ML20209D913
| ML20209D913 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/16/1987 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20209D831 | List: |
| References | |
| NUDOCS 8704290386 | |
| Download: ML20209D913 (26) | |
Text
.
PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.7.1 The control room emergency habitability system is OPERABLE when:
a.
Two out of three emergency ventilation subsystems,
Five bottled air pressurization subsystems consisting of two bottles per subsystem are OPERABLE, and c.
The series normal air intake and exhaust isolation dampers are
- OPERABLE, and capable of automatic closure on a CIB, Control Room High Radiation and Chlorine isolation signal, or closed.
d.
The control room air temperature is maintained 188'F.
APPLICABILITY:
- a. With either unit
- in MODES 1, 2, 3 and 4, or
- b. During irradiated fuel movement at either unit and
- a. above or
- c. Refer to T.S.
3.9.15 when both units are in either MODES 5 or 6 ACTION:
a.
With less than two emergency ventilation subsystems, fans, and associated filters
days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, a.1 With an emergency ventilation subsystem inlet isolation damper open and not capable of being closed, the requirements of 3.0.3 i
are applicable.
b.
With one bottled air pressurization subsystem inoperable, restore five bottled air pressurization subsystems to OPERABLE within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in l
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 />.
b.1 With less than four bottled air pressurization subsystems
- OPERABLE, the requirements of 3.0.3 are applicable and movement
)
of irradiated fuel shall be suspended.
8704290386 870416 PDR ADOCK 05000334 P
PDR Emergency power for one train of dampers of the Unit in MODES 5 or 6 need not be available.
BEAVER VALLEY - UNITS 1 & 2 3/4 7-16 PROPOSED WORDING
PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY HABITABIITY SYSTEMS LIMITING CONDITION FOR OPERATION c.
With one open series normal air intake or exhaust isolation damper inoperable and not capable of closing, restore all series dampers to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
col With both series normal air intake or exhaust isolation dampers inoperable and not capable of being closed, the requirements of 3.0.3 are applicable and movement of irradiated fuel shall be suspended, d.
With the control room air temperature
>88*F, return the temperature to
<88"F in 7
days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
e.
The requirements of 3.0.4 are not applicable.
BEAVER VALLEY - UNITS 1 & 2 3/4 7-16A PROPOSED WORDING
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.7.1.1 The BV-1 emergency ventilation subsystem shall be l demonstrated OPERABLE:
a.
At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control rcom air temperature is <88"F.
l b.
At least once per 31 days by initiating flow through the l HEPA filter and charcoal adsorber train and verifying that the train operates for 15 minutes.
c.
At least once per 18 months or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of l system operation and (1) after each complete or partial replacement of a
HEPA filter or charcoal adsorhar bank, or (2) after any structural maintenance on the HEDA filter or charcoal adsorber housing or (3) following painting, fire or chemical release in any ventilation zone communicating with the system by:
1.
Verifying that the filtration system satisfies the in-place penetration and by-pass leakage testing acceptance criteria of less than 1%
when tested in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 800 - 1000 cfm.
2.
Subjecting the carbon contained in at least one test canister or at least two carbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of 99%
for ladioactive methyl iodine at an air flow velocity of.68 ft/sec 120% with an inlet methyl iodide concentration of 1.5 to 2.0 mg/m,
>70%
relative 3
- humidity, and 30*C 11/2*C; other test conditions shall be in accordance with ANSI N510-1980.
The carbon samples not obtained from test canisters shall be prepared by either:
a)
Emptying one entire bed from a removed adsorber
- tray, mixing the adsorbent thoroughly, andl obtaining a
sample volume equivalent to at least two inches in diameter and with a length equal to the thickness of the bed, or b)
Removing a
longitudinal sample from al adsorber l tray using a
slotted-tube
- sampler, n ixing the adsorbent thoroughly, and obtaining a
sample volume equivalent to at least two inches in diameter and with length equal to the thickness of the bed.
BEAVER VALLEY - UNIT 1 & 2 3/4 7-17 PROPOSED WORDING
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (continued) 3.
Verifying a
system flow rate of 800 - 1000 cfm during l system operation.
d.
At least once per 18 months by:
1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is <6 inches Water Gauge while operating the ventilation system at a flow rate of 800 - 1000 cfm.
l 2.
Verifying that on a
chlorine / control room high radiation / containment phase B
isolation test signal from either Unit *, the system automatically closes all the series isolation ventilation system dampers which isolate the combined control room from the outside atmosphere.
3.
Verifying that one emergency ventilation subsystem maintains the combined control room at a
positive pressure of
>1/8 inch Water Gauge relative to the outside atmosphere during system operation.
4.
Verifying that the heaters dissipate 5 1 0.5 kw when tested in accordance with ANSI N510-1980.
4.7.7.1.2 The BV-2 emergency ventilation subsystems shall be demonstrated OPERABLE:
a.
At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is <88"F.
b.
At least once per 31 days by initiating flow.through each HEPA filter and charcoal adsorber train and by verifying that each train operates for 15 minutes.
c.
At least once per 18 months, or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation and (1) after each complete or partial replacement of a
HEPA filter or charcoal adsorber bank, or (2) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (3) following painting, fire or chemical release in any ventilation zone communicating with the system by:
1.
