ML20212F661

Proposed Tech Specs,Revising Surveillance Std to Which Ventilation Charcoal Must Be Laboratory Tested as Recommended by GL 99-02

ML20212F661
Person / Time
Site:	Beaver Valley
Issue date:	09/20/1999
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20212F656	List: L-99-145, LARs 263 & 138 for Licenses DPR-66 & NPF-73,revising TS Surveillance Std to Which Ventilation Charcoal Must Be Laboratory Tested as Recommended by GL 99-02 ML20212F661
References
GL-99-02, NUDOCS 9909280312
Download: ML20212F661 (20)

Text

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ATTACHMENT A-1 Beaver Valley Power Station, Ursit No. 1 License Amendment Request Ze 263 The following is a list of the affected pages:

Affected Pages: 3/4 7-17 3/4 7-18 3/4 7-18a 3/4 7-18b 3/4 7-19 3/4 7-20 3/4 7-21 1

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l 9909200312 990920 PDR ADOCK 05000334 p PDR

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hPLANT 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 room air temperature is 188'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.

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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 or (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 housing or (3) following painting, fir,e or chemical release in any ventilation zone communicating Pith 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 H510-1980 while operating the flow rate of 800 - 1000 cfm.

tE,31d Q srstem_at_a_Q ventilation Tkr reme vo

2. @^snbjectTn f the carbon ~ contained in at least one test canister or at least tw6 carbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of 1 99% for radioactive methyl iodine at an air flow velocity of .68 ft/see 120% with an inlet methyl iodide concentration of 1.5 to 2.0 mg/m3 , 170% relative humidity, and 30*C 11/2*C other test i shall be in accordance with S2 N510-1989L, The conditions carbon samples not obtained fromf__ 'st canisters shall be prepared by either:

(Srm p 3To3_,9 $3) a) Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining a sample volume equivalent to at least l two inches in diameter and with a length equal to the thickness of the bed, or b) Removing a longitudinal sample from an adsorber I tray using a slottes-tube sampler, mixing 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 3/4 7-17 Miendment No.109 (Pro (>osed UMd Eq }

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D PLANT SYSTEMS

. . SURVEILLANCE REQUIREMENTS (continued)

3. Verifying a system flow rate of 800 - 1000 cfm during system operation.

d. At least once per 18 months by:

1. Verifying that the pressure drop acrosit the combined HEPA filters and charcoal adsorber banks is <6 inches Water Gauge while operating the ventilation system at a 1 flow rate of 800 - 1000 cfm . /

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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 l!

isolate the combined control room from the outside l atmosphere.

3. Verifying that one emergency ventilation subsystem l

,~~~'-' maintains the combined control room at a positive j pressure of >1/8 inch Water Gauge relative to the i a3 leash 3.%7 y' outside atmospEere during system operation.

u S not e.ycece q p m J-Verifying that the heaters dissipate I

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tested in accordance with ANSI N510-1980.h + C 4.7.7.1.2 The BV-2 emergency ventilation s'ubsystems shall be demonstrated OPERABLE: ,

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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 188'F.

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b. At least once per 31 days by initiating flow through each l NEPA 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.

BEAVER VALLEY - UNIT 1 3/4 7-18 Amendment No. M,116

( posec f Wor cI $ m; )

[25ED PLANT SYSTEMS SURVEILLANCE REQUIREMENTS, Continued (JJ:4k6 34 % s a 4 k r- re ww w%)

2. ,SM eeting the carbon contained in at least one test I canister or at least two carbon samples removed from i one of the . charcoal adsorbers to a laboratory carbon l sample analysis and verifying a removal efficiency of I

>99% for radioactive methyl iodine at an air flow l velocity of 0.70 ft/sec 120% with an inlet methyl I iodine concentration of 1.5 to 2.0 mg/m3,.)_70% relative humidity, and 30*C il/2*C othar___ test conditions shall be in accordance with dQLSI_ N510_1_jl8]E,e The carbon samples not obtained from test canisters shall be prepared by either: AS 386Ei%p a) Emptying one entire bed from a removed adsorber trey, 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 the combined HEPA I filters and charcoal adsorber banks is less than 5.6 inches Water Gauge 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 either Unit, the system automatically closes all the series l

. 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 ,

I filters and charcoal adsorber banks.

3. Verifying that on a chlorine test signal from either Unit, the system automatici11y closes all the series I)i isolation ventilation system dampers which isolate the combined control room from the outside atmosphere.

