Text

Forwards Response to 870512 Request for Addl Info Re Rev 2 to Tech Spec Change Request 126 Concerning as-modified Shared Control Room Habitability Sys for Both Units Based on Licensing Criteria Applicable to Unit 2
	ML20214E422
Person / Time
Site:	Beaver Valley
Issue date:	05/13/1987
From:	Sieber J; DUQUESNE LIGHT CO.
To:	; NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
	NUDOCS 8705220081
	Download: ML20214E422 (45)
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l 'W Telephone (412) 393-6000 Noclear Group '

P.O. Box 4 Shippingport, PA 15G77-0004 May 13, 1987 i

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 I

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Response to Request for Additional Information (TSCR-126, Rev. 2)

Gentlemen:

In your letter dated May 12, 1987, you requested additional information concerning our Technical Specification Change Request No.

126, Revision 2. You requested information primarily related to the determination that the as-modified shared control room habitability system for both Beaver Valley Unit 1 and Unit 2 is acceptable based on the licensing criteria applicable to Unit 2. We have addressed each question and provided our response in the attachment to this submittal. As indicated in your letter, the restart of Unit 1 is currently scheduled for May 16, 1987 and as such we continue to need this Technical Specification Change approved and issued prior to this date.

If you have any questions regarding this submittal, please contact my office or members of my staff.

Very truly yours,

b. -

. D. Sieber Vice President, Nuclear Attachment l

8705220081 870513 4 PDR ADOCK 0500 P

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. - 3 4-Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License.No. DPR-66 Response to Request for Additional Information (TSCR-126, Rev. 2)

Page 2 cc: Mr. S. M. Pindale, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077

. U. S. Nuclear Regulatory Commission.

Regional Administrator Region 1

- 631 Park Avenue King of Prussia, PA 19406 i Mr. Peter S. Tam U. S. Nuclear Regulatory Commission Project Directorate No. 2 .

Division of PWR Licensing - A l Washington, DC 20555

- Mail Stop 316 Addressee only Director, Safety Evaluation & Control Virginia Electric & Power Company

P.O. Box 26666 One James River Plaza Richmond, VA 23261 1

Mr. Thomas M. Gerusky, Director Burenu of Radiation Protection-Pennsylvania Dept. of Environmental-Resources P.O. Box 2063 Harrisburg, PA 17120 2

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4 l ATTACHMENT l

Response to NRC

! Request for Additional Information Beaver Valley Unit 1 Tech Spec Change Request No. 126, Rev. 2 l -The purpose of the requested clarifications primarily relates to the determination. that the as-modified shared control room habitability system for. Beaver Valley Units l'and 2 is acceptable based _on the R i

licensing criteria applicable to Unit. 2. This determination is required even though the - requested technical specification changes

. concern only Unit 1 because the system serves Unit 2 as well.

!. 1. Provide information to justify the conclusion that .the as-

modified ' design complies with GDC-4 regarding its ability to

maintain a suitable environment, and GDC-5 concerning-shared safety functions.

Response ,

1 The- Unit 2 FSAR Section 6.4 defines the control room envelope as

. including the Unit 1 and Unit 2 spaces-and that the habitability system of -the control room.is designed in accordance:with GDC-4. ~

The Unit 1 UFSAR Appendix A states that in meeting GDC-4 that

' structures, systems and- components important to safety shall be designed to accommodate the effects-of and to be compatible _with ;

i the associated environmental conditions and that components shall j be . appropriately protected against dynamic affects, including the ;

l effects of missiles, pipe whipping-and discharging fluide, that j may result from equipment failures. The control room (i.e.,

control' room. envelope) and components of the~ control 1 room 3 ventilation system are -defined as structures, . systems and i i components important to safety and as such meet GDC-4.~ The as-modified design of the Unit 1 emergency habitability systems to meet the same criteria. A- summary .of those.

continue t modifications is included in response to item 2 below. As a result of our review of these modifications, the conclusion that

! we meet GDC-4 regarding the ability to maintain a suitable l control room environment remains valid.-

Since the control room .was, through= FSAR references and descriptions, always intended. to be a common facility for both units, it was necessary to design the bottled-air pressurization .

