ML20212M554

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Advises That Review of Tech Specs Re Installed Filter Sys Indicates Need for Addl Limiting Conditions for Operations & Surveillance Requirements.Application for Amend to License DPR-35 Requested within 45 Days of Ltr Date
ML20212M554
Person / Time
Site: Pilgrim
Issue date: 01/07/1975
From: Ziemann D
US ATOMIC ENERGY COMMISSION (AEC)
To: Feldman M
BOSTON EDISON CO.
Shared Package
ML20212M446 List:
References
NUDOCS 8701300160
Download: ML20212M554 (10)


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UsetTED STAT M ATOMIC ENWISY COMMISWON

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January 7, 1975 y

Docket No. 50-293 gL 7

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Boston Edison Company h

ATTN: ter. Maurice J. Feldesan Vice President

[v Operations and Engineering

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800 Boylston Street Boston, Massachusetts 02199 Gentlemen:

Our review of your Technical Specifications related to insta11d filter systems indicates a need for additional Limiting conditione for Operation These are required is order to 43 (140) and Surveillance Requirements.

ensure high confidence that the systems will function reliably, when moeded, at a degree of efficiency equal to or better then that assumed in O

O the accident smalyses.

In order to assist you in the preparation of appropriate revisises,as O

have prepared model Technical Specifications which include IAO's, Serve 111ance Requirements and Bases for the following Pilgria Unit 1 ovetems:

1) Main Control Room Environmental Control Systems N
2) Standby Gas Treatment System to submit by no later then 45 days from the date of You are r e

lication for amenement to your Ise - tuns would O

this 1 Specifications related to tastalled f11ter eyetens chemSe the Techairal so as to be in comforenace with the requiremente in the amm1M model O

Technical Specifications, Sincerely, ww' m

Deania L. Eiemaan ief Operating Ranctore Breech #2 Directorate of Licensing Enclosera Model Technical Specificatione fh ces See mest page

/o ao 8701300160 870127 PDR ADOCK 05000293 n

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UttfTED STATES ATOMIC ENUW3Y COMMISS4CN d

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-o-January 7, 1975 h

6% g Docket No. 50-293 a

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Boston Edison Company

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h ATTN:

Mr. Maurice J. Feldmann Vice President

[g Operations and Engineering T

800 Boylston Street

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Boston, Massachusetts 02199 Centlement Our review of your Technical Specifications related to installed filter systems indicates a need for additional Limiting Conditions for Operation These are required in order to e

(LCO) and Surveillance Requirements.

ensure high confidence that the systems will function reliably, when needed, at a degree of efficiency equal to or better than that assumed in O

C the accident analyses.

In order to assist you in the preparation of appropriate revisines, we O

have prepared modal Technical Specifications which include LCO's, Surveillance Requirements and Basse for the following Pilgria Dait i systems:

1) Main Control Room Ravironmental Control Systems CM
2) Standby Ces Treatment System You are requasted to submit by no later thes 45 days from the dat_a_of this letm==.pplication for

-- t to your license tnat would O

change the Technical Specificatione related to installed filtar systeme so as to b-in conformance with the requirensets in the maniamed model g

Technical Specifications.

Sincerely, f

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wvwas n-Dennis L. Zie= ann, iaf Operating Reactors Branch #2 Directorate of Licensing Encloeures Model Technical Specifications fh A

,to ect See next page

/o t 8701300160 870107 PDR ADOCK 0500009J P

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q Boston Edison Company "

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Mr. Dale G. Stoodley, Counsel Boston Edison Company 800 Boylston Street Boston, Massachusetts 021M Mr. J. Edward Howard, Superintendent Nuclear Engineering Department Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Mr. Grant Baston, Pilgrim Division Beed Boston Edison Company EyD #1 Rocky Hill Road 02360 Plymouth, Massachusetts N

Mr. Winfield M. Sides, Jr.

Quality Assurance Manager O

800 Boylston Street Boston, Maseachusetts 02199 O

Anthony Z. Rotsman, Esquire O

Berlin, Roisaan and Kessler 1712 N Street, N. W.

9 Washington, D. C.

20036 Plymouth Public Library g

North Street N

Plymouth, Massachusetts 02360 Mr. J. E. Larson Senior Licensing Engineer o

and Co-ordinator j

Boeton Edison Company o

EyD #1 Rocky Hill Road Plymouth, Massachusetts 02360 0

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ooo, O '1. a C'A TECHr.!CfL SPECIFICATTCNS

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4.7 SURVEILLANCE REGUIRDE'iTS 3.7 LIMIT!*i CONDITIONS FOR OPERATION 8.