Verifying that the filtration system satisfies the in-place penetration and by-pass leakage testing acceptance criteria of less than 1%
when tested in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 800-1000 cfm.
Input from Unit 2 is not applicable until prior to initial entry j
into MODE 4.
BEAVER VALLEY - UNITS 1 & 2 3/4 7-18 PROPOSED WORDING
l PLANT SYSTEMS SURVEILLANCE REQUIREMENTS, Continued i
2.
Subjecting the carbon contained in at least one test canister or at least two carbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of
>99%
for radioactive methyl iodine at an air flow velocity of 0.70 ft/sec 120%
with an inlet methyl iodine concentration of 1.5 to 2.0 mg/m3, >70% relative
- humidity, and 30*C 11/2*C; other test conditions shall be in accordance with ANSI N510-1980.
The carbon samples not obtained from test canisters shall be prepared by either:
a)
Emptying one entire bed from a removed adsorber
- tray, mixing the adsorbent thoroughly, and obtaining a
sample volume equivalent to at least two inches in diameter and with a length equal to the thickness of the bed, or b)
Removing a
longitudinal sample from an adsorber tray using a
slotted-tube
- sampler, mixing the adsorbent thoroughly, and obtaining a
sample volume equivalent to at least two inches in diameter and with a length equal to the thickness of the bed.
3.
Verifying a
system flow rate of 800 to 1000 cfm during system operation.
d.
At least once per 18 months by:
1.
Verifying that the pressure drop for each filter assembly is
<3.0 inches Water Gauge across each HEPA filter and <0.9 inches Water Gauge across each charcoal filter while operating the ventilation system at a flow rate of 800 to 1000 cfm.
2.
Verifying that on a
Containment Isolation Phase B/ Control Room High Radiation test signal from e ther Unit *,
the system automatically closes all the series isolation ventilation system dampers which isolate the combined control room from the outside atmosphere and the system automatically starts 60 minutes later and supplies air to the control room through the HEPA filters and charcoal adsorber banks.
3.
Verifying that on a
chlorine test signal from either Unit *,
the system automatically closes all the series isolation ventilation system dampers which isolate the combined control room from the outside atmosphere.
Input from Unit 2 is not applicable until prior to initial entry into MODE 4.
i BEAVER VALLEY UNITS 1 & 2 3/4 7-18a l
PROPOSED WORDING
PLANT SYSTEMS SURVEILLANCE REQUIREMENTS, (continued) 4.
Verifying that one emergency ventilation subsystem maintains the control room at a positive pressure of
>1/8 inch Water Gauge relative to the outside atmosphere during system operation.
~
5.
Verifying that the heaters dissipate 5 1 0.5 kw when tested in accordance with ANSI N510-1980.
4.7.7.2 The bottled air pressurization system shall be demonstrated OPERABLE:
a.
At least once per 31 days by verifying that the system contains a
minimum of 10 bottles of air each pressurized to at least 1825 psig and by verifying that the system solenoid operated valves are powered from an operable emergency bus.
b.
At least once per 18 months be verifying that:
l 1.
A chlorine / control room high radiation / containment phase B
isolation test signal from either Unit
- will initiate system operation.
2.
Upon a
partial discharge test using four out of five bottled air subsystems the system will pressurize the control room to
>1/8 inch Water Gauge relative to the outside atmosphere during system operation.**
Input from Unit 2 is not applicable until prior to initial entry into MODE 4.
A one-time one-hour discharge test has been performed utilizing four out of five bottled air subsystems demonstrating the bottled air pressurization system will maintain the combined control room at a
positive pressure of >1/8 inch Water Gauge relative to the outside atmosphere.
BEAVER VALLEY UNITS 1 & 2 3/4 7-18b PROPOSED WORDING
PLANT SYSTEMS 3/4.9.15 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION FOR OPERATION 3.9.15.1 The control room emergency habitability system is OPERABLE when:
a.
Two out of three emergency ventilation subsystems, fans and associated filters and dampers are OPERABLE, and b.
Five bottled air pressurization subsystems consisting of two bottles per subsystem are OPERABLE, and c.
The series normal air intake and exhaust isolation dampers are OPERABLE, and capable of automatic closure on a
Control Room High Radiation and Chlorine isolation signal *, or closed.
APPLICABILITY:
When both units are in either MODE 5 or 6.
ACTION:
a.
With less than two emergency ventilation subsystems, fans and associated filters OPERABLE and irradiated fuel being
- moved, restore at least two subsystems to OPERABLE status within 7 days or close at least one series normal air intake and exhaust isolation damper on each intake and exhaust to the control room.
b.
With one bottled air pressurization subsystem inoperable, restore five bottled air pressurization subsystems to OPERABLE within 7
days or suspend all operations involving movement of irradiated fuel.
b.1 With less than four bottled air pressurization subsystems OPERABLE or no emergency ventilation subsystems OPERABLE, suspend all operations involving movement of irradiated
- fuel, c.
With one open series normal air intake or exhaust isolation damper inoperable # and not capable of closing and irradiated fuel being
- moved, restore all series dampers to OPERABLE status within 7 days or close at least one series normal air intake and exhaust isolation damper on each intake and exhaust to the control room.
Not applicable when output relay fuses are removed to prevent inadvertant ESF actuation.
Emergency backup power not required for any 1
of 2 series dampers.
