically listed in Item III.D.3.4 as cuidance along with a 1974 AEC conference paper.

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J g Similarly, NUREG-0660, Item III.D.3.4, " Control Room Habitability" (which is referenced in NUREG-0737) does not specifically state that new or revised technical specifications will be required. NUREG-0660 does identify both Regulatory Guides 1.78 and 1.95, and the SRP, as <

applicable. l NRC Generic Letter 83-36 (Reference 17) addresses technical specifications for NUREG-0737 items scheduled for implementation after December 31, 1981. (NUREG-0737 items scheduled for implementation before this date were addressed in Generic Letter 83-02.) Generic Letter 83-36 described its three enclosures as follows:

... Enclosure 1 is guidance on the scope of Technical Specifications which the staff would find acceptable. Enclosure 2 presents a l discussion on items which do not require a response at this time. Enclosure 3 contains samples in Standard Technical Specification format... These samples are for for your information only."

Enclosure 1 to the generic letter included two paragraphs on NUREG-0737 Item II.D.3.4 (Control Room Habitability) technical specifications. The first paragraph discussed technical specifications associated with toxic gas monitors. (This paragraph does not apply to FitzPatrick because there are no toxic gas detectors installed.) The second paragraph on page 4 of Enclosure 1 states that "other aspects of the control room habitability requirements should be included." The generic letter goes on to clarify this broad statement in the next sentence: "Two independent control room emergency air ventilation system (sic) should be operable continuously during all modes of plant operation and capable of meeting design requirements." The FitzPatrick Technical Specifications already have limiting conditions for operation and allowable out-of-service times l

for the Emergency Control Room Ventilation System.

The Authority's evaluation of the FitzPatrick Control -

Room (Reference 2) committed to complete certain modifications to bring the Control Room into compliance with SRP Section 6.4 criteria. The NRC reviewed and approved the proposed modificiations concluding that "...the proposed l modifications will satisfy control room habitability

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1 requirements and are, therefore, acceptable" (Reference 9). '

Based on the overall content of the SER, the Authority understood the NRC's review and conclusion to be equally applicable to the proposed technical specification.

In Reference 13, the Authority summarized a June 1982 test of Control Room Ventilation System damper MOD-113. The test demonstrated that a single active failure of this outside air intake damper would not result in loss of the system's functional performance. As stated in Reference 3, no need exists to add a redundant damper as previously committed.

III. Comparison of Limiting Conditions for Operation (LCOs)

This section will compare allowable out-of-service timos for emergency control room ventilation systems in the STS and FitzPatrick Techncial Specifications.

1. Operability During Power Operation Startup or Hot Shutdown Standard Technical Specifications section 3.7.2.a Two independent control room emergency ventilation system subsystems shall be operable. During power

, operation, startup or het shutdown conditions, with one (1) control room emergency filtration subsystem inoperable, the inoperable subsystem must be restored within seven (7) days or the plant must be in hot shutdown within the next twelve (12) hours and in cold shutdown within the following twenty-four (24) hours.

FitzPatrick Technical Specifications Section 3.11.A.1 The reactor shall not have a coolant temperature greater than two hundred and twelve (212) degrees Fahrenheit and fuel may not be handled unless both of the control room emergency ventilation air supply fans and fresh air filter trains are avaliable for normal operation except that one emergency ventilation air supply fan and/or filter may be out of service for one (1) month.

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The Control Room Emergency Ventilation System l shall not be unavailable for service for a period i 5

exceeding seven (7) days during normal reactor operation or refueling operation. In the event that the system is not returned to service within

. seven (7) days the reactor will be shutdown in an orderly manner and in the cold shutdown condition within twenty-four (24) hours or if refueling operations are in progress, such operations will

.be terminated in an orderly manner.

Discussion Both the STS and FitzPatrick specifications require that the Control Room Emergency Ventilation System be operable during reactor operation and fuel handling or refueling. (See STS Section 3.7.2.b.1 for specifications applicable during cold shutdown, refueling and fuel handling operations.)

Both specifications also require shutdown within twenty-four (24) hours of LCO expiration.

The FitzPatrick specification permits longer reactor i

operation (up to one month) with one redundant emergency filtration subsystem out of service; the STS permits operation for only seven (7) days.

The FitzPatrick specification also permits both filter trains to be inoperable for up to seven (7) days; the STS permits both trains to be inoperable for up to twelve (12)

, hours.

The existing FitzPatrick LCOs are both appropriate and justifiable considering the relative importance of the Emergency Control Room Filtration System. Because definitive criteria.for calculating allowable out-of-service times (AOTs) has not been developed, a qualitative scale of relative importances has historically been used. The latest version of the STS (Reference 3) were themselves developed 1

using this unwritten scale.

i For example, the FitzPatrick Technical Specifications permit reactor operation for up to seven (7) days if the HPCI system is declared inoperable provided that alternate l

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systems are operable. The HPC1 system is of significantly more importance to safety and the prompt mitigation of an accident than the Control Room Emergency Filtration System.

HPCI acts to mitigate an accident if it does occur.

Emergency filtration is required only if an accident occurs and the containment structure leaks.