BEAVER VALLEY UNIT 1 3/4 7-18a Amendment No. MR,116

( Yro pcseal LO cu- d l'n g )

+

PLMfT SYSTDtS

' SURVEILLANCE REQUIREMENTS, (continued)

4. Verifying that one emergency ventilation subsystem maintains the control room at a positive pressure of 2,1/8 inch Water Gauge relative to the outside atmo, sphere during system operation.

5. Verifying that the heaters dissipate kw when i tested in accordance with ANSI N510-1980. 4 5 leu < 3.37 k ne f -en c e et QC,so, 4.7.7.2 The bottled air pressurization system shall bi 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 orb per 18 months @ verifying that: .

1.' A chlorine /controlroomhEghradiation/ containment phase B isolation test signal from either Unit I will initiate system operation.

2. Upon a partial discharge test using four out of five bott'M air subsystems the system will supply 3, 1000 cC.r. of air and pressurize the control room to >1/8 inch Water Gauge relative to the outside atmosphere during system operation.

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BEAVER VALLEY UNIT 1 3/4 7-18b Amendnent No. Ma16

( ProrcF J W e'd h )

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(bPRM PLANT SYSTEMS 3/4.7.8 SUPPLPMENTAL LFAX COLLFCTION AND RELFASE (SLCRS) SYSTEM LIMITING CONDITION FOR OPERATION 3.7.8.1 Two SLCRS exhaust air filter trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one SLCRS exhaust air inoperable train to filter train inoperable, restore the HOT STANDBY within OPERABLZ status within 7 days or be in at least following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. 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 SKUTDOWN within the SURVEILLANCE REQUIREMENTS 4.7.8.1 Each SLCRS OPERABLE: exhaust air filter train shall be demonstrated a.

At least once per 31 days on a STAGGERED TEST BASIS by:

1. Initiating, from the control roomt flow through the HEPA filter and charcoal adsorber' train and verifying that the train operates r at least 15 minutes.

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b.

At least once per C12 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 or replacement of a HEPA (1) after each complete or partial l

(2) after any structuralfilter or charcoal adsorber bank, or charcoal adsorber housings, maintenance on the HEPA filter or or chemical release in any or (3) following painting, fire with the system by: ventilation zone communicating

1. Verifying that the halogenated hydrocarbon charcoal adsorbers remove 2 99% of a refrigerant test gas when they are testing in-place in while operating accordance with ANSI N510-1975 36,000 cfm i 10%. the ventilation system at a flow rate of 1

BEAVER VALLEY - UNIT 1 3/4 7-19 Amen &ient No.151 (Pro sect oJo rd /q )

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PLANT SYSTD!S

$URVE1LLANCE REQUIREMENTS (Continued)

2. Verifying that the liEPA filter barles remove 99% of the DOP vhen they are tested in-place in accordance with ANSI N510-1975 while operating the ventilation system at

,R av rata of 36.00R_cf + 10%.

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3. [ Subjecting the carbon contained in at least one test canister or at least two catbon samples removed from one of the charcoal adsorbers to a laboratory carbon sample analysis and verifying a removal efficiency of 2 90% for 3 radioactive methyl iodide at an air flow velocity ft/sec : 20% vith 3an inlet methyl iodide concentrationof 0.9 ho#Ctbh ,

, t 0.05 to 0.15 mg/m , 395% relative humidity, and 12 ' _

other test conditions shal ^

standard _ M-16-1T, June 197[l be in accordance with The carbon samples not obtained h57M D3Sc3 from test canisters shall be prepared by either:

a) Emptying one entire bed from a. removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least rao inches in diameter and with a length equal to the thickness of the bed, or -

b) Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

4. Verifying a system flow rate of 36,000 cfm : 10% during system operation.

c. At least once per 19 months by:

1. Verifying.that the pressure drop across the combined HEPA filters and charcoal adsorber banks is 46 inches Water Cauge while operating the ventilation system at I a flow rate of 36,000 cfm : 10%.

i 3/4 7-20 Amendrgent No 56 S E A VE R' V ALL E Y- U NIT 1

( pro pe sc h v) od hy )

j PLANT SYSTEMS

. . SURVEILLANCE REQUIREMENTS (Contirued)

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2. Verifying that the air flow distribution to each HEIPA filter and charcoal adsorber is within + 20% of the

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teraged flow per unit.