BEAVER VALLEY - UNIT 1 & 2 3/4 9-16 l
PROPOSED WORDING
PLANT SYSTEMS LIMITING CONDITION FOR OPERATION c.1 With both series normal air intake or exhaust isolation dampers inoperable # and not capable of being closed, suspend all operations involving movement of irradiated fuel.
d.
The requirements of 3.0.4 are not applicable.
SURVEILLANCE REQUIREMENTS 4.9.15.1 The emergency ventilation subsystems and the bottled air pressurization system shall be demonstrated OPERABLE in accordance with Specifications 4.7.7.1.1, 4.7.7.1.2 and 4.7.7.2 with the following exception:
a.
Automatic operation upon receipt of a containment phase B isolation signal is not required.
Emergency backup power not required for any 1
of 2 series dampers.
BEAVER VALLEY - UNITS 1 & 2 3/4 9-17 l
PROPOSED WORDING
REFUELING OPERATIONS BASES 3/4.9.15 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS The OPERABILITY of the control room ventilation system ensures that 1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions.
The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole
- body, or its equivalent.
This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A",
i 3
i BEAVER VALLEY - UNIT 1 & 2 B 3/4 9-4 PROPOSED WORDING
PLANT SYSTEMS BASES 3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEM The OPERABILITY of the control room emergency habitability system ensures that the control room will remain habitable for operations personnel during and following all credible accident conditions.
The ambient air temperature is controlled to prevent exceeding the allowable equipment qualification temperature for the equipment and instrumentation in the control room.
The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5
rem or less whole body, or its equivalent.
This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A",
3/4.7.8 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS)
The OPERABILITY of the SLCRS provides for the filtering of postulated radioactive effluents resulting from a
Fuel Handling Accident (FHA) and from leakage of LOSS of COOLANT ACCIDENT (LOCA) activity from systems outside of the Reactor Containment building, such as Engineered Safeguards Features (ESF) equipment, prior to their release to the environment.
This system also collects potential leakage of LOCA activity trom the Reactor Containment
~
building penetrations into the contiguous areas ventilated by the SLCRS except for the Main Steam Valve Room and Emergency Air Lock.
The operation of this system was assumed in calculating the postulated offsite doses in the analysis for a FHA.
System operation was also assumed in that portion of the Design Basis Accident (DBA)
LOCA analysis which addressed ESF leakage following the
- LOCA, however, no credit for SLCRS operation was taken in the DBA LOCA analysis for collection and filtration of Reactor Containment building leakage even though an unquantifiable amount of contiguous area penetration leakage would in fact be collected and filtered.
Based on the results of the analyses, the SLCRS must be OPERABLE to ensure that ESF leakage following the postulated DBA LOCA and leakage resulting from a FHA will not exceed 10 CFR 100 limits.
3/4.7.9 SEALED SOURCE CONTAMINATION The limitations on sealed source removable contamination ensure that the total body or individual organ irradiation does not exceed allowable limits in the event of ingestion or inhalation of the source material.
The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 79.39(c) limits for plutonium.
Leakage of sources excluded from the requirements of this specification represent less than one maximum permissible body burden for total body irradiation if the source material is inhaled or ingested.
3/4.7.10 and 3/4.7.11 RESIDUAL HEAT REMOVAL SYSTEM (RHR)
Deleted BEAVER VALLEY UNIT 1 & 2 B 3/4 7-5 PROPOSED WORDING
REFUELING OPERATIONS BASES 3/4.9.15 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS The OPERABILITY of the control room emergency habitability system ensures that the control room will remain habitable for operations personnel during and following all credible accident conditions.
The ambient air temperature is controlled to prevent exceeding the allowable equipment qualification temperature for the equipment and instrumentation in the control room. The OPERABILITY of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent.
This limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A",
BEAVER VALLEY - UNIT 1 & 2 B 3/4 9-4 PROPOSED WORDING
ATTACHMENT B
Proposed Technical Specification Change No. 126, Revision 2 No Significant Hazard Consideration Description of amendment request:
The Control Room Emergency Bottled Air Pressurization System (CREBAPS) and Control Room Emergency Ventilation System (CREVS) will be modified to upgrade both systems to accommodate the additional volume of the Unit 2 contro.l.
room.
A wall currently separates the Unit 1 and Unit 2 control roo as and serves as a
ventilation, fire protection and security barrier.
The wall will be removed to provide a common control room area for the two units.
The CREBAPS compressed air storage capacity will be increased by adding five new compressed air storage tanks which are equivalent in capacity and pressure to the existing tanks.
The combined capacity of the compressed air storage tanks will then be sufficient to maintain the common control room area pressurized for the required one-hour time period.
A larger air compressor has also been installed to provide additional charging capability for the system.
The Unit 1 Control Room Emergency Ventilation System Supply Fans VS-F-41A and VS-F-41B will be replaced with larger fans capable of supplying the additional flow rate required to maintain the common control room area pressurized.
In
- addition, larger supply and discharge
- ducting, a
larger duct heater and larger dampers will be installed to satisfy the additional flow requirements.
Operating more than one fan at a time may pressurize the control room area so that it may be difficult to open and close control room doors.
Therefore, operating procedures will be revised so that only one fan will be operated at any one time.
Control Room Emergency Habitability Systems will continue to meet General Design Criteria 19 as described in Beaver Valley Power Station Unit No.