As a further example, the STS includes a fourteen (14) day LCO for HPCI inoperability (STS Section 3/4.5.1). 1 FitzPatrick's HPCI LCO is only one-half of the STS's LCO -

seven days. Considering only safety significance, HPCI is different than the Emergency Control Room Ventilation System. AOTs and LCOs should reflect this difference.

Where FitzPatrick may have a longer AOT than the STS, this may be more than compensated for by other, shorter AOTs. AOTs must be compared against other AOTs within the same technical specification and LCOs compared with other LCOs. LCOs more-restrictive or less-restrictive than those included in the STS do not, by themselves, make any plant less safe. Longer AOTs increase the probability that any specific system or component may be inoperable when it would otherwise be called on to function. Conversely, rhort AOTs may decrease this probability. The overall probanility that any system or component will not be avaliable at any specific time is a combination of these probabilities.

Based on this, it is inappropriate to critique a single LCO or AOT in isolation.

Risk combines the elements of probability and consequences. Recent research on the contribution of containment leakage tc risk illustrates the lower relative importance of the Control Room Emergency Filtration System.

NUREG/CR-4330 (Reference 10) concludes that containment failure, when compared to containment leakage, is the l dominant contributor to risk. This report further concludes that the current limits on containment leakage could be relaxed without an unacceptable increase in risk.

These LCOs are also justified based on the existence of l two other systems at FitzPatrick: the Standby Gas Treatment System (SBGTS) and the Control Room Auxiliary Air Breathing System. The SBGTS reduces both onsite and offsite radiological doces by maintaining the secondary containment building at a pressure below atmospheric thereby assuring only inleakage. SBGTS filters the atmosphere evacuated from the secondary containment (including primary containment i

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l leakage) through HEPA filters and charcoal adsorbers before 1 the processed gases are sent to the main stack. (See FSAR Section 5.3.3.4 for futher information on the SBGTS.)

Design basis calculations used to determine post-accident doses to control room inhabitants are based on very conservative assumptions. Source terms used in these calculations are significantly higher than the actual release fractions. 'When current research on accident source terms is considered in these calculations, the importance of the emergency ventilation system will be futher reduced because the consequences cf an inoperable emergency ventilation system will be significantly reduced.

Applying this qualitative measure of safety, and comparing the FitzPatrick HPCI LCOs with those for the Control Room Emergency Ventilation System, concludes that the existing LCO specifications are appropriate.

2. Operabilty During Shutdown Refueling or Fuel Handling I

, Standard Technical Specifications Section 3.7.2.b.1 During cold shutdown, refueling, or when

irradiated fuel is being handled in the secondary containment, with one control room emergency filtration system inoperable, restore the inoperable subsystem to operable status within
seven days or initiate and maintain operation of the operable subsystem in the [ isolation] mode of operation.

FitzPatrick Technical Specifications Section 3.11.A.1 The reactor shall not have a coolant temperature greater than two hundred and twelve (212) degrees Fahrenheit and fuel may not be handled unless both of the control room emergency ventilation air supply fans and fresh air filter trains are avaliable for normal operation except that one emergency ventilation air supply fan and/or filter may be out of service for one (1) month.

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FitzPatrick Technical Specifications Section 3.11.A.3 The Control Room Emergency Ventilation System shall not be unavailable for service for a period exceeding sevan (7) days during normal reactor-operation or refueling operation. In the event that the system is not returned to service within ,

seven (7) days the reactor will be shutdown in an orderly manner and in the cold shutdown condition within twenty-four (24) hours or if refueling operations are in progress, such operations will be terminated in an orderly manner.

Discussion The STS require that the emergency control room filtration subsystems be operable during all operating and non-operating modes. FitzPatrick's specification does not require that the system be operable during periods when the plant is in the cold condition and no fuel is being handled.

Plant operation may continue for up to one month with one filtration subsystem inoperable under the FitzPatrick specification. The STS is more restrictive in that it permits operation for only seven days under the same circumstances.

The less restrictive operability requirements during shutdown with no fuel handling are appropriate and justifiable. Reduced reactor temperature and the absence of fuel handling significantly reduce the possibility of a radioactive release that might require operation of the emergency ventilation system. To add to the " defense in depth" concept, the Control Room is equipped with breathing air tanks and masks. (See Section V, below.) The SBGTS

! also acts to reduce possible radioactive releases.

The existing FitzPatrick LCOs are comparable to other i FitzPatrick LCOs (HPCI for example) when the the relative j importance of these systems is taken into consideration.

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3. Operability During Normal Operations Cold Shutdown, Irradiated Fuel Handling or Refueling Standard Technical Specifications Section 3.7.2.b.2 During cold shutdown, refueling or when irradiated fuel is being handled in the secondary containment, with both control room emergency filtration subsystems inoperable, suspend core alterations, handling of irradiated fuel in the secondary containment and operations with a

! potential for draining the reactor vessel.

FitzPatrick Technical Specification Section 3.ll.A.3 The Control Room Emergency Ventilation System shall not be unavailable for service for a period

. exceeding seven (7) days during normal reactor operation or refueling operation. In the event that the system is not returned to service within seven (7) days the reactor will be shutdown in an orderly manner and in the cold shutdown condition

! within twenty-four (24) hours or if refueling operations are in progress, such operations will be terminated in an orderly manner.

