ML20212R170

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Proposed Tech Specs,Revising Max Acceptable Pressure Drops Across High Efficient Particulate Air & Charcoal Filters in Emergency Gas Treatment Sys,Auxiliary Bldg Gas Treatment Sys & Control Room Ventilation Sys.Nshc & Justification Encl
ML20212R170
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/17/1987
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20212R165 List:
References
NUDOCS 8704240328
Download: ML20212R170 (13)
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Text

e ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327, -328 (TVA SQN TS 87-10)

REVISION OF THE MAXIMUM ACCEPTABLE PRESSURE DROPS ACROSS THE HEPA AND CHARCOAL FILTERS IN THE ABGTS, ECTS, AND CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIST OF AFFECTED PAGES Unit 1 3/4 6-14 3/4 7-18 3/4 7-20 3/4 9-13 Unit 2 3/4 6-14 3/4 7-18 3/4 7-20 3/4 9-15 8704240328 870417 PDH ADOCK 05000327 p PDR

O '

C0hTAINMENT SYSTEMS

., SURVEILLANCE REQUIREMENTS (Continued)

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representa-tive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the Regulatory Guide 1.52, Revision 2, March 1978. *- i
d. At least once per 18 months by:
1. Verifying that the pressure drop.across the combinegl HEPV E filters and charcoal adsorber banks is less thans inches Water E Gauge while operating the filter train at a flow rate of 4000 cfs 110L
2. Verifying that the filter train starts on a Phase A containment isolation Test Signal.
3. Verify the operation of the filter cooling bypass valves.
4. Verifying that the heaters dissipate 1611.6 kw when tested '

in accordance with ANSI N510-1975.

5. Verifying that each system produces a. negative pressure of J greater than or equal to 0.5 inches W.C. in the annulus within R25 (1) minute af ter a start signal.
e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm 110L
f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas .,

when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm 110L .

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, i December 23, 1982 s G *'

SEQUOYAH - UNIT 1 3/4 6-14 Amendment 21 e e

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PLANT SYSTEMS .

3 SURVEILLANCE REQUIREMENTS (Continued) i l.

Verifying that the cleanup system satisfies the in place testing acceptance criteria and uses the test procedures of Regulatory i

Positions C.S.a C.S.c and C.S d of Regulatory Guide 1.52, -

i Revision 2, March 1978 (except for the provisions of ANSI N510 10%.

i

  1. 5ections 8 and 9), and the system flow rate is 4000 cfm i

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2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 March 1978, meets the laboratory testing criteria of Regulatory Position- C.6.a of Regulatory Gui'de 1.52, Revision 2, March 1978.

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3. Verifying a system flow rate of 4000 cfm + 10% during system operation when tested in accordance with ANSI N510-1975.

I d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representa-( tive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory i

testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

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e. At least once per 18 months by: .

Ep 3 w

1. Verifying that the pressure drop across the combinedinches Water l 'p. ,

filters and charcoal adsorber banks is less than 10%.

Gauge while operating the system at a flow rate of 4000 cfm i

)

I 2. Verifying that on a safety injection signal or a high radiation signal from the air intake stream, the system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks.

3. Verifying that the system maintains the control room at a ~

positive pressure of greater than or equal to 1/8 inch Water l Gauge relative to the outside atmosphere at a system flow rate of 4000 cfm 1 10% (3800 cfm recirculation and 200 cfm fresh air).

f. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to I l '

99.95% of the 00P when they are tested in place in accordance with 10%.

ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i 1

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1975 j

while operating the system at a flow rate of 4000 cfm ; 10%.

- MAR 251982 &

Amendment No. 12 Y i

SEQUOYAH - UNIT 1 3/4 7 18 R16 \.J i i

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) _ __

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c. After ever'y 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of ch.ircoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of repre-

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sentative carbon sample obtained in accordance with Regulatory -

Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, ,"

meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Goide 1.52, Revision 2, March 1978.

d. At least once per 18 months by:

1 1. Verifying that the pressure drop across the combined EPA ~3 filters and charcoal adsorber banks is less than nches Water Q Gauge while operating the filter train at a flow rate of 9000 cfm + 10%.

2. Verifying that the filter trains start on a Containment Phase

, A Isolation test signal; or a high radiation signal from the ,

! fuel pool radiation monitoring system or the auxiliary building i ventilation monitoring system.

3. Verifying that the system maintains the spent fuel storage area and the ESF pump rooms at a pressure equal to or more negative than minus 1/4 inch water gage relative the outside atmosphere while maintaining a vacuum relief flow greater than 2000 cfm and a total Q<a system flow of 9000 cfm 1 10%. *
4. Verifying that the heaters dispite 32 + 3.2 kw when tested in accordance with ANSI N510-1975.