1 (BVPS-1)
FSAR Section 1.3.2 and Appendix A.
Testing criteria for the BVPS-1 control room post accident engineered safety feature air filtration and adsorption unit meets the intent of Regulatory Guide 1.52, Rev.
2, Positions C.5 and C.6 with the following alternatives:
Paragraph C.5.b The airflow capacity and distribution test procedure will be developed based on Section 8
of ANSI N510-1980 except for the following alternatives:
1.
To avoid damage to system components, an artificial resistance may be used in lieu of the recommendations of Paragraph 8.3.1.1.
l
\\
ATTACHMENT B (Continued)
Page 2 1
2.
The airflow test specified in Paragraph 8.3.1.6 will be performed with the filter bank at 100 percent of design dirty-pressure drop.
The system and equipment instrumentation and surveillance preclude inadvertent operation of the filter banks with the pressure or flow outside of the allowable limits.
3.
The airflow test specified in Paragraph 8.3.1.7 will be performed with the filter bank at 50 percent of design dirty-pressure drop.
4.
Airflow distribution through the HEPA will not be performed on the basis of the design employing a single HEPA filter located downstream of the charcoal adsorber.
Paragraph C.5.c The in-place DOP test of HEPA filters will be performed in accordance with Section 10 of ANSI N510-1980.
The air-aerosol mixing uniformity test in Section 9 of ANSI N510-1980 will not be performed since the BVPS-1 emergency ventilation subsystem contains only one HEPA filter.
In-place DOP testing will be conducted to confirm a
penetration of less than 1.0% at rated flow which is consistent with Standard Technical Specifications, Draft Rev. 5.
Paragraph C.S.d The in-place test of the carbon adsorber will be performed in accordance with Section 12 of ANSI N510-1980.
In-place refrigerant gas testing will be conducted to ensure that bypass leakage through the adsorber section is less than 1.0% which is consistent with Standard Technical Specifications, Draft Rev. 5.
Paragraph C.6.b Laboratory testing frequency for the activated carbon will meet the recommended minimum test frequency indicated in Table 1 of ANSI N510-1980.
The carbon samples not obtained from test canisters will be obtained with a slotted-tube sampler.
Assumptions for evaluating the habitability of the BVPS-1 control room during a
postulated hazardous chemical release meet the intent of Regulatory Guide 1.78, Rev. O with the following clarifications and alternatives:
Of the various evaluation methods available, BVPS-1 evaluation has been performed by the methodology outlined in NUREG-0570, published in June
- 1979, which is similar to that presented in Appendix B
of Regulatory Guide 1.78 but at a much greater level
ATTACHMENT B (Continued)
Page 3 of detail and refinement.
This evaluation was submitted to the NRC in response to NUREG-0737 item III.D.3.4 by our letter dated December 28, 1981.
The NRC safety evaluation was issued on February 9, 1982.
Protection of the control room during a chlorine release is also addressed in the BVPS-1 position on Regulatory Guide 1.95.
Paragraph C.9 The existing control room emergency bottled air pressurization
- system, which will be used to pressurize both the BVPS-1 and BVPS-2 control
- rooms, will provide a minimum positive pressure differential of 1/8 inch water gauge in the control room relative to the outside atmosphere.
Paragraph C.12 A
chlorine release concurrent with an earthquake, tornado or flood and coincident with the radiological consequences of a design basis accident as described in Regulatory Guide 1.78, Position C.12 is interpeted as events simultaneously occurring.
Paragraph C.13 operators will be instructed to don self contained breathing apparatus upon receipt of a chlorine signal.
The self contained breathing apparatus has an air supply of 6 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This action is consistent with that defined in Regulatory Guide 1.78, Position C.13.
Protection of the control room operators against an accidental chlorine release meets the intent of Regulatory Guide 1.95 with the following alternatives and clarifications:
Paragraph C.3 An evaluation of control room habitability is performed using the general design considerations of Regulatory Guide 1.78 in lieu of Paragraph C.3.
Specific design features and procedures are
- defined, to the extent necessary, to assure the chlorine concentration inside the control room could not exceed 15 ppm by volume (45 mg/M )
within 2
minutes of detection and that the operator is protected.
Paragraph C.4 The charcoal filters will not be used for chlorine removal as discussed in Paragraph C.4.a because the filters are not designed to remove or limit chlorine accumulation.
The design basis of the filters is purely radiological.
ATTACHMENT B (Continued)
Page 4 The surveillance requirements of the BVPS Technical Specifications, are used in lieu of those suggested in Paragraph C.4.
System response
- time, described in paragraph C.4.d.(2), will be fast enough to ensure that the chlorine concentration inside the 8
control room could not exceed 15 ppm by volume
( 45 mg/m )
within 2
minutes after the operators are made aware of the presence of chlorine.
The detection system has not been qualified as described in Paragraph C.4.d.(5) since the detectors were not identified as required to be included on the Environmental Qualification Master Equipment List in accordance with 10 CFR 50.49.
The BVPS-2 positions on Regulatory Guides 1.52, 1.78 and 1.95 are contained in the Unit 2 FSAR, Table 1.8-1.
The following changes have been incorporated:
I.
3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS A.
Operability Requirements 1.
The proposed specification requires control room ventilation system normal air intake and exhaust isolation dampers to be operable and capable of automatic closure on a
containment isolation phase B (CIB),
control room high radiation and chlorine isolation
- signal, or closed.