Discussion The FitzPatrick specification permits fuel handling or

, refueling to continue for up to seven (7) days with both Control Room Emergency Ventilation Subsystems inoperable.

The STS do not permit either subsystem to be inoperable during refueling (core alterations and irradiated fuel

handling). STS also require the suspension of operations that could drain the reactor vessel.

The significant difference between these two specifications is FitzPatrick's seven (7) day LCO versus the immediate cessation LCO of the STS. For the same reasons -

described above, the Authority considers this LCO is both reasonable and justifiable because it is comparable to other FitzPatrick LCOs.

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The standard also requires operability during

" operations with a potential for draining the reactor vessel." This requirement should not be added to the FitzPatrick Techncial Specifications because the Emergency Control Room Ventilation System would be required only if ,

the SBGTS were inoperable. SBGTS operation is the preferrable of reducing both onsite and offsite radiological consequences.

The Authority does not routinely conduct operations that significantly increase the possibility of draining the vessel; rather, these operations occur very infrequently.

In addition, the probability of inadvertently draining the reactor vessel combined with SBGTS failure is very, very low.

In addition to the two emergency air filtration subsystems, the Control Room staff has an alternate source of clean breathing air. Five tanks and air masks, each capable of supplying air for one individual for up to nine hours, are avaliable.

4. Special Conditions During Fuel Handling
Standard Technical Specifications Section 3.7.2.c The provisions of Specification 3.0.3 are not 1

applicable in operational condition when i

irradiated fuel is being handled in secondary containment.

Standard Technical Specifications Section 3.0.3 l

"When a Limiting condition for Operation is not met, except as provided in the associated ACTION

, requirements, within one hour action shall be 1

initiated to place the unit in an OPERATIONAL CONDITION in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and
2. At least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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i Where corrective measures are completed that permit operation under the ACTICN requirements, the ACTION maybe taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications."

FitzPatrick Technical Specifications 3.0.C "In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless corrective measures are complered that permit reactor operation under the permissi.51e ACTION or until the reactor is placed in an OPEhATIONAL CONDITION (mode) in which the specification is not applicable. Exceptions to these requirements shall be stated in the individual specifications."

Discussion This FitzPatrick specification requires plant shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when circumstances arise that are not specifically addressed in action statements and violate the intent of the specification.

The existing FitzPatrick specification is more conservative than the STS because it allows only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (vs. 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in the STS) for cold shutdown.

IV. Comparison of Surveillance Requirements

1. Control Rooy Temperature Surveillance Standard Technical Specifications Section 4.7.2.a Each control room emergency filtration subsystem .

shall be demonstrated operable at least once per twalve (12) hours by verifying that the control room air temperature is less than or equal to (120] degrees Fahrenheit.

FitzPatrick Technical Specifications None Discussion The FitzPatrick Technical Specifications do not contain any requirements for periodically monitoring Control Room ambient temperature. The FitzPatrick Control Room is continuously occupied by operations personnel (Technical Specification requirement, Section 6.2). Any significant change in the ambient temperature outside the normal range of temperatures considered comfortable (approximately 65 to i

75 degrees Fahrenheit) would quickly be noticed by the staff. Temperatures over 85 degrees are noticeably

uncomfortable; over 100 is extremely uncomfortable making work difficult.

Adding a Technical Specification surveillance requirement to monitor temperature would not speed the j identification of an inoperable Emergency Control Room Ventilation System since the system does not provide air -

cooling; failure of the normal ventilation cooling system would be quickly evident to everyone in the areas served by the normal system.

4 Both the Control Room and Relay Room are served by 4

equipment, ductwork, and controls independent from other

, plant HVAC systems. The system has redundant air handling / cooling units, recirculation exhaust fans, and chiller units, each powered from a separate source of emergency electrical power to prevent system shutdown in the event of a loss cf offsite power. In the event both chiller units fail, cooling coils can be supplied with lake water by either the Normal Service Water System or the Emergency

, Service Water System. Control Room air would not exceed 100 degrees Fahrenheit in this case, assuming a maximum lake 4

water temperature of 77 degrees Fahrenheit (Reference 20).

The FitzPatrick Control Room Ventilation System will

, automatically switch to a one hundred percent recirculation (isolation) mode with full cooling when the temperature inside the Control Room rcaches 104 degrees Fahrenheit 1 (Operating Procedure F-OP-55B, Reference 16). High control i

room temperature (over 104 degrees) is also annunciatei in the Control Room. This design feature futher obviates the a

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need for periodic temperature surveillance.

Updated FSAR Section 7.1.12 " Criteria to Assure That ,

Loss of Air Conditioning and/or Ventilation System Will Not Adversely Affect the Operability of Safety Related Control and Electrical Equipment Located in the Control Room and Other Equipment Rooms" describes how the possibility of loss of cooling was considered.

In response to IE Information Notice 85-89 (Reference

21) and General Electric Service Information Letter (SIL) 421 (Reference 20), the Authority re-examined the possible effects of a complete Control Room ventilation system failure on equipment in the control room. Both of these address the impact of cooling system failure on solid state equipment in the Control Room.

Recent measurements performed as part of this re-examination indicate that control room cabinet -

temperatures are approximately eighteen degrees higher than the ambient Control Room air temperature. The original design specification (Reference 18) indicates that instrumentation in the FitzPatrick Control Room is capable of operation at temperatures up to 120 degrees Fahrenheit.