[@. Verifying that the SLCRS flow is diverted through the filter train en a Containment Isolation - Phase "A" signal.

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BEAVER VALLEY - UNIT l 3/4 7-21

( Prep ;eef Mc v d t s

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ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 License Amendment Request No. 138 l l

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The following is a list of the affected pages:

Affected Pages: 3/4 7-16 3/4 7-17 l 3/4 7-18 l l

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m 2

, i PLANT SYSTEMS 1 1

• 3/4.7.7 CONTROL ROOM EMERGENCY AIR CLEANUP AND PRESSURIZATION SYSTEM SURVEILLANCE REOUIREMENTS 4.7.7.1 The Control Room Emergency Air Cleanup and Pressurization System 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:

1. Initiating flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for 15 minutes with the heaters in operation.

2. Verifying that the bottled air pressurization system contains a minimum of 10 bottles of air each pressurized to at least 1825 psig and that each solenoid operated valve is powered from an operable emergency bus.

c. At least once per 18 months or (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 by:

1. Verifying that the charcoal adsorbers remove > 99.95% of a halo-genated hydrocarbon refrigerant test gas when~they are tested in place in accordance with ANSI N510-1980 while operating the pressurization filtration system at a flow rate of 800 to 1000 cfm.

2. Verifying that the HEPA filter banks remove > 99.95% of the 00P l

when they are tested in place in accordance with ANSI N510-1980 while operating the pressurization filtration system at a flow i rate of 800 to 1000 cfm. '

3. Verifying a system flow rate of 800 to 1000 cfm during system  ;

operation. l

d. At least' once per 18 months or (1) after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system opera-tion, or (2) following painting, fire or chemical release in the

- m vicinity of control room outside air intakes while the system 4fls

>J.G 31 %) operatin(t ter or aleast two carbon samples removed from one of the charcoalsu

1. ,(y peu ,

adsorbers to a laboratory carbon sample analysis and verifying a re-moval efficiency of > 997, for radioactive methyl iodide at an air ficw velocity of 0.7~ft/sec + 20% with an inlet methyl iodide con-a>

centration 1/2*C: other oftest 1.5 conditions to 2.0 mg/m sha, T1 be in accordance with70%

NSD relative humidit (p

L-y g 3-igl if510-1BDI"The carbon samples not obtained from test can stars shall be prepared by either:

BEAVER VAll.EY - UNIT 2 3/4 7-16

( Pro fyek e<f .'7g)

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) a) Emptying one entire bed from a removed adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diamete= and with a length equal to the thickness of the bed, or b) Emptying a longitudinal sample from an adsorber tray, mixing the adsorbent thoroughly, and obtaining samples at least two inches in diameter and with a length equal to the thickness of the bed.

e. At least once per 18 months by:

1. Verifying that the pressure drop for the combined HEPA filters and charcoal adsorber banks is less than 5.6 inches Water Gauge while operating the pressurization filtration 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, the system automatically closes all the series isolation ventilation system dampers which isolate the 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 the system auto-matically closes all the series isolation ventilation system dampers which isolate the combined control room from the out-side atmosphere.

4. Verifying that the pressurization filtration system maintains the control room at a positive pressure of > 1/8 inch Water Gauge relative to the outside atmosphere during system operation.

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Verifying that the heaters dissipate 5 i 0. kw when tested in (1 EE ') 5. accordance with ANSI N510-1980.

6. Verifying that a chlorine / control room high radiation / containment phase B isolation signal will initiate operation of the bottled air pressurization system.

7. Verifying by a partial discharge test from four out of five sub-systems of the bottled air pressurization system at a discharge flow of less than 1000 cfm that the bottled air pressurization system will pressurize the control room to > 1/8 inch Water Gauge relative to the outside atmosphere during system operation.

BEAVER VALLEY - UNIT 2 3/4 7-17

( Pre psed Went ?q )

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[hk7,33 l PLANT SYSTEMS 3/4.7.8 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS) 1 LIlilT.ItE14 TID 11 TON FOR OPERATION 3.7.8.1 Two SLCRS exhaust air filter trains shall be OPERABLE. '

APPLICA8ILITY: MODES 1, 2, 3 and 4.  !