This damper operability requirement will ensure that no flow path is open to the outside atmosphere and that the control room can be pressurized during plant operation.
Radiation monitors will be added to the BVPS-1 control room ventilation system to initiate control room isolation and pressurization in the event of radioactive inleakage.
It has been determined that a small line break (SLB) outside of containment at BVPS-2 is limiting with respect to control room dose.
For more information about the SLB see Section 6.4.4.1 of the BVPS-2 FSAR.
2.
The proposed specification requires operability of two out of three available control room emergency ventilation subsystems, and five bottled air pressurization subsystems.
Operability of two out of three emergency ventilation subsystems provides operational flexibility to operate any two of three of the following; two 100%
redundant BVPS-2 emergency ventilation subsystems and the BVPS-1 emergency ventilation system which is being defined as one subsystem.
ATTACHMENT B (Continued)
Page 5 l
3.
The proposed specification requires the control room air temperature be maintained at greater than or equal to 88"F.
The control room equipment is qualified to at least 104*F, therefore, monitoring this temperature assures the environmental conditions do not exceed the equipment qualifications.
B.
Applicability 1.
Applicability requirements were expanded to include periods of time when either unit is in modes 1, 2, 3 or 4,
when moving irradiated fuel at either unit, and to reference Specification 3.9.15 for requirements applicable when both units are in either mode 5 or 6.
The proposed applicability statement ensures habitability of the control room regardless of plant mode.
The footnote added to the applicability requirement permits one train of ESF equipment to be out of service in modes 5 or 6.
The purpose of this is to allow diesel generator maintenance when one of the two units is in either mode 5
or 6 as defined in Specification 3.0.5 and its' bases.
C.
Action Statements 1.
Action statements were expanded to provide for the additional operability and applicability requirements.
The proposed action statements require that with less than the defined control room emergency habitability subsystems operable, operators take appropriate actions to ensure single failure criteria is met in a timely manner.
Action statement "a." provides the required actions to be taken with less than two emergency ventilation subsystems operable and "a.1" provides the required actions when the control room pressure boundary envelope integrity is lost due to the subsystems inlet dampers being open and incapable of being closed.
2.
Action statements "b."
and "b.1" provide the required actions to be taken when the bottled air pressurization system has one subsystem inoperable, and when less than l
four subsystems are OPERABLE.
This distinction allows for actions to be taken to meet single failure criteria and protective actions required when the primary safety system is incapable of performing its intended function.
3.
Action statements "c."
and "c.1" provide the required actions to be taken when one or both of the series normal air intake or exhaust isolation dampers are inoperable.
These actions are consistent with the above with respect to meeting single failure criteria.
. ~ _ -
ATTACHMENT B (Continued)
Page 6 j
4.
Action statement "d." provides the required actions to be taken if the control room temperature cannot be maintained 1 88*F.
This action requires the plant to proceed to a mode where the failure of control room equipment, due to elevated temperatures, will have negligible effect on the plant systems and components.
5.
Action statement "e."
states that the requirements of l
[ Specification]
3.0.4 are not applicable.
This will
]
allow entry into an operational mode if the limiting i
conditions for operation are met with reliance on provisions contained in the action statement I
requirements.
Since the maximum out of service time j
for a component is 7 days, this would continue to limit the allowable repair time while not restricting a plant re-start if a trip occurred during the period.
D.
Surveillance Requirements 1.
Surveillance requirement 4.7.7.1 was divided into two separate requirements, 4.7.7.1.1, and 4.7.7.1.2.
The first surveillance requirement, 4.7.7.1.1, demonstrates operability of the BVPS-1 emergency ventilation J
subsystem and the second requirement, 4.7.7.1.2, l
demonstrates operability of the BVPS-2 emergency i
ventilation subsystems.
The control room air temperature requirement was lowered to 1 88*F to be i
consistent with the NRC Staff's request for the BVPS-2 Technical Specification requirements.
Surveillance requirements for charcoal adsorber and HEPA filter bank j
testing were revised to be in agreement with ANSI N510-1980 as described above in our position on Regulatory Guide 1.52.
j Surveillance 4.7.7.1.2.d.2 requires that the BVPS-2 emergency ventilation subsystems automatically start after 60 minutes and supply air to the control room l
through the HEPA filters and charcoal adsorber banks.
Surveillance 4.7.7.1.1.d.2 does not have a
similar i
requirement to verify that the BVPS-1 emergency j
ventilation subsystem starts automatically.
These l
actions will be performed manually for the BVPS-1 subsystem since the system is not required to be i
operated before 60 minutes after an event.
Surveillance 4.7.7.1.1.d.4 and 4.7.7.1.2.d.5 have been i
1 added to verify that the duct heaters remain operable j
i and capable of maintaining the relative humidity of the i
incoming air to the emergency ventilation subsystems filters at S 70%.
5_________--_._,__,.
ATTACHMENT B (Continued)
Page 7 A
footnote to surveillance requirements 4.7.7.1.1.d.2, 4.7.7.1.2.d.2, and 4.7.7.2.b.1 provides that a signal from BVPS-2 to close control room isolation dampers is not required until just before BVPS-2 makes its initial entry into mode 4.
This exception is proposed since the BVPS-2 solid state protection system will not be operable until after BVPS-1 restart.