New equipment is purchased to-this same maximum temperature specification.

i Based on a maximum equipment qualification temperature of 120 degrees and an 18 degree temperature differential, the Authority is considering revising plant procedures to lower the maximum allowable Control Room temperature from 104 to 102 degrees. Consideration is also being given to reducing the setpoint for automatic initiation of full cooling from 104 to 102 degrees.

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One possible reason for this STS surveillance requirement is the existence of equipment in the control room that could exhibit degraded performance or failure at higher than normal temperatures. Newer equipment that uses solid state or semiconductor materials is most sensitive to this.

l FitzPatrick has never had an equipment failure in the Control Room attributable to high ambient temperature.

Before the Control Room Ventilation System was completed, temperatures inside the Control Room were much higher than normal due to the use of high-powered construction

lighting. A significant portion of the control Room equipment was installed and operational during this time.

No heat-induced failures in the Control Room were noted even during this period of elevated temperatures.

LCOs and AOTs for some Control Room instrumentation is already included in other sections of the technical specifications.

2. Subsystem Ope.rabilty Surveillance Standard Technical Specifications Section 4.7.2.b '

Each control room emergency filtration subsystem shall be demonstrated operable at least once every

' thirty-one (31) days on.a staggered test basis by initiating, from the control room, flow through the HEPA filters and charcoal adscrbers and verifying that the subsystem operates for at least ten hours with the heaters operable.

FitzPatrick Technical Specifications Fection 4.ll.A.1 Each of the Control Room Emergency Ventilation air supply fans and dampers shall be tested for operability every three (3) months.

Discussion The STS require that each subsystem be tested approximately once each month (twelve times per year) .

FitzPatrick requires four tests per year.

The higher test frequency specified by the STS is not necessary to assure system operability and high system reliability. The emergency filtration subsystems are effectively tested during the emergency air supply fan i

tests; these fans are used to supply air flow through the HEPA and charcoal adsorber.

Because of the arrangement of the emergency air supply fans and filter trains, the emergency air supply fans cannot be tested without drawing air through the associated filter train. The Control Room Ventilation System has four fan units (See Figure 1). During normal operation, one of two j i l

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normal fans are used (either 70-AHU-3A or 70-AHU-3B). The other two fans (70-FN-6A and 70-FN-6B) are part of the Control Room Emergency Ventilation System and draw air through independent filter trains. During emergency operation, one normal and one emergency fan is required.

Electric heaters (70-E-7 and 70-E-8) are part of the Control Room Ventilation System, are located downstream of the filter trains, and are not used to preheat outside air. I Their failure would not decrease the efficiency of the HEPA filters or charcoal adsorber beds. Therefore, surveillance testing of these heaters is not included in the FitzPatrick l Technical Specifications.

The current plant surveillance procedure F-ST-18 " Main l Control Room Emergency Fan and Damper Operability Test,"

(Reference 11) specifies that these tests are initiated ,

poing switches located in the Control Room.

3, FArticulate Filter-Surveillance Stahdard Technical Specifications Section 4.7.2.c.1 Ecch control room emergency filtration subsystem shall be demonstrated operable at least once per eighteen (18) months or (a) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (b) following painting, fire or chemical release in any ventilation zone-communicating with the system by verifying that the subsystem satisfies the in-place penetration and bypass leakage in testing acceptance criteria of less than [*] percent and uses the test procedures guidance in Regulatory Positions C.S.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is [2000) cfm plus or minus ten (10) percent.

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FitzPatrick Technical Specifications Section 4.11.A.1 The fresh air filter trains shall be tested once every six (6) months as follows: (b)

Di-octylphatalate (DOP) test for particulate filter efficiency greater that ninety-nine (99) percent for particulate greater than zero point three (0.3) micron size.

Discussion 4

The FitzPatrick specification does not explicitly require testing after filter maintenance that potentially l

could affect filter efficiency. However, the current i Authority Work Activity Control Procedure (WACP-10.1.1) provides guidanca on minimum testing to be conducted before the equipment, systems or components are returned to service after maintenance or repair. This assures that the equipment is operable prior to being returned to service.

In addition, the current FitzPatrick Technical Specifications require testing three times more frequently than the STS (once per six months versus once per eighteen months).

Portions of the omsrgency ventilation system are shared with the normal control room ventilation system. One of two one hundred percent capacity normal ventilation fans are

used during both normal and emergency operation.

Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52 address in-place testing criteria for engineered-safety-feature (ESF) filtration systems. These regulatory positions also refer to ANSI N510-1975 (Reference

8) for visual inspections, HEPA tests and activated charcoal leak tests. (Both the regulatory guide and the ANSI standard were issued after FitzPatrick recieved its Operating License.) The Authority's procedure for performing these tests addresses most of the points in both the regulatory guide and the ANSI standard.

Flow verification testing is included in a proposed technical specification change (Reference 1) currently under consideration by the NRC staff.

4. Charcoal Filter Surveillance Standard Technical Specifications Section 4.7.2.c.2 Each control room emergency filtration subsystem shall be demonstrated operable at least once per eighteen (18) months or (a) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (b) following painting, fire or chemical release in any ventilation zone communicating with the system by verifying within l

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thirty-one days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than (**] percent.