1

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to I 99.95% of the DOP when they are tested in place in accordance with ,

ANSI N510-1975 while operating the system at a flow rate of 9000 cfm  !

+ 10%.

f. After each complete or partial replacement of a charcoal adsorber .

. bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI H510-1975 while operating the system at a flow rate of 9000 cfm + 10%.

s .

1 i

MAR 251982 Amendment No. 12 ,R16 I,*;.~

.g ,

SEQUOYAH - UNIT 1 3/4 7-20 NG/l

/.

REFUELING OPERATIONS N

SURVEILLANCE REQUIREMENTS (Continued) ...

i c. Af ter every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representa-tive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the '

laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

j d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined _HEPA_ -15 y

filters and charcoal adsorber banks is less than #' Inches Water Gauge while operating the filter train at a flow rate of 9000 cfm lR i 10%.

2. Verifying that the filter train starts on a Containment Phase A Isolation Test Signal; or a high radiation signal from the t fuel pool radiation monitoring system or the auxiliary building ventilation monitoring system.
3. Verifying that the heaters dissipate 32 1 3.2 kw when tested in accordance with ANSI N510-1975.

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e. After each complete or partial replacement of a HEPA filter bank by l

' verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm 1 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas

! when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm + 10%. ,

I l

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] 5EQUOYAH - UNIT 1 3/4 9-13 i

1

F7 CONTAINMENT SYSTEMS

, SURVEILLANCE REQUIREMENTS (Continued)

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representa-tive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the Regulatory Guide 1.52, Revision 2, March 1978.
d. At least once per 18 montns by:

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1. Verifying 'that the pressure drop across the combine EPA 5 3 filters and charcoal adsorber banks is less than nches Water  ; 74 Ga'uge while operating the filter train at a. flow rate of 4000 cfm 1 10%. -
2. Verifying that the filter train starts on a Phase A containment isolation Test Signal.
3. Verify the operation of the filter cooling bypass valves.
4. Verifying that the heaters dissipate 16 1 1.6 kw when tested in accordance with ANSI N510-1975. g,
5. Verifying that each system produces a negative pressure of greater than or equal to 0.5 inches W.G. in the annulus within R11 (1) minute af ter a start signal.

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I e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm 1 12E.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas I when they are tested in place in accordance with ANSI N510-1975 l

, while operating the system at a flow rate of 4000 cfm 1 10%. . j l

- i l

De,cember 23, 1982 -

SEQUOYAH - UNIT 2 3/4 6-14 Amendment 11, 1982

PLANT SYSTEMS 7

SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying that the cleanup system satisfies the in place testing '

acceptance criteria and uses the test procedures of Regulatory Positions C.S.a, C.5.c and C.S.d of Regulatory Guide 1.52, Revision 2, March 1978 (except for the provisions of ANSI N510 Sections 8 and 9), and the system flow rate is 4000 cfm 1 10%.

2. Verifying, within 31 days after removal, that a laboratory analysis of a representat.ive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, ,

March 1978.

Verifying a system flow rate of 4000 cfm + 10% during system 3.

operation when tested in accordance with XNSI N510-1975.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 da9s after removal, that a laboratory analysis of a represen-tative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.
e. At least once per 18 months by:

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1. Verifying that the pressure drop across the combined PA IA filters and charcoal adsorber banks is less than # nches Water Gauge while operating the system at a flow rate of 4000 cfs 1 10%.
2. Verifying that on a safety injection signal or high radiation signal from the air int:ake stream, the system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks.
3. Verifying that the system maintains the control room at a -

positive pressure of greater than or equal to 1/8 inch Water Gauge relative to the outside atmosphere at a system flow rate of 4000 cfm i 10% (3800 cfm recirculation and 200 cfm fresh air).

f. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i 10%.
g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm + 10%.

i

. SEQUOYAH - UNIT 2 3/4 7-18 ~ )

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PLANT SYSTEMS e-SURVEILLANCE REQUIREMENTS (Continued)

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.
d. At least once per 18 months by:
1. Verifying that the pressure, drop across the combined EPA 3 filters and charcoal adsorber banks is less than # nc es Water ] T2.

Gauge while operating the fi. iter train at a flow rate of 9000 cfm 1 0%.

1

2. Verifying that the filter trains start on a Containment Phase A Isolation test signal; or a high radiation signal from the fuel pool radiation monitoring system or the auxiliary building ventilation monitoring system.
3. Verifying that the system maintains the spent fuel storage area and the ESF pump rooms at a pressure equal to or more negative than minus 1/4 inch water gauge relative the outside atmosphere while p ~~-J maintaining a vacuum _ relief flow greater than 2000 cfm and a total V system flow of 9000 cfm 10%.

- i'

< 4. Verifying that the heaters dissipate 32 1 3.2 kw when tested in accordance with ANSI N510-1975.

e. After each complete or partial replacement of a HEPA filter bank by -

verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm 1 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying .that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm i 10%.