- However, equivalent protection is provided since BVPS-1 protection signals will initiate operation of BVPS-2 emergency habitability systems independently of BVPS-2 protection signals.
2.
Surveillance requirement 4.7.7.2 parts "a." and "b."
were expanded to reflect the addition of 5 air bottles and to include verification that a) a chlorine, control room high radiation or CIB test signal from either unit will initiate bottled air pressurization system operation, and b) the bottled air pressurization system is operable by performing a partial discharge test.
II. 3/4.9.15 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS A.
Operability Requirements 1.
Specification 3/4.9.15 has been incorporated to address control room emergency habitability requirements when both units are in either mode 5 or 6.
The operability requirements are the same as those found in Specification 3/4.7.7 except that automatic actions resulting from a CIB are not required since both units are shutdown.
The footnote to Specification 3.9.15.1.c indicates that automatic closure of the series normal air intake and exhaust isolation dampers on a
control room high radiation or chlorine isolation signal is not applicable when output relay fuses are removed.
This exception is proposed to prevent inadvertent operation of ESF equipment while performing surveillance testing.
B.
Applicability 1.
Specification 3.9.15 will be applicable when both units are in either mode 5 or 6.
This will ensure that the operators are protected by limiting radiation exposure in the event of a
fuel handling accident and by limiting exposure to chlorine in the event of a
chlorine release accident.
C.
Action Statements 1.
Action statement "a." provides the required actions to be taken with less than two emergency ventilation subsystems operable when moving irradiated fuel.
No action is required when less than two emergency ventilation subsystems are operable and irradiated fuel
ATTACHMENT B (Continued)
Pago 8 is not being moved since a fuel handling accident is not possible and the emergency ventilation subsystem is not used to mitigate the consequences of a chlorine release accident.
2.
Action statements "b." and "b.1" provides the required actions to be taken when the bottled air pressurization system has inoperable subsystems.
These action statements are similar to those of Specification 3.7.7.1 Action "b." and "b.1" in that different actions are taken depending on whether one or more subsystems are inoperable.
Action statement "b.1" also requires that all operations involving movement of irradiated fuel be suspended if no emergency ventilation subsystems are operable.
3.
Action statements "c."
and "c.1" provide the required actions to be taken when one or both of the series normal air intake or exhaust isolation dampers are inoperable.
The footnote to action statements "c." and "c.1" provides that emergency backup power is not required for any 1 of 2 series dampers.
The purpose of this is to allow diesel generator maintenance and i
preclude a
condition where no makeup air would be available for an extended period of time to the control room.
This is consistent with specification 3.0.5 and its' bases.
4.
Action statement "d."
states that the requirements of
[ Specification]
3.0.4 are not applicable.
The purpose of this action statement is the same as that of Specification 3.7.7.1 Action "e." described above.
D.
Surveillance Requirements 1.
Surveillance 4.9.15.1 requires that the emergency ventilation subsystems and the bottled air pressurization system be demonstrated operable in accordance with Specifications 4.7.7.1.1, 4.7.7.1.2, and 4.7.7.2 with one exception.
Automatic operation upon receipt of a CIB signal is not required in mode 5 or 6.
E.
Technical Specification Bases 1.
Bases Section 3/4.9.15 Control Room Emergency Habitability Systems has been added to reflect the bases applicable to Specification 3.7.7.1.
Bases for no significant hazards determination:
The proposed changes do not involve a significant hazards consideration because plant operation in accordance with these changes would not:
1.
Involve a
significant increase in the probability of occurrence or the consequences of a previously evaluated accident because:
The proposed changes reflect the limiting conditions of operation l
ATTACHMENT B (Continued)
Page 9 required to assure the combined control room emergency habitability systems remain operable in order to protect the control room operators during an emergency and the general public in accordance with 10 CFR 100.
The Control Room Emergency Bottled Air Pressurization System (CREBAPS) has been modified to the extent that it is capable of pressurizing the combined control room area to > 1/8 inch water gauge with respect to the outside atmosphere for a
period of one hour.
The Unit 1 protection signals required to operate this system remain the same and the Unit 2
protection signals perform the same function.
A protection signal from either Unit will initiate control room protective actions, therefore, the habitability of the control room is assured to the same level of protection and the probability of occurrence or the consequences of a previously evaluated accident is not effected due to the changes to the CREBAPS.
The change requiring two out of three emergency ventilation subsystems to be operable incorporates the Unit 2 design of two 100%
redundant emergency ventilation subsystems, and the Unit 1
- system, being defined as one subsystem.
This results in the operators having additional equipment to utilize in meeting the minimum required subsystems to provide control room habitability during accident conditions.
All equipment is supported by equivalent support systems at each respective unit and is capable of protecting the operators in accordance with 10 CFR 50, Appendix A,
The Unit 2 FSAR, Section 6.4, defines the accidents (radiological and non-radiological) the control room habitability systems have been designed to protect against.
As a result of the modifications to the Unit 1
equipment, an equivalent evaluation of accidents, as defined by the Standard Review Plan, has been performed for Unit 1.
The conclusions are that the Unit 2, small line break outside of containment remains the limiting accident with respect to operator doses in the control room.
The control room modifications have also been reviewed with respect to releases of toxic gases.
The Unit 1 response to NUREG-0737, item III.D.3.4, Control Room Habitability is unaffected by the modifications.