FitzPatrick Technical Specifications Section 4.11.A.1 The fresh air filter trains shall be tested. once every six (6) months as follows: (a) . . . (b) . . . (c)

Freon-112 test for charcoal filter as a measure of filter efficiency of at least ninety-nine and one-half (99.5) percent for halogen removal. (d) A sample of the charcoal filter shall be analyzed once a year to assure halogen removal efficiency of at least ninety-nine and one-half (99.5) percent.

Discussion The current FitzPatrick specification requires charcoal filter tests three (3) times more frequently than the STS.

While the FitzPatrick specification does not explicitly require testing after filter maintenance that potentially could affect filter efficiency, Authority Work Activity Control Procedure (WACP-10.1.1) provides guidance on minimum 4

testing be conducted before equipment, systems or components are be returned to service after maintenance or repair.

This assures that the equipment is operable prior to being returned to service.

The Authority completes each of the tests required by the FitzPatrick Technical Specifications as soon as i

reasonably possible. Tests are not routinely delayed.

However, testing schedules can be affected by special circumstances. This is especially true when work is performed by contractors at offsite locations. The Authority considers that the thirty-one day time limit for performing a laboratory analysis is an unnecessary l

administrative burden that does not significantly improve '

the safety of the plant. )

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

l The need to re-test the filtration subsycter "following painting, fire or chemical release in any ventilation zone communicating with the system" is not applicable to the Emergency Control Room Ventilation System because air drawn i through the filtration subsystems comes from outside the '

plant through one of two air intakes.

5. Post-Maintenance System Surveillance Standard Technical Specifications Section 4.7.2.c.3 Each control room emergency filtration subsystem shall be demonstrated operable at least once per eighteen (18) months or (a) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (b) following painting, fire or chemical release in any ventilation zone communicating with the system by verifying a subsystem flow rate of (2000) cfm plus or minus ten (10) percent during subsystem operation when tested in accordance with ANSI N510-1975.

FitzPatrick Technical Specifications None i

Discussion The FitzPatrick specification does not explicitly require testing after filter maintenance that potentially could affect filter efficiency. However, Authority Work Activity Control Procedure (WACP-10.1.1) provides guidance on testing be conducted before equipment, systems or components are returned to service after maintenance or repair. This assures that the equipment is operable prior to being returned to service.

The FitzPatrick specification does not currently require a periodic subsystem-flow test. However, a proposed change to the FitzPatrick Technical Specifications (Reference 1) has been submitted that will require that a test of the ventilation system be performed every eighteen (18) months to assure that the makeup air capacity is within ten (10) percent of its design value.

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

6. Periodic Charcoal Analysis Standard Technical Specifications Section 4.7.2.d Each control room emergency filtration subsystem shall be demonstrated operable after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying  !

within thirty-one (31) days after removal that a ,

laboratory analysis of a representative carbon i sample obtained in accordance with Regulatory '

Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than [**]

percent.

FitzPatrick Technical Specifications Section 4.ll.A.l.d A sample of the charcoal filter shall be analyzed once a year to assure halogen removal efficiency of at least ninety-nine and one-half (99.5) percent.

Discussion The FitzPatrick Specification does not specify a maximum number of hours of filter operation between charcoal adsorber tests. It does not specify a maximum time period for completing the tests after removing the carbon from the subsystem, nor does it specifically require the test procedures described in Regulatory Guide 1.52.

Ten years of operating experience has shown that the Emergency Control Room Ventilation System is used very infrequently. Almost all of the time the system is in operation is for surveillance testing. To accumulate 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of adsorber operation in one year, the Emergency Control Room Ventilation System would have to be operated an average of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day or approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per month. Surveillance testing comprises less than ten percent i of the 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />. Therefore, the annual test included in the FitzPatrick specification requires more frequent analysis of the charcoal filter than the STS.

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

The Authority completes each of the tests required by the FitzPatrick Technical Specifications as soon as reasonably possible. The Authority considers that the thirty-one day time limit for performing a laboratory analysis is an unnecessary administrative burden that does not significantly improve the safety of the plant.

Regulatory Guide 1.52, Rev. 2, Section C.6 contains laboratory testing criteria for activated carbon. This section references the requirements of ANSI N509-1976 for physical properties of new activated carbon and the design of carbon samplers. The Authority's procedures for performing these tests already address most of the points in both the regulatory guide and ANSI standard.

4

7. Filter Train Surveillance Standard Technical Specification Section 4.7.2.e.1 Each control room emergency ventilation filtration subsystem shall be demonstrated operable at least once per eighteen (18) months by verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than (6)

I inches Water Gauge while operating the subsystem at a flow rate of (2000] cfm plus or minus ten (10) percent.

! FitzPatrick Technical Specification Section 4.11.A.1 The fresh air filter trains shall be tested once every six (6) months as follows: (a) Pressure drop test across each filter and the filter system.

Discussion The current FitzPatrick specification requires pressure drop tests of the filter trains three (3) times more frequently than the STS. In addition, the FitzPatrick specification requires a pressure drop test across each filter in addition to a test of the combined filter system.