. I

[* ,

Wi w SEQUOYAH - UNIT 2 3/4 7-20

)

REFUELING OPERATIONS.

SURVEILLANCE RE0VIREMENTS (Continued)

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of representa-tive carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2 March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March *1978.
d. At least once per 18 months by:

Verifying that the pressure drop across the combin e pd 3 1.

{s

- filters and charcoal adsorber banks is less than y inches Water Gauge while operating the filter train at a flow rate of 9000 cfm 10%.

2. Verifying that the filter train starts on a Containment Phase A Isolation Test Signal; or a high radiation signal from the fuel pool radiation monitoring system or the auxiliary building ventilation monitoring system.
3. Verifying that the heaters dissipate 32 1 3.2 kw when tested in -

g accordance with ANSI N510-1975.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the 00P when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm 1 10%.
f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 9000 cfm + 10%. -

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. 1 l

SEOUOYAH - UNIT 2 3/4 9-15 l

ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327, -328 (TVA SQN TS 87-10)

DESCRIPTION AND JUSTIFICATION FOR PROPOSED REVISION OF THE MAKIMUM ACCEPTABLE PRESSURE DROPS ACROSS THE HEPA AND CHARCOAL FILTERS IN THE ABGTS, ECTS, AND CONTROL ROOM EMERGENCY VENTILATION SYSTEM l

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Description of Change -

The maximum acceptable pressure drops across the various high efficient particulate air (HEPA) filters and charcoal adsorber banks referenced in surveillance requirements (SR) 4.6.1.8.d.1, 4.7.7.e.1, 4.7.8.d.1, and 4.9.12.d.1 of both the unit 1 and 2 technical specifications are lowered.

Specifically, the maximum acceptable pressure drop of eight inches water gauge (WG) across the combined HEPA filters and charcoal banks referenced in SR 4.6.1.8.d.1 for the emergency gas treatment system (EGTS) is lowered to five inches WG. The maximum acceptable pressure drop of six inches WG across the combined HEPA filters and charcoal banks referenced in SR 4.7.7.e.1 for the control room emergency ventilation system (CREVS) is lowered to three inches WG. Lastly, the maximum acceptable pressure drop of six inches WG across the combined HEPA filter and charcoal bank referenced in SR 4.7.8.d.1 and 4.9.12.d.1 for the auxiliary building gas treatment system (ABGTS) is lowered to three inches.

Reason for Change As a result of TVA's recent Technical Specification Verification Program at Sequoyah, it was determined that the current maximum acceptable pressure drops specified in SR 4.6.1.8.d.1, 4.7.7.e.1, 4.7.8.d.1, and 4.9.12.d.1 for the various air cleanup system filter trains could not be substantiated. It appears that the specified values were based upon the total calculated pressure drops used to size the fan of each system. The new limiting pressure drop values proposed in this technical specification change request are the pressure drops solely attributed to the HEPA filters and charcoal banks in the filter train of each system.

Justification for Change TVA's Technical Specification Verification Program at Sequoyah identified that there was not a traceable documented basis for the limiting pressure drop values provided in SR 4.6.8.d.1, 4.7.7.e.1, 4.7.8.d.1, and 4.9.12.d.1.

Consequently, TVA is requesting that these pressure drop values be revised to reflect the values used in the engineering design calculations. These design calculations were performed to determine the fan sizing requirements based on the desired airflow rate and the pressure losses due to the duct configurations, dampers, grills, and filters. The pressure losses attributed to the filters are based on the assumption that the filters are dirty and that they will be changed before the associated pressure drop exceeds the specified value. These specified maximum pressure drop values are the new values proposed in this technical specification change request. This will result in a traceable documented basis for each of the subject pressure drop values.

It should be noted that all of these changes are in the conservative direction.

1

ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 -328 (TVA SQN TS 87-10)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS FOR PROPOSED REVISION OF THE MAXIMUM ACCEPTABLE PRESSURE DROPS ACROSS THE HEPA AND CHARCOAL FILTERS IN THE ABGTS, EGTS, AND CONTROL ROOM EMERGENCY VENTILATION SYSTZM l

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4 SIGNIFICANT HAZARDS EVALUATION l

1. Does the proparad amendment involve a significant increase in the probability ce consequences of an accident previously evaluated?

No. The proposed change is conservative. The maximum allowable pressure drops due to dirty HEPA and charcoal filters in the various air cleanup systems are lowered. This change adds additional assurance that these filters will be replaced before their function or the system's flow capacity is significantly degraded.

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

No. The proposed change will not result in any new maintenance procedures, testing, or different operational parameters. Thus, the possibility of a new or different kind of accident is not created.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

No. The margin of safety is not reduced. The function of these air cleanup systems is not compromised.

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