The Unit 2 FSAR, Section 6.4, describes the combined control room protection from toxic gases.
The on-site release of chlorine gas remains the only toxic gas for which protection of the control room operators is required.
The potential for a
chlorine gas release is unaffected by the modifications and the proposed technical specifications.
The effect of a
chlorine gas release on the combined control rooms has been re-evaluated and it has been concluded that Regulatory Guide 1.78 and 1.95 can be met with respect to demonstrating the I
toxicity limit will not be reached within the first two minutes l
after the gas is detected by the chlorine detectors thereby l
providing the operators sufficient time to don a self-contained l
breathing apparatus.
l
ATTACHMENT B (Continued)
Page 10 In conclusion, the proposed changes provide additional limitations on the control room emergency habitability systems to ensure the control room area environmental conditions are maintained to protect the plant operators under postulated accident conditions.
Additionally, Specification 3.9.15.1 incorporates operability requirements into the refueling section of the technical specifications which apply when both units are in either modes 5
or 6.
These changes are consistent with removal of the control room wall and upgrade of the control room habitability systems in order to handle the additional volume of the Unit 2 control room area.
Therefore, these changes will not affect the probability of occurrence or the consequences of previously evaluated accidents.
2.
Create the possibility of a
new or different kind of accident from any previously analyzed because:
The proposed changes will ensure control room environmental conditions are maintained suitable for operator habitability during accident conditions.
Removal of the temporary wall, defining the need for two out of three emergency ventilation subsystems or increasing the capacity of the bottled air pressurization system does not create a new or different kind of accident.
The combined control room has been analyzed for radiological and non-radiological accidents none of which are a
new or different type.
The two out of three arrangement provides increased operator flexibility in defining which subsystems are operable and provides for a third 100%
redundant emergency ventilation subsystem.
The bottled air pressurization system provides, at least, an equivalent level of operator protection as before since the Unit 2 control room envelope volume is only 59,000 ft.8 while the Unit 1 area is 114,000 ft.8 and the bottled air pressurization capacity has been doubled.
The wall removal requires the additional capacity of the control room habitability systems to handle the additional volume of the Unit 2
control room area.
The requirements of Specification 3.7.7.1 provide limitations on the Unit 2 as well as the Unit 1 systems during modes 1-4 and Specification 3.9.15.1 provides the limitations applicable when either unit is in mode 5 or 6.
Therefore, the possibility for a new or different kind of accident will not be created.
3.
Involve a
significant reduction in a margin of safety because:
The Technical Specifications provide limitations on control room habitability during modes 1-6 and when moving irradiated fuel.
Identical requirements are being required for each Units' technical specifications since this specification applies to both units.
With one unit operating and one unit shutdown, two trains of emergency control room habitability equipment are required to remain operable.
Additionally, operability requirements are being imposed when both units are in either mode 5 or 6.
As a
- result, ESF equipment is available to protect the operators in all modes of operation when protection from postulated accidents is required.
Therefore, there is no significant reductions in the margin of safety due to the combined control room being protected by common equipment.
ATTACHMENT B (Continued)
Page 11 Conclusion The proposed changes are consistent with the removal of the l
control room wall and upgrade of the control room emergency habitability systems required to handle the additional volume of the Unit 2
control room area.
Technical Specifications provide the limitations requimed to ensure the control room area environmental conditions are maintained to protect the plant operators during postulated accident conditions.
Accident conditions include both radiological and non-radiological.
The equipment and testing has been evaluated against the applicable Regulatory Guides (1.52, 1.78 and 1.95) and it has been determined these can be met as stated above in the description of this technical specification change.
The control room operators are protected in accordance with 10 CFR 50, Appendix A, GDC-19 and the public protected in accordance with 10 CFR 100.
These changes will not increase the likelihood of a malfunction of safety related equipment, increase the consequences of an accident previously analyzed nor create the possibility of a malfunction different than previously evaluated.
Therefore, based on the above, it is proposed to characterize the change as involving no significant hazards.
1
r SAFETY EVALUATION Technical Specification Change 1A-126, Revision 2 reflects the equipment modifications to the Control Room Emergency Bottled Air Pressurization System (CREBAPS) and Control Room Emergency Ventilation System (CREVS) to upgrade both systems to accommodate the additional volume of the Unit 2 control room.
Basis 1.
Is the probability of an occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the UFSAR increased?
No Reason The proposed changes reflect the limiting conditions of operation required to assure the combined control room emergency habitability systems remain operable in order to protect the control room operators during an emergency and the general public in accordance with 10 CFR 100.
The Control Room Emergency Bottled Air Pressurization System (CREBAPS) has been modified to the extent that it is capable of pressurizing the combined control room area to > 1/8 inch water gauge with respect to the outside atmosphere for a
period of one hour.
The Unit 1 protection signals required to operate this system remain the same and the Unit 2
protection signals perform the same function.
A protection signal from either Unit will initiate control room protective actions, therefore, the habitability of the control room is assured to the same level of protection and the probability of occurrence or the consequences of a previously evaluated accident is not effected due to the changes to the CREBAPS.
The change requiring two out of three emergency ventilation subsystems to be operable incorporates the Unit 2 design of two 100%
redundant emergency ventilation subsystems, and the Unit 1
- system, being defined as one subsystem.