While the flow rate for these tests is not specifically i identified, the Authority has submitted a proposed change to l the FitzPatrick Technical Specifications (Reference 1) that

o will require that a test of the ventilation system be performed every eighteen (18) months to assure that the makeup air capacity is within ten (10) percent of its design value.

8. Toxic Gas Monitor Surveillance Standard Technical Specification Section 4.7.2.e.2 Each control room emergency ventilation subsystem shall be demonstrated operable at least once per eighteen (18) months, by verifying that on each of the below [ isolation) mode actuation test signals, the subsystem automatically switches to the

[ isolation] node of operation and the isolation valves close within (*) seconds: a) [ Chlorine detection]; b) [ Ammonia. detection).

FitzPatrick Technical Specifications None Discussion l This specification does not apply to FitzPatrick because there are no toxic gas detectors installed. The Authority completed a control room habitability study (Reference 2) as part of the NRC's TMI lessons learned program (NUREG-0737, Item III.D.3.4). In that study, the Authority determined that no toxic gases are stored in sufficient quantities on the site or in close proximity that would threaten the habitability of the Control Room.

9. Air Intake Radiation Monitor Surveillance Standard Technical Specifications section 4.7.2.e.3 l Each control room emergency ventilation subsystem shall be demonstrated operable at least once per f

eighteen (18) months, by verifying that on each of the below [ pressurization) mode actuation test signals, the subsystem automatically switches to the [ pressurization) mode of operation and the control room is maintained at a positive pressure (of one-eighth inch W.G.] relative to the outside

1 atmosphere during subsystem operation at a flow rate.less than or equal to [2000] cfm: a) [ Smoke detection]; b) Air intake radiation monitors, and; c) [*].

FitzPatrick Technical Specifications Section 4.11.A.2 Operability of the main Control Room air intake radiation monitor shall be tested once per three

'(3) months. 1 FitzPatrick Technical Specifications Section 3.11.A.2 The main Control Room air radiation monitor shall be operable whenever the Control Room ventilation air sapply fans and filter trains are required to be operable by 3.ll.A.1 or filtration of the Control Room ventilation intake air must be initiated.

Discussion >

The current FitzPatrick Technical Specification requires that tests be performed every three months, or six (6) times more frequently than required by the STS.

The Emergency Control Room Ventilation System at FitzPatrick does not automatically isolate on a high radiation signal. A Control Room alarm alerts the operator to this condition who then manually places the system in the

isolate mode to provide a positive one-quarter inch w.g.

pressure in the Control Room.

The FitzPatrick Control Room pressurization rate (based on zone volume and makeup air) is approximately 0.4 volume a changes per hour. Flow tests assure that the Control Room is maintained at a slightly positive pressure thereby minimizingtin-leakage. Item II.3.C.b of Standard Review Plan Section 6.4, " Control Room Habitability System" specifies that systems having pressurization rates of less than 0.5 and equal to or greater than 0.25 volume changes per hour should be subjected to periodic make-up tests to

] verify that flow is within ten percent of the design value.

1

, $ 5 A proposed change to the FitzPatrick Technical Specifications (Reference 1) is currently under NRC staff review that will require that a flow capacity test of the Emergency Control Room Ventilation System every eighteen months.

FitzPatrick surveillance test procedure F-ST-18 (Reference 11) already includes acceptance criteria of at least one-quarter inch water gauge positive pressure between the interior and exterior volumes of the Control Room. '

10. Heater Surveillance Standard Technical Specifications Section 4.7.2.e.4 Each control room emergency ventilation subsystem shall be demonstrated operable at least once per eighteen (18) months, by verifying that the heaters dissipate [7.5) plus or minus [0.75] Kw when tested in accordance with ANSI N510-1975.

4 FitzPatrick Technical Specifications 4

, None Discussion The Control Room Ventilation System heaters are part of the Normal Control Room Ventilation System. The heaters are located downstream of the filter trains, and are not used to preheat outside air prior to filtration. Their failure would not affect the efficiency of the HEPA filters or charcoal adsorber beds.

Therefore, surveill.nce testing of these heaters should not be included in the FitzPatrick Technical Specifications.

11. Post-Maintenance Filter Surveillance - Particulates Standard Technical Specifications Section 4.7.2.f Each control room emergency ventilation subsystem shall be demonstrated operable after each complete or partial replacement of a HEPA filter bank by t

. . - - - --m . , , . , . , - . - - . - - , _ _ _ . . . _ _ _ . . . . , _ . , , _...___.c.... . - . . _ _ _ _ _ ._...,__,,,__m._,_,,,....-_,__

+

verifying that the HEPA filter bank satisfies the inplace penetration and bypass leakage testing

- acceptance criteria of less [*] percent in accordance with ANSI N510-1975 while operating the system at a flow rate of [2000] cfm plus or minus ten (10) percent.

1 FitzPatrick Technical Specifications 4.ll.A.1 The fresh air filter trains shall be tested once every every six months as follows:

Di-octylphatalate (DOP) test for particulate

- filter efficiency greater than ninety-nine (99) percent for particulate greater than zero point t

three (0.3) micron size.

Discussion The FitzPatrick specification does not specifically require post-maintenace testing of the particulate filters.