.I system to accommodate the shared safety system design._ With the .

i control room- environment being shared by both units, that ;

i environment must be protected against postulated accidents- l l occurring at- either unit. This has been accomplished with the j L integration of the high -radiation, chlorine isolation and CIB ~

actuating signals effecting control room ventilation isolation-and actuation of .the bottled air pressurization system upon i receipt .of-any of these- signals from _either. unit. The design:

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. ~ ATTACHMENT (Continued)

. wiring diagrams - for- the- Unit 2 subsystems and the as-modified' ;

, LUnit_ l' systems -demonstrating separation,. independence' and' r

isolation were provided.to the NRC staff during a meeting at the Beaver ' Valley site on. April 30 and'May'1, 1987. See the-attached s

letter dated May 13,.1987 referencing control room habitability. ;

.The systems were designed to assure initiation from either. unit :

as stated above,. however,. additional redundancy is provided in

that. each uniti has its own.. redundant . control room. radiation monitors and- redundant chlorine detectors which' initiate control room isolation. All components are powered from their respective unit's power sources- but the actuating circuits initiate i protective. actions at-either unit.

If the bottled air pressurization system was _ actuated, the ability to shutdown and cooldown .either- unit would not lxn impaired since each unit's' safety equipment required for shutdown and initiation of the cooldown can independently be placed into service from the common control room.

We also believe that the dual unit control room will' provide an

incremental benefit in the safety posture of our facility since it will provide a resource aof additional _ licensed _ personnel during normal-and abnormal plant. conditions.

The common control room pressurization envelope _ design is also

> provided, with an additional level of protection by the installed capability of four 100% independent, safety. grade. emergency filtration fans and three 100% filter subsystems for assuring-F long term pressurization of .the control . room envelope. The as-modified design upgraded the Unit- 1 emergency ventilation system such that it is capable ofcproviding the same air flows for pressurizing the combined- control -room as the Unit .2 subsystem. The velocity through the non-redundant Unit l' filter housing has been verified to achieve the same residence time.

through the charcoal adsorber. (which isLthe same: design as the

Unit 2 adsorber -

i.e., Type II, 2 inch charcoal beds).as the i Unit 2 components. The Unit 1 emergency ventilation system was originally designed. as two 100 percent redundant subsystems sharing a non-redundant' filter (consistent with SRP 6.4). As such, separation and independence was provided from power supply to actuating devices. The Unit 2 systems'were_ designed in the same manner. Therefore, as shared safety systems, the emergency l ventilation subsystems of _each unit, are totally independent of- i each other and satisfy the GDC-5 criteria ~for not impacting the-ability of the other unit to achieve a safe shutdown. condition.

Based 'upon.these considerations and other information conveyed at our meetings on March 18, April 2, April 30 and May 1, 1987 we believe that compliance with GDC-4 and GDC-5' .have- been-established. ,

i 1 Each units emergency habitability. system has been designed and installed to meet the' requirements of GDC-2. ThefUnit 1 UFSAR, Appendix 1A ' provides a description of how design conformance'is

! achieved. The control room -and as-modified emergency habitability systems meet GDC-2.

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ATTACHMENT (Continu:d) l HI n the SER for Unit 2 (NUREG-1057),'Section 6.4, Lit.is-stated'

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. that to Jensure compliance with:NRC'guidelinesiin the. protection l of the control room- operator following a-chlorine release,,the-staff will review. the Unit 2 TS to ensure that controluroom :

isolation, response times and pressurization test flow rates.are

! consistent with the guidance of RG 1.95, Table .l. In this regard, provide- a description. of this. capability:and how these .

, functions will. be ensured by the proposed TS change. (See-Item 4b. below for further discussion).

Response

The relevant modifications that are being .made to the Unit 1-Control Room Habitability Systems include the following::

a. The BV-1 Emergency Ventilation System Fans capacity have

been increased from 400 cfm to 800-1000 cfm- which- is consistent with BV-2 flow rates.

-b. The bottled. air pressurization flow rate capacity have been doubled from approximately 100 cfm per bottle to approximately 200 cfm for two bottles in a parallel arrangement,

c. A larger- heater and necessary piping .and ductwork was installed on the Emergency Ventilation System to accommodate

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the higher air flow.

d. The BV-1 Emergency -Ventilation' System was modified to,be a manually operated system to eliminate potential filter bypass flow. This is further discussed in our May 13, 1987 submittal referencing Control Room Habitability (attached).

e. The actuating circuits for . Control Room Ventilation Isolation CIB, Control Room Radiation and Chlorine Isolation L were. modified so that these signals would isolate all (8) intake and. exhaust dampers on the. combined BV-1/BV-2 systems,

f. The BV-1 chlorine detectors are being replaced with a design-similar to the BV-2 system with the detectors being located closer to the air inlet for improved time response.

g. The bottled air capacity has' been doubled while the control room envelope has only been increased from 114,000 ft8 to 173,000 ft 8 (BV-2 FSAR Table 6.4-1).

h. An additional charcoal filter adsorber cell was installed-in the BV-1 filter housing 'for improved! efficiency. and residence time.