Stan6y f%s Trectment System l

8.

Standby Gas T-eatr.ent Systen 1.

At least once per operating cycle, the 1.

Except as specified in Specification following conditions shall be de.,onstrated.

3.7.8.3 below, both circuits of the standby gas treate.cnt system and the a.

Pressure drop across the conbined e

diesel ger.crators required for HEPA filters and charcoal adsorber k.D ^

operation of such circuits shall be banks is less than inches of /

wateratthesysten@<esignflow operable at all times hten secondary containment integrity is required.

rate.

2.

a.

The results of the in-place cold DOP d,f,

b. fnlet heater input is capable of
p.and halo enated hydrocarben tests at I4f freducingR.H.from100to707.R.H.

design f ows on HEPA filters and

- o wC charcoal adsorber banks shall show Air distribution is uniform within M

>99% 00P removal and > 99%

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Ealogenated hydrocarbon removal.

I 20% across HEPA filters and charcoal l y

e tests and sample analysis of.

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results of laboratory carbon }

sasple analysis shall show >95%

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Specification 3.7.8.2,sh,g,1) jy

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_ amoaccmurethyl iodide rEnoval

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performed initially a_nd at least w

I at a velocity within 20 percent of once.per year for standby service

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actuglsystendesign,0.5to1.5 cr after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of

.3 inlet methyl iodido concentra-system operation and following j

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t on. >,,70% R.H. and >190*F.

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( significant painting. fire or J

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Fans shall be shown to operate within /

chemical release in any ventilation zone coemunicating with the system.

?,,10% design ficw.

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Cold DOP testing shall be perfenned E Q;

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'after each complete or partial pg wee.1 oNI] Ym g,4 cnooA -flow 7' replacement of the HEPA filter M '. ' 3 bank or after any structural

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d N e n,, g, c p u,a 2 maintenance on the system housing.

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O OO I24 BWR TECMMICAL 59ECIFICATIO'iS

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]F 4.0 St.'RVEILLA:tCE REQUIRFT.ENTS LIMITING CONDITIONS FCR OPERATION 3.7 911cgenated hydrocarbon testing shall

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be perforred after each complete er I-

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partial rcplaccecnt of the charcoal s

adsorber bank or after any structural Cl gp traintenar.cc on the systers housing.

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Each circuit shall be cperated with

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the heaters ori at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> every

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f Test sealing of gaskets for housing doors tWnstream of the HEPA filters M

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and charcoal adsorbers shall be performed 8 at and in confomance with each test ef. h [,.< C - [/

perfonred for compliance with 4

0; Specification 4.7.6.2.a and Specification 3.7.B.2.a.

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System drains e.cre present shall be 1%

qucrterly for adequate water level in Je Frcm and after the date that one l

3.

circuit of the standby sas treatment loop-seals.

system is made or four.d to be At least once per operating cycle inoperable for any reason, recctor 4.

4.

automatic initiation of each branch operation and fuel handling is of the standby gas treatment system permissible only during the succeeding a

seven days unless such circuit is sooner

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made operable, provided that during j7J.At least once per operating cycle 7

1 such seven days allsactive components

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msnual operability of the bypass valve g.

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for filter cooling shall be dueenstre

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circuit shall be operable.

a When one circuit of the standby gas If these conditions cannot be met, o

procedures shall be initiated treatment system becomes inoperable c.

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t sha H k M a h W inr:ediately to establish reactor MN o

rc conditions for which the standby

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3.7.8 Standby Gas Treatment System Ust the reactor butiding ateosphere to The star.dby gas treatrent system is designed to filter ar.d exh:Both stancy gas treatmant system fans the stack during secondary cantain: cr.t isolatien conditions.

q are destgr.ed to autcrratically start upon contairrr.ent isolation and to maintain the reactor bu Should one system pressure to the design r.egative pressure so that all leakage should be in-leakege.Each of the two fans has 10 fail to start, the redundant system is designed to start automatically.

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High efficiency particulate absolute (HEPA) filters are installed before and after the charcoal ad to minimize potential release of particulates to the envirorcent and to prevent clogging of the iodine The charcoal adsorbers are installed to reduce the potertial release adsorbers.

bypass leakage for the ch:rcoal *.dsorbces and a HEPA cffic:crcy of at least 99 percent rer.- al of g

environment.