+

Authority Work Activity Control Procedure (WACP-10.1.1) provides guidance on testing be conducted before equipment, systems or componcnts are returned to service after maintenance or repair. This assures that the equipment is operable prior to being returned to service.

The FitzPatrick specification does require that tests of the Emergency Control Room Ventilation System filters three (3) times more frequently than the STS (once per 18 months versus once par 6 months). The required filter efficiencies specified in the FitzPatrick specification are based on plant-specific analyses. Test procedures currently used for filter testing already address most of the points included in ANSI N510-1975. '

12. Post-Maintenance Filter Surveillance - Charcoal Standard Technical Specification Section 4.7.2.g Each control room emergency ventilation subsystem shall be demonstrated operable after each complete of partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorber bank satisfies the inplace penetration and bypass leakage testing acceptance criteria of less than 4

==r = = ----m-m er -,1,"-----,-,-e-,---------w-,---, , , - - - - - - -e-v,.w,w--.w.----,,r,-cr-----.-- - - , , - , , ww-,--,-w re w,,. -w- e,w-r--,r---.,c---

1

[*] percent in accordance with ANSI 510-1975 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow. rate of [2000] cfm plus or minus ten (10) percent.

I FitzPatrick Technical Specifications Section 4.11.A.1

The fresh air filter trains shall be tested once every six (6) months as follows:(c) Freon-112 test

' for charcoal filter as a measure of filter efficiency of at least ninety-nine and one-half (99.5) percent for halogen removal. (d) A sample of the charcoal filter shall be analyzed once a year to assure halogen removal efficiency of at least ninety-nine and one-half (99.5) percent.

Discussion The FitzPatrick Technical Specifications do not include explicit requirements to test the HEPA filters after replacement. The Authority's procedure for control of maintenance (WACP-10.1.1) provides 7 .nce on testing to be

, conducted before aquipment, systems m Lomponents are returned to service after maintenance or repair. This procedure provides a comparable level of assurance that maintenance or repair activities do not degrade system effectiveness.

The need to re-test the filtration subsystem "following painting, fire or chemical release in any ventilation zone communicating with the system" is not applicable to the Emergency Control Room Ventilation System because air drawn through the filtration subsystems comes from outside the plant through one of two air intakes. The necessity to re-test after a fire or chemical release outside the plant is best determined on a case-by-case basis when the specifics of the release or fire can be considered.

Scheduled tests are conducted three times more frequently than required by the STS. The Authority considers this higher frequency testing, combined with post-maintenance testing, to be a higher level of

.I surveillance.

i t

l I

i

l L l A proposed technical specification change (Reference 1)  ;

that will require that a periodic test of the Control Room Emergency Ventilation System is currently under NRC staff  !

review. The implementation of this proposed change will I verify system flow capacity.

V. Upgraded Control Room Air Supply System ,

The Authority committed to install an air supply and mask system in the FitzPatrick Control Room as a result of the NUREG-0737 Item III.D.3.4 Control Room habitability evaluation (Reference 2). The system has been installed since that report was submitted. An upgraded system, capable of supporting more personnel for a longer period of time than was described in the Authority's commitment, has been installed. The system is equipped with five (5) air masks and is capable of supporting five (5) Control Room occupants for up to nine (9) hours. Self-contained emergency breathing air packs are also avaliable for use by Control Room personnel.

The Authority will revise the FitzPatrick operating procedures to require the use of these air masks whenever i

conditions require the use of the Control Room emergency filtration system and neither subsystem is operable.

VI. Summary The current FitzPatrick Technical Specifications provide a level of assurance comparable to that described in the STS. The current AOTs and LCOs are consistent with and comparable to other FitzPatrick AOTs and LCOs. Changing the existing LCOs or AOTs would not significantly increase safety. Existing technical specifications surveillance requirements, along with other tests, are adequate to assure i

that the emergency ventilation system will be capable of performing its intended function in the event of'a radiation release.

'; In addition, an upgraded bottled air supply system is avaliable in the unlikely event that both filtration subsystems fail. Use of the backup bottled air system will be incorporated into plant operating procedures.

It is not clear that the adoption of all or parts of the STS for emergency control room ventilation systems was specifically included as part of the NRC's TMI Lessons l

I i I

Learned Program. Generic Letter 83-36 specifically only mentions two items regarding technical specifications for Control Room Habitability: toxic gas detectors and an LCO on system operability. Toxic gas detectors are not installed so the first item is not applicable to FitzPatrick. For the second item, a comparable LCO is already present in the FitzPatrick specifications.

1 l

l

  • l

{ p c .*

FIGURE 1 James A. FitzPatrick Nuclear Power Plant Control Room Normal and Emergency Heating, Ventilating and Air Conditioning System Flow Diagram EXHAUST O ' SECONDARY -

HOOD- ,rM%

I l FOURl VV 70-CMR AIR SOURCE O@

l l INTAKE HOOO ro.c ay.0: i Tsios M0D

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, C" z= f_g-w #

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TOILE T FAN s

uoo p V ri,4 g e Y 2W N fl F-17 MOD 1088 4 d

'"~'

IO8A M DIST L #-

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( Q g('} gt F N-4 A 4 pig g F N 48 M743((g g gE} AHU-3A IMC C-C 26 31 (MCC C253) u u lMCC C63\, , 60783 sh $ hb r AHU-3B h d i b+ b+ MOD NOD FN-6B f  %/ WlO68