These modifications, except ~ for item ~f, were discussed at.a meeting with the NRC on April 2, 1987 and found acceptable. The i Technical Specifications for BV-2 -will not rely _on anyfof the BV-1 fans or filters since the BV-2 schedule can not support the 4

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ATTACHMENT (ContinuGd) staff -review time. Additional information concerning clarifications per Regulatory Guide 1.95 were provided in our

letter dated April 16, 1987.

-The combined control room will be isolated upon receipt of an initiating signal ~ from either unit. This capability has previously been discussed in item 1 above. The chlorine detector response time will be verified by functional system testing as opposed to assuming vendor specifications. The detector response time and damper isolation time will'be verified to provide an acceptable system response time to assure the control room operators are protected from a chlorine gas release. See our.

response to item 3.b for our position on response time with respect to Regulatory Guide 1.95.

We have reviewed Table 1 of Regulatory Guide 1.95 and determined that our control room is a Type III. This is based on the following:

local detectors no remote detectors

- isolation time as defined in response to item 3.b~

- normal air exchange rate less than 0.3 per hour isolated air exchange rate less than 0.006 per hour based on the SRP assumed in-leakage of 10 cfm.

largest single container of chlorine is 2000 pounds at a distance of 152 meters from the control room.

The bottled air pressurization system will discharge for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months following initiation of control room isolation. The technical specification testing of this system will be as discussed in item 4.c. below. There are no guidelines in the Standard Technical Specification for placing chlorine protection response times in the technical specifications. We will revise our Bases to the chlorine detector technical specification by September 1, 1987 to include our position stated in item 3.b.

As stated in item f above, we are replacing the unit 1 chlorine detectors. This modification is expected to be completed by June l 16, 1987. In the interim, the control room operators will be protected from a chlorine release accident by -one of the '

following:

- The Unit 2 chlorine detectors, if operable.

Isolation of the control- room from the outside atmosphere and monitoring oxygen content within the control room pressure envelope. Periodic purging will be accomplished based on oxygen levels or the build-up of contaminants as a result of work activities.(i.e., painting, welding, etc.).

During the purge time, we will either monitor the air outside the normal air intake for chlorine with a portable detector and a communications system established or station a watch at the chlorine storage area with communications'to the control room.

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ATTACHMENT (Continued).

'It ' i:s important to- note that the modifications completed, or-Lpending .(i.e. , Lchlorine . detectors),; would only. serve to reduce the postulated effects of- a chlorine accident-because the BV-1

chlorine detectors .are being,. replaced- and: will be located upstream of the isolation ' dampers. Since-.the bottled : air capacity and flow -rates have been increased _100%'while/the free 3

air'- space has only been increased (item g)'by'approximately 50%, '

this would result.in more dilution and a higher positive pressure 4

.being maintained within the entire envelope than that which would- -

have existed forcBV-1 alone. In addition, each unit has separate and . independent intake and. exhaust fans -which :would provide additional capacity 'for purging the- control croom envelope-d following cessation of a -hypothetical radioactive or. toxic. gas

, . release. The ~ availability of (4) 100%. capacity filtration fans i and (3) 100% capacity . filters would also. provide an additional ~

. level- of protection beyond that which was'previously afforded.by the original BV-1 system (two 100% capacity fans and 1 filter).

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Based on these considerations, and.the previous staff-reviews of the _BV-1 and BV-2 Habitability Systems, these' changes'would;only.

serve to reduce the affects of a hypothetical ~ toxic radioactive i gas release and the staff conclusion should remain valid.

3 .- Confirm that the staff conclusion in the Beaver Valley Unit'2-SER (NUREG-1057) that the acceptance criteria of SRP'6.4 (including.

GDC-19) and SRP 6.5.1 remains valid-for the as-modified system design.

I' a. Specifically address the as-modified subsystems' .not

addressed in NUREG-1057.