This results in the operators having additional equipment to utilize in meeting the minimum required subsystems to provide control room habitability during accident conditions.
All equipment is supported by equivalent support systems at each respective unit and is capable of protecting the operators in accordance with 10 CFR 50, Appendix A,
The Unit 2 FSAR, Section 6.4, defines the accidents (radiological and non-radiological) the control room habitability systems have been designed to protect against.
As a result of the modifications to the Unit 1
equipment, an equivalent evaluation of accidents, as defined by the Standard Review
- Plan, has been performed for Unit 1.
The conclusions are that the Unit 2, small line break outside of containment remains the limiting accident with respect to operator doses in the control room.
i
I l
SAFETY EVALUATION (Continued)
Page 2 The control room modifications have also been reviewed with respect to releases of toxic gases.
The Unit 1 response to NUREG-0737, item III.D.3.4, Control Room Habitability is unaffected by the modifications.
The Unit 2 FSAR, Section 6.4, describes the combined control room protection from toxic gases.
The on-site release of chlorine gas remains the only toxic gas for which protection of the control room operators is required.
The potential for a
chlorine gas release is unaffected by the modifications and the proposed technical specifications.
The effect of a
chlorine gas release on the combined control rooms has been re-evaluated and it has been concluded that Regulatory Guide 1.78 and 1.95 can be met with respect to demonstrating the toxicity limit will not be reached within the first two minutes after the gas is detected by the chlorine detectors thereby providing the operators sufficient time to don a self-contained breathing apparatus.
In conclusion, the proposed changes provide additional limitations on the control room emergency habitability systems to ensure the control room area environmental conditions are maintained to protect the plant operators under postulated accident conditions.
Additionally, Specification 3.9.15.1 incorporates operability requirements into the refueling section of the technical specifications which apply when both units are in either modes 5
or 6.
These changes are consistent with removal of the control room wall and upgrade of the control room habitability systems in order to handle the additional volume of the Unit 2 control room area.
Therefore, these changes will not affect the probability of occurrence or the consequences of previously evaluated accidents.
2.
Is the probability for an accident or malfunction of a different type than previously evaluated in the UFSAR created?
No Reason The proposed changes will ensure the control room environmental conditions are maintained suitable for operator habitability during accident conditions.
Removal of the temporary wall, defining the need for two out of three emergency ventilation subsystems or increasing the capacity of the bottled air pressurization system does not create the probability for an accident or malfunction of a
different type than previously evaluated in the UFSAR.
The combined control room has been analyzed for radiological and non-radiological accidents, none of which.are of a
new or different type.
The two out of three arrangement provides increased operator flexibility in defining which subsystems are operable and provides for a third 100%
redundant emergency ventilation subsystem.
The bottled air pressurization system provides, at least, an equivalent level of operator protection as before since the Unit 2 control room envelope volume is only 59,000 ft.3 while the Unit 1 area is 114,000 ft.3 and the bottled air pressurization capacity has been doubled.
The wall removal requires the additional capacity
r SAFETY EVALUATION (Continued)
Page 3 of the control room emergency habitability systems to handle the additional volume of the Unit 2 control room area.
The require-ments of Specification 3.7.7.1 provide limitations on the Unit 2 as well as the Unit 1 systems during modes 1-4 and Specification 3.9.15.1 provides the limitations applicable during modes 5 and 6.
Therefore, the possibility for a new or different kind of accident will not be created.
3.
Is the margin of safety as defined in the basis for any technical specification reduced?
No Reason The technical specifications provide limitations on control room habitability during modes 1-6 and when moving irradiated fuel.
Identical requirements are being proposed for each Units' Technical Specifications since this specification applies to both units.
With one unit operating and one unit shutdown, two trains of emergency control room habitability equipment are required to remain operable.
Additionally, operability requirements are being imposed when both units are in either mode 5 or 6.
As a
- result, ESF equipment is available to protect the operators in all modes of operation when protection from postulated accidents is required.
Therefore, there is no significant reductions in the margin of safety as defined in the basis for any technical specification.
4.
Is a change to the UFSAR required?
Yes Reason UFSAR Section 9.13.4, Main Control Area Ventilation Systems and Tables 9.13-1 and 9.13-2 require revision to reflect the increased capacity of the Control Room Emergency Habitability Systems.
Conclusions The proposed changes are consistent with the removal of the control room wall and upgrade of the Control Room Emergency Habitability Systems required to handle the additional volume of the Unit 2
control room area.
Technical Specifications provide the limitations required to ensure the control room area environmental conditions are maintained to protect the plant operators during i
postulated accident conditions.
Accident conditions include both radiological and non-radiological.
The equipment and testing has been evaluated against the applicable Regulatory Guides (1.52, 1.78 and 1.95) and it has been determined that these can be met as stated j
above in the description of this technical specification change.
The i
control room operators are protected in accordance with 10 CFR 50, Appendix A, GPC-19 and the public protected in accordance with 10 CFR l
100.
Unit 2
will have similar limitations to provide the same protection.
These changes will not increase the likelihood of a
r-
~
SAFETT EVALUATION (Continued)
Page 4
\\1 conclusion (Continued) malfunction of safety related equipment, increase the consequences of f an accident previously
- analyzed, nor create the possibility of af g malfunction different than previously evaluated.
Therefore, based on the
- above, these changes have been determined to be safe and do not involve an unre/iewed safety question.
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