ACTION:

With one SLCRS exhaust air filter train inoperable, restore the inoperable train to OPERA 8LE status within 7 days or be in at least HOT STAN0BY 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 />.

j suRVEILLANCF RFnUIREMENTS 4.7.8.1 Each SLCRS exhaust air filter train shall be demonstrated OPERABLE:

a. At least once per 31 days by initiating, from the control room, flow' through the " standby" HEPA filter and charcoal adsorber train and verifying that the train operates for at least 15 minutes with the heater controls operational.

b. At least once per 18 months or (1) after each complete or partial l replacement of a HEPA filter or charcoal adsorber bank, or (2) after l 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 charcoa'l adsorbers remove 199.95% of a halo-genated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1980 while operating the ventilation system at a flow rate of 57,000 cfm + 10%.

2. Verifying that the HEPA filter banks remove > 99.95% of the DOP I when they are tested in place in accordance with ANSI N510-1980 '

while operating the ventilation sy: tem at a flow rate of 57,000 cfm

• 105.

w & 31 d'"/

ab rwM ~ ~y 3. f 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 > 995 for radioactive methyl iodide at an air flow velocity of 077 ft/sec

• 205 with an inlet methyl iodide concentration of 1.5 to 2.0. og/es, > 705 relative humidity, and 39'C 1 k'C: othe. test conditions shall be in accordance As rat .p3tro3, g g6 w $ PSI M510-1 . The carbon samples not obtained from test canisters sna n be taken with a slotted tube sampler in accord-ance with ANSI N509-1980.

BEAVER VALLEY - UNIT 2 3/4 7-18 Amendment No. M. 28

( f> r o pse. c9 W e kV I"g )

r ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request No. 263 and 138 REVISION OF CONTROL ROOM VENTILATION & SLCRS TECHNICAL SPECIFICATIONS l A. DESCRIPTION OF AMENDMENT REQUEST This license amendment request revises the standard to which the control room ventilation charcoal and Supplementary Leak Collection and Release System (SLCRS) charcoal must be laboratory )

tested as specified in Beaver Valley Power Station (BVPS) Unit '

No. 1 Technical Specification 4.7.7.1.1.c.2 for the Control Room Emergency Habitability Systems, BVPS Unit No. 1 Technical Specification 4.7.8.1.b.3 for the SLCRS, BVPS Unit No. 2 l Technical Specification 4.7.7.1.d for the Control Room Emergency Air Cleanup and Pressurization System, and BVPS Unit No. 2 Technical Specification 4.7.8.1.b.3 for the SLCRS. As documented in NRC Generic Letter 99-02, " Laboratory Testing of Nuclear-Grade Activated Charcoal," dated June 3, 1999, licensees were requested to revise their Technical Specification criteria associated with laboratory testing of ventilation charcoal to a valid test l protocol, which included ASTM D3803-1989. This license amendment request revises the charcoal laboratory standard to follow ASTM D3803-1989 for each BVPS Unit.

This license amendment request also revises the minimum amount of output in kilowatts needed for the control room emergency ventilation system heaters at each BVPS Unit. Calculations were performed for each Unit to show that the minimum required output of control room emergency ventilation system heaters needed to reduce the incoming air relative humidity from 100% to 70% could be reduced from 4.5 kw to 3.87 kw. This license amendment request also revises BVPS Unit 1 SLCRS surveillance testing criteria to be consistent with ANSI /ASME N510-1980, the BVPS Unit 1 control room ventilation testing, and the BVPS Unit 2 l SLCRS/ control room ventilation testing. This license amendment request also revises minor typographical corrections and l editorial changes. l B. DESIGN BASES Each BVPS Unit No. 1 and 2 control room emergency ventilation system draws air from an outside air intake by an air pressurization fan. The air flows through a heater which is provided to limit the relative humidity of the air to the filter banks. The fan then discharges the air through an emergency outside air filter bank which contains a charcoal filter. The filtered air is introduced into the air conditioning system to maintain the pressurized condition in the control area. The BVPS Unit 1 control room emergency ventilation system is described in i Section 9.13.4 in the BVPS Unit 1 UFSAR. The BVPS Unit 2 control j room emergency ventilation system is described in Section 9.4.1 l in the BVPS Unit 2 UFSAR. Under accident conditions, the control I room air-conditioning system outdoor air intake is closed on a i

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ATTACHMENT B, continu:E;d License Amendment Request Nos. 263 and 138 Page 2 l

1 CIB signal or by operator action, isolating the entire main ,

control area from the atmosphere. Emergency air pressurization l system releases air from its compressed air tanks to maintain the i control room at a positive pressure. Upon depletion of the '

compressed air supply in 60 minutes, the control room emergency ventilation system is initiated to subsequently maintain the control room environment.