.ethv )iedide g The laboratcry carbo.i scep'c test results sheu!d indicate a....m uuIf the ef icier,cies particulates.

rencval efficiency of at least 95 percent for expected accident conditions.

of the HEPA filters and charcoal adsorbers are as specified, the resulting doses wil' be less than the 1Q. fro 100 cuidelines fs-.de,,, accidents analyzed.J Cperation of the fans significant'y different f EN /b design flow will change the ren.,vai ctricicncy of the NEPA filters and charcoal adsorbers.

pT Only one of the two standby gas treatment systems is needed to cicanup the reactor buildir.g at=os Mh If one system is found to be inoperable there is no israediate threat to the containment system performance and reactor operation or refueling operatio'n upon contairment isolation.

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repairs are being made.

g standby gas treatment system is not required.

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Standby Gas Treat.-ent Syste-less thar 6 nches of water at 4.7.3. Pressure drop across the co-bined HEPA filters and ctarcoal s are not c ogged by excessive d b the system design flow rate will indicate that the filters and a sor er a.ounts of foreign matter.at least once por op* rating cycle to sPc. systen parfemarce ca;;bility, u

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The frequency of tests and o r ple ahalysis are nermw to sh et tht t s'or tne cc.crcoal adsorders uith haloganated hydrocarton refrig rfom as evaluat 07-1082. for the rer:vai or p [#. h can r orted in accordance with USAEC Report ge. Standard M-16-1T/ The enarcoal adscrber ef ficiency test procedures should all:w g one acsoroer tray, emptying of or.e bed fec, the tray, mixing the Each srple should be at least two inches in dicacter and a length equal d If test results are unccceptable, all adsorbent in,the system shall be replac at least two sccples. ida 1.52. The replacerr.cnt tray for I.F# ygthickness of the bed.j with an adsor'ocnt qualified according to Table 1 of Regula Tests of the HEFA filters lity. the adsorber tray removed for the test shocid meet the sane adsorbent quaAny HEPA filters found da with 00p aerosol shall be performed in acccedance to ANSI N101.1-1972. f Regulatory Guide 1.52. /[ad shall be replaced with filters qualified pursuant to Regulatory Position C.3.d o

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the test of heate. All elements of the heater should be demonstrated to be functional tm i [,, capacity. externally 'cag the 'I linear check the y ket scal. ny dote n of 00P the fan ust NS W doo closed fan in op-tion. 0 -rosol shal spre sh:11 b ns. ad an u. ptable t re uit an be gaskets airs an .st repea b ach res,. tive door A88f peri ry o

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w p, cm i. uy-pass ieaxd5e ii uo th0 5'4L h coal adsorber Tevel could become contaminated from the fumes, chemicals or foreign The determination of significant shall be made by

Sall be performed as required for operational use. Knowledgeable staff members should be consulted prior the operator on duty at the time of the incident.

to making this determination. umiliv vi siit.er cco.ing i:. inc;n 7 E w o.u.m on of the automatic initiation capn iii b o %~If one standby pas treatment system is ino h s reactor operi asw er ay nem perrorrance capability.This substantiates the avnilability of the operable syste'n and t mast be i.ested daily. can continue for a limited period of time. er refueling operation

m O..f.4 ~ .T Gboi2 G ooi24 PWR AND 8WR TECHNICAL SPECIFICATIONS 1.: ,.Y I 4.0 SURVE!LLANCE REQUIREE NTS 3.0 LIMITING CON 0!TIONS FOR OPERATION 'a :. +m 8. Control Roers Air Trea*===t swstem 8. Control Room Air Treatment System At least once per operatino cycle, the R 1. Except as specified in Specification pressure drop across the castined MM 3.0.8.3 below, the control room air filters and charcoal adsorter banks ( g/ j A h d I treatment system and the diesel shall be demonstrated to be less them Ng& y 1 generators required for operation 6 inches of water at system design fles of this system shall he ansrable 9 4 ' 4A M -<at all timmt "--Contjainmen 37#O[,, sa d filteority is movind. 2.

a. TThe tests and sample amelysis of 9

Specificat%cn 3.0.8.2 shall be ,4 2. a. The results of the in-place cold performed initially and at least - 4 DW and halogenated hydrocartpon I servicei e once per year tests at design ficws on'HEPA or after of ten Fx filters and charcoal adsorber banks /[. en and ft igni shall show >995 00P removal and >995 1 release painting, fire er halogenate O ydrocartan removal.- in any ventilation zone communicattig { ;< b. The results of laboratory cartpon I with the systen.

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sample analysis shall show >905 radiesctive methyl iodide removal / b. Cold.00P testi shall be perftrum8, 4 at a velocity within 20% of system Q after each or partial y filter beak er Og., ment of theany structure 1 amistenance en to Wip. 0.05 to 0.15 mg/k3 inlet iodide concentration >955 R.H. and >125'F. system housieg. _j ~ Fans shall be shown to operate within

c. Malogensted hydrocorten MM c.