Response

Beaver Valley Unit 2 FSAR Sections 6.4.2.1 and 9.4.1.5.1 and i Table 6.4-1 identified the Unit 1' control room and certain

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equipment areas as being part of the control' room envelope.

These sections reference analyses- completed with ~the :

assumptions of the combined net free air _ volume-and normal make-up air flow rates. Similar: radiological accidents have;

' been, analyzed for Unit 1 as' discussed'in: item 3.b below.

The Unit 2 FSAR Section 6.4.2.2 toxic gas analysis, provided l in support of NUREG-0737 Item fIII.D.3.4 also_ assumed:the

combined normal air make-up flow rate of 500 cfm.(200 cfm t for Unit 2, 300 cfm for Unit 1) for purposes'of analyzing

the effects of toxic gas-releases'cx1 the control' room....The toxic gas evaluation provided-in response to NUREG-0737 item III.D.3.4 and reviewed for-Unit.2 was also~ reviewed for. Unit.

1 since it was a common evaluation, .however, docketed separately for each: . unit.' The- toxic ' gas analyses

, description provided in the Unit- 2.FSAR,fSection~6.4,:is i written to bc totally applicable- to~the combined control 1 roon. BV-1 is installing the same chlorine detectors as-BV-2 due to problemsLidentified on the time response 1 testing of these units. Therefore,.with respect to protection-from i a chlorine gas release, the as-modified Unit 1Lsystem was 4 ;

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. ATTACHMENT.(Continued)$

' H the assumed Unit. 2 designed. system:for providing. control d

4 room. -pressurization ~. :This is consistent with the l

assumptions- in 'the ~ BV-2ianalysis for demonstrating meeting I SRP 6.4 in that theidefined control room volume"can only be adequately - pressurized by. the' as-modified . bottled' air 4 pressurization system. Additionally, the . control- room-operators are. protected equally by either units chlorine' detectors - and the system response as discussed-in' item 3.b '

below.

No design credit was- given, for the additional filtration capability- of the .as-modified.: Unit l' system which:is a.

manual back-up to the:BV-2 system. - The upgrade: ofithe Unit 1 system.provides additional protection beyond'that required for existing plants .since there are.(4) 100% capacity. fans and (3) 100% . capacity _ filters. A description-of analyses I completed for Unit lLis provided in response to item _3.b and

, Unit l' positions on- the - various regulatory guides are provided in our proposed Technical- Specification. Change i

~ Request. No. 126, Rev. 2- and. within our responses to the remaining items of this request for additional'information.

1 While different. positions between Unit .1 and Unit 2 may

) exist on the various regulatory. guides,-the as-modified Unit capable of providing .the same level 1 of

! 1 system is

! protection as a Unit 2 subsystem, except,for the automatic' i initiation - feature. As previously stated, the bottled air

, system capacity has been doubled while the total .

pressurization envelope has only' increased by approximately 50% and is conservative in this ' regard.. This;again is-consistent with the assumptions in .the BV-2 analysis for demonstrating meeting SRP 6.4' in that the. defined control room can only be adequately pressurized by the as-modified bottled air pressurizatien system.- The. -combined subatmospheric containment- design, . air. pressurization capacity and emergency- filter subsystems are in excess-of that required by SRP 6.4' III~3(5) . which stipulates.

"one-redundant filtration ..._ system".

Due to schedule priorities, BV-2 Technical Specifications were revised during a meeting in Bethesda'on May 8, 1987.

This- had removed - the capability for BV-2 to-rely on-BV-1

equipment for meeting the emergencycfilter specification.

The current status of the BV-2 Technical Specification can'

not take credit- for any- ofithe BV-1 emergency filtration systems. 'However, the Unit l_and Unit 2 analyses performed for the radiological and toxic gas release accidents assumed' t the combined control ' room free- air. volume and identical

-make-up flow rates. The staff conclusion of.NUREG-1057 is unaffected by' the as-modified' systems, and-in: fact can only.

be supported by the changes made to:the BV-1 systems.-

1 i b. Provide analyses regarding the consequences of postulated radiological and non-radiological accidents. -

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. ATTACHMENT-'(Continu*.d)-

Response

New analyses for determining control room operators'[ dose have been--performed for Unit 1 and.have includedninLtheir.

assumptions the as-modified subsystems. These analyses include:

-1. Locked Rotor

2. Loss of Non-Emergency AC Power

3. Waste. Gas. Storage Tank Rupture.

j 4. Main Steam Line Break 1 5. Steam Generator Tube Rupture-

6. Small Line Break Outside Containment

7. Fuel Handling Accident

8. Rod Ejection _ Accident

9. Loss of Coolant Accident 4

For analyses fl, 2 and 3fthe 30-day control room. doses are y below . the GDC-19 requirements and additional protective actions are not required. 'For all others,:some protective action. (i.e., control room isolation, control pressurization-or. operation of the . emergency ventilation- system) is j' required to assure ~ the operator dose remains below GDC-19'

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requirements. Table 1 -provides the results.of the above i analyses. ,

l The non-radiological accidents- for Unit-1 are the same as i for Unit 2. A complete discussion of this is. contained in the Unit 2 FSAR,' Section 6.4.- The chlorine release is the

only toxic gas release which requires additional. control- -

2 room monitoring. We are currently installing new chlorine detectors in the Unit- 1 air intake which~are the same-as 4 those installed at Unit.2. %hn will-protect 1the control room operators in accordance with Regulatory Guide 1.95,.Section- i B and our statement ~in our April 16, 1987 . Technical Specification. Change Request No. 126, Rev. 2,Jon Regulatory Guide 1.95 regulatory position C.3, in-that we will assure

" the toxicity limit in; the. control- room. is not exceeded

within the first two minutes following detection. This has been previously discussed in our- May 12, 1987- submittal referencing confirmatory items'(attached).

. c. Clarify exceptions taken to RG 1.52'and RG 1.95 as follows:-

I' i.. Clarify how use of artificial resistance is needed to ,

avoid damage to installed' system components..

Response

ANSI N510-1980, Section 8.3.1.1 requires. installation of all components -prior to conducting clean and dirty filter air flow capacity tests. The-use of artificial l resistance is a ; technique used to ' conduct ' system: l acceptance testing (i.e., flow-balancing) without i

, exposing the filters to contaminated air or. .other I

. ATTACHMENT-(Continusd) foreign mat'erials whichicould damage them. 'The--intent herei.is- to accomplishL this- through: the;' ability to.

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remove or protect: the filters and. substitute .an

- equivalent artificial- resistance when -doing; system performanceL acceptance testing. However, ;since our filters are currently; installed and construction is-completed for. Unit 1, we do not anticipate implementing this exception in the .near future.- This position is being provided as. a future option should we.ever need to do system performance ' testing and the: filters are removed or some'other. artificial resistance is applied-to avoid damaging them.- i We would' also like;;to. clarify our position = stated in our proposed Technical Specification Change No. 126, Rev. 2, regarding Regulatory Guide' l.52 Lposition C.5.b. We- stated in item 3 that the' air flow test .

specified in Paragraph 8.3.1.7 will be performed with

the filter- bank at.50 percent.of-design-dirty pressure 2

drop. Since our system has a- 6 inch' water gauge design-dirty pressure drop.and a 3.75' inch water gauge design-clean ' pressure drop, we .can not achieve a' 50 percent of design-dirty - pressure drop as previously stated. Instead we will test to obtain datanat a point-

' midway between design-dirty. and ' design-clean. We F believe this' satisfies the-intent'of theistandard.-

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> ii. ~ Clarify how the chlorine detection system is qualified t

for the severe environments that lead to or could be a result of a chlorine' release.

Response

New chlorine detectors have- been procured to the following specifications:

IEEE 323-1974; General Guide for . Qualifying Class: l' i Electric Equipment for Nuclear -Power Generating Stations IEEE 344-1975; . Seismic-. Qualification Tof Class. 1 Electrical Equipment. for Nuclear. Power ' Generation

! Stations 4 .- Provide justification for all deviations-Ifrom the Standard Technical Specifications. Specifically address the following:

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a. -In' order _ to be able to credit the emergency ventilation. I subsystems 1 with the capability to maintain positive pressure

in the envelope and to remove radioactive materials from incoming air the- STS require- that each subsystem must be

. . surveillance ' tested'at.the flow rate intended to be used.for-

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these-functions i 10%.

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i. Verify the intended flow rate of each of the Unit 1 and Unit 2 systems.