/ *\ tucc.Czs31 F N-6A H MCC-C2 6 31 M_OD

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CONTROL EQUIPMENT ROOM P_TD IO8 y 70- E - 7 MILE AR6 PHYS V8 IMCC C2531 -

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o l I I I -: l+ /COWTROtk gi0 \ HALL T OI LE T KITCHENj ROOM _y

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. s VII. Notes and References

1. NYPA letter, J. C. Brons to D. R. Muller, dated April 15, 1986 (JPN-86-18) submits proposed changes to the FitzPatrick Technical Specifications regarding Control Room Emergency Ventilation System Air Supply Capacity Test (JPTS-82-01) .
2. PASNY letter J. P. Bayne to T. A. Ippolito, dated August 13, 1981 (JPN-81-60) regarding NUREG-0737 Item III.D.3.4, '

" Control Room Habitability Requirements." Includes FitzPatrick Control Room habitability evaluation report.

I 3. NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors," Revision 3, Decsaber 1980, Section 3/4.7.2, " Control Room Emergency Filtration System."

4. NYPA Radiological and Environmental Services Department Procedure PSP-6 "SBGTS, CREVASS, and TSCCVASS Filter 1- Testing," dated 04/85.
5. Nuclear Containment Systems Procedure NCS-375, " Procedure for-in-place of HEPA Filters and Carbon Adsorbers," dated February 15, 1985.
6. NYPA Drawing 11825-FB-45A, " Flow Diagram - Administration and Control Room Heating, Ventilating and Air Conditioning,"

Sheet 1.

7. USNRC Regulatory Guide 1.52, " Design, Testing, and Maintenance criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration ant Adsorption Units of Light-Water-Cooled Nuclear Power .'lants," Revision 2, March 1978.

I 8. American National Standard ANSI N510-1975 " Testing of

Nuclear Air-Cleaning Systems."
9. USNRC letter, D. B. Vassallo to L. W. Sinclair, dated February 24, 1982 regarding NUREG-0737, Item III.D.3.4, l Control Room Habitability. Includes NRC " Safety Evaluation for FitzPatrick from the Accident Evaluation Branch on NUREG-0737 Item III.D.3.4." Proposed modifications were i found to meet NUREG-0737 criteria. I 1 10. NUREG/CR-4330 " Review of Light Water Reactor Regulatory
Requirements - Assessment of Selected Regulatory 4

I l

t 1

l s Requirements That May Have Marginal Importance to Risk,"

Pacific Northwest Laboratory.

11. NYPA FitzPatrick Procedure F-ST-18, " Main Control Room Emergency Fan and Damper Operability Test."
12. NYPA FitzPatrick Procedure WACP-10.1.1, " Procedure for Control of Maintenance," Revision 10, dated January 29, 1986.
13. NYPA letter, J. C. Brons to D. B. Vassallo, dated September 15, 1986 (JPN-86-41) regarding NUREG-0737 Item III.D.3.4, Control Room Habitability Requirements. Describes test of damper MOD-ll3 and justifies NYPA decision not to install a redundant, parallel damper.
14. NRC letter, D. G. Eisenhut to All Operating Reactor Licensees, dated May 7, 1980 regarding five additional TMI-2 related requirements to operate reactors.
15. Updated FitzPatrick FSAR, Section 9.9.3.11, " Control and Relay Room Air Conditioning System," and Figure 9.9-5.
16. NYPA FitzPatrick Operating Procedure F-OP-55B, " Control Room Ventilation and Cooling," Revision 4, dated October 17, 1984.
17. NRC Generic Letter 83-36, D. G. Eisenhut to All Boiling Water Reactor Licensees, dated November 1, 1983 regarding NUREG-0737 Technical Specifications. Enclosure 1 includes guidance on the scope of technical specifications which the ,

staff would find acceptable for nine NUREG-0737 items.

18. General Electric Atomic Power Equipment Department Design Specification 22A2928, Revision 2, "BWR Equipment Environmental Interface Data," issued April 16, 1971.
19. General Electric Service Information Letter, SIL-421, "Effect of HVAC Failure," dated March 28, 1985.
20. NYPA memorandum, L. Guaquil to R. Converse, dated July 25, 1986 (PEM-86-445) regarding examination of control room HVAC configuration and review of IE Information Notice 85-89 and GE Information Letter SIL 421.
21. NRC IE Information Notice 85-89, " Potential Loss of Solid-State Instrumentation Following Failure of Control i .

i

, . . - - . . - - .. - - ,- .. __. .. .- -.r  %-.,,,,____,.,.y. . , , , , . _ , _ , - . , _ .-_.,._..-.,.,_.,..,,,..___,_~.___,p,_, _, y .-..... y. ,..-....-

s'

, , e Room Cooling," dated November 19, 1986. Describes consequences of loss of all Main Control Room cooling at McGuire Nuclear Station in 1984.

4 22. Updated FitzPatrick FSAR, Section 7.1.12, " Criteria to Assure That Loss of Air Conditioning and/or Ventilation System Will Not Adversely Affect the Operability of Safety Related Control and Electrical Equipment Located in the Control Room and Other Equipment Rooms."

1 l

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