The BVPS Unit No. 1 Supplementary Leak Collection and Release System (SLCRS) is described in Section 6.6 in the BVPS Unit No. 1 UFSAR. The BVPS Unit No. 2 SLCRS is described in Section 6.5.3.2 in the BVPS Unit No. 2 UFSAR. The primary function of the SLCRS system is to ensure that radioactive leakage from the primary containment following a Design Basis Accident (DBA), or radioactive release due to a fuel handling accident, or radioactive material released in the waste gas storage area is collected and filtered for iodine removal prior to discharge to the atmosphere at the SLCRS vent. The SLCRS train consists of a leak collection exhaust fan, which exhausts air from many areas where radioactive release may occur. Each train contains a charcoal filter which is effective for radioactive iodine removal.

C. JUSTIFICATION The proposed changes to the surveillance requirements for the laboratory testing of ventilation system charcoal are consistent with Generic Letter 99-02. The proposed change will adopt ASTM D3803-1989 as the laboratory testing standard for performing the surveillance associated with the Control Room emergency ventilation and the SLCRS charcoal filters at each BVPS Unit.

This standard provides the assurance for complying with the BVPS Unit 1 and Unit 2 licensing basis as it relates to the dose limits of GDC 19 and 10 CFR Part 100 as discussed in Generic Letter 99-02. The laboratory testing surveillance change also proposes a limitation of conducting the testing within 31 days after the charcoal is removed, in accordance with the recommended criteria described in Generic Letter 99-02 Attachment 2.

Previously the Technical Specification surveillances listed no specific limitation for the time frame to conduct the laboratory testing after the charcoal was removed.

A design calculation was completed for each BVPS Unit showing that the minimum required capacity of the Control Room emergency ventilation system heaters needed to reduce the incoming air relative humidity from 100% to 70% was 3.87 kw. The current Technical Specification requirement for minimum control room emergency ventilation system heater output was 4.5 kw. This conclusion was based on the current Technical Specification requirement for flow through the filters to be a maximum of 1000 cfm, with.outside conditions assumed to be 90F and 100% RH.

The calculation addressed the energy needed to increase the outside air from 90F to 102F in order to reduce the relative B-2

7 ATTACHMENT B, continu:d l Lic;nra Am:ndm:nt Requsst Nos. 263 and 138 l Page 3 humidity from 100% to 70%. The calculated heater output was determined to be 3.87 kw. Therefore, the proposed minimum level of heater output will be sufficient to meet the system design requirements.

The BVPS Unit 1 SLCRS Technical Specification surveillance 4.7.8.1.b is proposed to be changed from a frequency of every 12 months to a frequency of every 18 months. This surveillance includes the charcoal adsorber in-place test gas removal testing, the HEPA filter in-place test gas removal testing, and the charcoal adsorber sample laboratory analysis testing. The proposed surveillance interval is acceptable based on the testing history of SLCRS at BVPS Unit 1. The testing history of SLCRS at BVPS Unit 1 shows that there has never been a HEPA filter failure discovered during DOP testing performed to satisfy Technical Specification 4.7.8.1.b.2 nor a mechanical efficiency failure of an adsorber bank discovered during testing performed to satisfy Technical Specification 4.7.8.1.b.1. This proposed frequency is also consistent with the frequency listed in ANSI /ASME N510-1980, Table 1, " Tests and Recommended Test Frequency," which suggests that the in-place leak test for laboratory testing of adsorbers, for HEPA filters in-place testing, for adsorbers in-place testing be at least once every operating cycle (in addition to the criteria for after every adsorber/ filter change). The current operating cycle for BVPS Unit 1 is 18 months. The current Technical Specification surveillance criteria for similar adsorber/ filter testing on the BVPS Unit 1 control room emergency ventilation system (4.7.7.1.d) is 18 months, consistent with once per operating cycle. This BVPS Unit 1 Technical Specification on the control room emergency ventilation system was revised from a frequency of 12 months to 18 months during License Amendment No. 109, dated May 20, 1987, based on the testing criteria meeting ANSI N510-1980. The current Technical Specification for similar adsorber/ filter testing on the BVPS Unit 2 SLCRS

( 4 . 7. 8 .1. b) and control room emergency ventilation system (4.7.7.1.1.c) is also 18 months, consistent with once per operating cycle. Thus the proposed change for adsorber/ filter testing on the BVPS Unit 1 SLCRS would make it consistent with both ANSI /ASME N510-1980 and similar Technical Specification criteria at both Unit 1 and Unit 2.