+101 design flow. he perferend efter eseh et P b partial repleesment of the datestaadsorbe maintenance on the system hose W { d. Each cirentt shall be operated at leasGDboves)very-Snth. I H JV

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P'JR AND m:R TEC1"l! CAL SPECIFICATIO:!S_ ~ .q ' I f ' ^ ' 4.0 SURVEILLANCE REQUIREMENTS ,I t 3.0 LIMITI E CONDITIO:ts FOR OPERATION ~ 7, ; a w., ? tr f< At least once per operating cycle 4:h J.,j((t'@ 3. From and after the date that the. automatic initiation of the control control room air treatment system room air treatment gystem shall be. 3 is made or found to be inoperable de:nonstrated. M4 for any reasor., reactor eceration ,ifj 3 refueling operations is fj or i per:nissible only during tha succeeding seven days unless such ' crig g l circuit is sooner made operable. .' ;9) <4 If these conditions cannot be met, reactor shutdown shall be initiated l Qq 4. and the reactor shall be in cold "~d, MK shutdown within 24 hours for ggq reactor operations and refueling yqf operations shall be terminated Ol. irmediately. - + g s

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las3, Control Room Air Treatnent System _

h for intake air 3.0.8. The control room air treatment system is designed to filter the control room atmosp ereThe con and/or for recirculation during control roon isolation conditions. i in the control room system is designed to automatically start upon control room isolation and to ma nta k pressure to the design positive pressure so that all leakcge should be out lea age. l adsorbers to High efficiency particulate absolute (HEPA) filters are installed before the charcoaThe charco prevent clogging of the iodine adsorbers. The in-place test results should indicate a system leakd a HETA effic intake of radio 1odine to the control room. tightness of less than 1 percent bypass leakage for the charcoal adsorbers anThe laboratcry carbon least 99 percent removal of CDP particulatos. least 90 percent for expacted accident conditions. lting doses , a radioactive methyl todide removal efficiency of at will be less than the allowable levels stated in Criterion 19 of the Ge Operation of the fans significantly different from the ) Power Plants. Appendix A to 10 CFR Part 50. design flow will change the removal efficiency of the HEPA filters and charcoal adsorbe { a d reactor If the system is found to be inoperable, there is not i;rcediate threat to the control room u ile repairs are being made. j operation or refueling operation may continue for a limited period of time wh ld shutd wr.

d If the system cannot be repaired within seven days, the reactor is shutdown and brough within 24 hours or refueling operations are terminated.

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f k PW A';D SG TECH!!ICAL $PECIFICATIONS_ i Seses n 4.0.8 Control Reca Air Treatment System _ Pressure drop across the co:6tned HEPA filters and charcoal a ie L Pressure drop should be detemined at least once per operating cycle amounts of foreign matter. to show system performance capability. The frequency of tests and sample analysis are r.ecessary to show that the HEPA fi Tests of the charcoal adsorbers with halogenated hy*irocarbon -1082. Iodine,rgeval efficiency tests shall adsorbers can perfom as evaluated. shall be perfomed in accordance with USAEC RepcrtThe charcoal cdsorber efficiency test procedures sh l d removal of one adsorber tray, ecptying of one bed from the tray, mixing the follow ROT Standard H-16-1T. obtaining at least two sampics. If test results are unacceptable, all adsorbent in the system The shall be replaced with a adsorbe t qualified iccordir.g.to Table 1 of Regulatory Guide 1.52 equal to the thickness of the bcd. replacement tray for the adsorber cray recoved for the test should meet the same ad Tests of the HEPA filters with 00P aerosol shall be perfont.ed in accordance to AflSI fl1 My HEPA filters found defective shall be replaced with filters qualified pursuant to Regu Position C.3.d of Regulatory Guide 1.52. Operation of the system for 10 hours every month will ds..onstrate operabjlity of the f adsorber system and remove excessive moisture built up on the adsorber. If significant painting, fire or chemical release occurs such that the HEPA filter or cha at adsorber could become contaminated from the fu:es, chemicals or foreign materials, the sa The detemination of and sample analysis shall be perforred as required for operational use. Knowledgeable significant shall be made by the operator on duty at the time of the incident. staff menbers should be consulted prior to rakf r.g this determination. Demonstration of the automatic initiation capability is necessary to assurs, systern perfon-an capability. m l '_ o 9*3800 e -}}