BVPS SLCRS Technical Specification 4.7.8.1.c.2 is proposed to be changed to verifying the air flow distribution to each HEPA filter and charcoal adsorber "after each initial installation and after any maintenance affecting the flow distribution," rather than once every 18 months. The proposed surveillance criteria is acceptable based on the testing history of SLCRS at BVPS Unit 1.

The testing history of SLCRS at BVPS Unit 1 show that the flow distribution surveillance test has been performed fourteen times since 1980 with no failed test results. This change is also consistent with ANSI /ASME N510-1980, Table 1, " Tests and Recommended Test Frequency" which states the air flow distribution test should be conducted after completion of initial B-3

p ATTACHMENT B, continund License Amendment Request Nos. 263 and 138 Page 4 construction and after any major system modification or repair.

This proposed change to the Unit 1 SLCRS Technical Specification frequency would make it consistent with the Unit 2 SLCRS Technical Specification 4.7.8.1.d surveillance frequency for air flow distribution testing which is "after initial installation and after any maintenance affecting the flow distribution." Air flow distribution through a ventilation system adsorber/ filter should not change unless there is some modification in the system arrangement which would cause a flow distribution change. Thus the proposed BVPS Unit 1 Technical Specification frequency change is consistent with the potential causes for what could cause an .

actual air flow distribution alteration. l The addition of the unit license number at the top of the page is an editorial administrative change to address site records criteria. Other editorial changes include changing the word "be" in BVPS Unit 1 Technical Specification 4.7.7.2.b to "by" which was a typographical error. BVPS Unit 2 Technical Specification 4.7.7.1.d removed an inadvertent extra "s" from the word

" system."

D. SAFETY ANALYSIS The proposed changes to the surveillance requirements for the laboratory testing of ventilation system charcoal are consistent with Generic Letter 99-02. The proposed change will adopt ASTM D3803-1989 as the laboratory testing standard for performing the surveillance associated with the Control Room emergency ventilation and the SLCRS charcoal filters at each BVPS Unit.

This standard provides the assurance for complying with the BVPS Unit 1 and Unit 2 licensing basis as it relates to the dose limits of GDC 19 and 10 CFR Part 100 as discussed in Generic Letter 99-02. Thus this change ensures that the current licensing basis is maintained.

The proposed change to the minimum required capacity of the Control Room emergency ventilation system heaters to 3.87 kw is acceptable because this lower value will continue to meet the system desiga criteria for reducing the incoming air relative humidity from 100% to 70%. Therefore, the proposed minimum level of heater output will be sufficient to meet the system design requirements providing continued acceptable control room emergency ventilation system operation.

The BVPS Unit 1 SLCRS Technical Specification surveillance 4.7.8.1.b is proposed to be changed from a frequency of every 12 months to a frequency of every 18 months. The proposed surveillance interval is acceptable based on the BVPS Unit 1 testing history showing no mechanical efficiency failures of an adsorber bank nor any HEPA filter failures discovered during DOP testing pursuant to Technical Specification 4.7.8.1.b.1 or 4.7.8.1.b.2. The proposed frequency is also consistent with the frequency listed in ANSI /ASME N510-1980, Table 1, " Tests and B-4 l

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l ATTACHMENT B, continund License Amendment Request Nos. 263 and 138 Page 5

. I Recommended Test Frequency," which provides a surveillance frequency acceptable for testing of nuclear air cleaning systems.

Thus the proposed change for adsorber/ filter testing on the BVPS Unit 1 SLCRS would continue to provide an acceptable testing frequency to verify system operation.

J BVPS SLCRS Technical Specification 4.7.8.1.c.2 is proposed to be changed to verifying the air flow distribution to each HEPA filter and charcoal adsorber "after each initial installation and after any maintenance affecting the flow distribution," rather i than once every 18 months. The proposed surveillance interval is acceptable based on the BVPS Unit 1 testing history showing no )

failed test results in the fourteen flow distribution surveillance tests performed since 1980 pursuant to Technical Specification 4.7.8.1.c.2. The proposed frequency is also consistent with the frequency listed in ANSI /ASME N510-1980, Table 1, " Tests and Recommended Test Frequency," which provides a surveillance frequency acceptable for testing of nuclear air ,

cleaning systems. Thus the proposed change for adsorber/ filter l testing on the BVPS Unit 1 SLCRS would continue to provide an {

acceptable testing frequency to verify system operation.

The addition of the unit license number at the top of the page is an editorial administrative change to address site records criteria. Other editorial changes include changing the word "be" in BVPS Unit 1 Technical Specification 4.7.7.2.b to "by" which was a typographical error. BVPS Unit 2 Technical Specification 4.7.7.1.d removed an inadvertent extra "s" from the word

" system."

E. NO SIGNIFICANT HAZARDS EVALUATION The no significant hazard considerations involved with the proposed amendment have been evaluated. The evaluation focused on the three standards set forth in 10 CFR 50.92(c), as quoted below:

The Commission may make a final determination, pursuant to '

the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or l consequences of an accident previously evaluated; or 1 (2) Create the _ possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

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ATTACHMENT B, continund License Amendment Request Nos. 263 and 138 ]

Page 6 The following evaluation is provided for the no significant hazards consideration standards.

1. Does the change involve a significant increase in the 4 probability or consequences of an accident previously l evaluated? l The proposed changes to the surveillance requirements for the laboratory testing of ventilation system charcoal are consistent with Generic Letter 99-02. The proposed change will adopt ASTM D3803-1989 as the laboratory testing )

standard for performing the surveillance associated with the  !

Control Room emergency ventilation and the SLCRS charcoal )

filters at each BVPS Unit. Thus this proposed change will l not involve a significant increase in the probability or consequences of a previously evaluated accident since this standard provides the assurance for continuing to comply with the current BVPS Unit 1 and Unit 2 licensing basis as it relates to the dose limits of GDC 19 and 10 CFR Part 100.

The change in the control room emergency ventilation system heater minimum output at both BVPS Units does not change the system ability to meet its design bases. The change in the BVPS Unit 1 SLCRS testing frequency for adsorber/ filter in-place testing and the adsorber laboratory testing does not change the SLCRS system's ability to meet its design bases.

The change in the BVPS Unit 1 SLCRS testing frequency for SLCRS air flow distribution testing does not change the SLCRS system's ability to meet its design bases. Therefore, these changes will not increase the probability cf occurrence of a postulated accident or the consequences of an accident previously evaluated since these systems' ability to operate as required remains unchanged.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The proposed license amendment to the control room emergency ventilation system and SLCRS at both BVPS Units does not change the way the system is operated. The proposed changes only involve changes to the surveillance testing. These testing modifications do not alter these systems' ability to perform their design bases. Therefore, these proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated accident since the control room emergency ventilation system and SLCRS will continue to operate in accordance with their previous design bases.

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ATTACHMENT B, continund License Amendment Request Nos. 263 and 138 Page 7

3. Does the change involvo a significant reduction in a margin of safety?

The proposed amendment does not involve revisions to any safety limits or safety system setting that would adversely )

impact plant safety. The proposed amendment does not affect the ability of system, structures or components important to the mitigation and control of design bases accident conditions within the facility. In addition, the proposed amendment does not affect the ability of safety systems to ensure that the facility can be maintained in a shutdown or refueling condition for extended periods of time. 4 The proposed license amendment to the control room emergency  ;

ventilation system and SLCRS at both BVPS Units does not 1 change the way the system is operated. The proposed changes only involve changes to the surveillance testing. These testing modifications do not alter these systems' ability to perform their design bases. The existing safety analyses remain bounding. Therefore, the margin of safety is not adversely affected.

4 F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that l the activities associated with this license amendment request l satisfy the requirements of 10 CFR 50.92(c) and, accordingly, a no significant hazards consideration finding is justified.

G. ENVIRONMENTAL CONSIDERATION l This license amendment request changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. It has been determined that this license amendment request involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. This license amendment request may change requirements with respect to installation or use of a facility component located within the restricted area or change an inspection or surveillance requirement; however, the category of this licensing action does not individually or cumulatively have a significant effect on the human environment. Accordingly, this license amendment request meets the eligibility criteria for i I

categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Pursuant to 10 CFR 51. 2 2 (b) no environmental impact statement or environmental assessment need be prepared in connection with the l issuance of this license amendment request.

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- H.- .UFSAR-CHANGES This proposed-license amendment would not' result in any changes to:either,the BVPS Unit 1 or Unit 2 UFSAR.

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