Response

In verifying the make-up air flow rate required to maintain a positive pressure of 1/8 inch water gauge in the control room, with respect to the outside atmosphere, actual test data from Unit 1 performance tests was utilized. This Unit 1 flow rate was then adjusted to account for the increased volume and potential: leakage paths resulting from the removal of the control room wall. As documented in the Unit 2 FSAR, Section. 6.4, this make-up air flow rate is 690.

cfm. The control room operator doses are based on this flow rate and calculations previously submitted on May 12, 1987 provide the basis for 690 cfm air make-up being conservative. Our emergency ventilation system was sized to provide margin through an increased air flow. This provides additional assurances that the 1/8 inch positive pressure is maintained and that the operators doses will be well within the GDC-19 requirements. Both units emergency ventilation system fans have 'been verified to provide a flow rate between 800-1000 cfm. The system design flow rate is 1000 cfm which provides a 0.25 second residence time for the installed charcoal adsorbers.

ii. Amend the proposed TS's to require each test at that flow rate i 10%.

Response

The propoced flow rate is in excess of the minimum flow rate required to maintain the control room at a 1/8 inch water gauge positive pressure and is conservative with respect to operator doses, it is therefore requested that the submitted flow rates of 800-1000 cfm be accepted as a deviation from the Standard Technical Specifications.

b. Likewise, for the bottled air pressurization system, TS 4.7.7.2 should provide a discharge flow rate-range, e.g.,

800 cfm i 10%, in an equivalent bottle pressure range for this test.

Response

There are no installed flow instruments in the bottled air pressurization system. The design bases for the system is to discharge an adequate volume of air such that the control' room pressurization envelope has a positive pressure at the end of a 60 minute period. This is to insure that leakage from the containment during the first hour when the containment would be pressurized,- would not be able to

.ATTAdHMENT (Continutd)'

bypass the filtration . system. .By maintaining a constant orifice inlet-pressure, the' flow rate.is fixed. By assuring.

'a minimum bottled air +. pressure, adequate volume is being' provided ' tx)- maintain the- required' pressure ~ in the control room for the required period of time.. The allowable bottled 1 air. flow- rates exceed the minimum flow rate required to.

maintain .the control room at a 1/8 inch: positive pressure (i.e., 690_.cfm). The limit on emergency-ventilation system e- fan flow rates serves 1to fix~the.value of allowable envelope.

, leakage- and provide some margin-to that which'would: permit a be . maintained during- accident positive. pressure to.

conditions. The- installed pressure switches on the inlets to the orifices 'which actuate a. red light on the Building-Service Panel, serve tu) give'the: operator.an indication that-the required- flow delivery _ is being maintained by the-

bottled air pressurization system..

t Flow rate tests (using temporary instruments) would require '

extended bottle discharges and result'in_a unit (s) shutdown due . ta) the inoperability of the. bottled air pressurization system.: .The system tests have measured-flow with the new orifices _at'approximately 190-210 cfm.

c. The ' meaning of footnote ** -in._. terms of the surveillance required is not clear. Clarify .the current proposa1 Eor amend the proposal and explain the change. -(See Item No. 2 above).

Response

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This one-time one-hour test was agreed to at a meeting _in-4 Bethesda on April 2, 1987. This was'necessary to insure that the air _ pressurization bottles would -be capable:of supplying the _ required discharged volume.such.that we would verify the control room at- a pressure fof > 1/8 inch water:

gauge with respect to the outside atmosphere'after one hour

, of operation. Subsequent testing, using a partial discharge

test, will be conducted from normal bottle pressure'to~al pressure -above the technical. specification limit of 1825 psig. This would preclude the invocation of Technical Specification 3.0.3 and require a one hour shut'down'of-the operating unit- since a full discharge test would_make: the bottled air ~ pressurization system inoperable. _ Depending'on the status of the make-up air ~ compressor, it can take'3 ,

days to charge the bottled air. system to full capacity.

Duquesne Light Company thad ' originally : proposed a 7 dr.y allowable out of service time to accommodate recovery from test discharges but- a compromise-led to the_one-timentest-l with the flow rate monitoring exception that is explained in i items 4b and was recently discussed on_May 8,.1987:with Mr..

R. Fell of the NRC.

, d. To apply the full-RG 1.52 radioactive' removal efficiencyLin the staff safety analysis the average residence _ time._for-l charcoal filters must be no less than 0.25 sec per:2-inches.

. of bed thickness.

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. -ATTACHMENT (Continutd).

'a) Verify that ~each. of 'the - emergency subsystems-has an

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average: residence time for charcoal filters of nocless

' than.0.25 sec pery2-inches of bed thickness. ,

Response

We. have type _ II: charcoal adsorbers which are designed' for a flow rate of 333 cfm per adsorber media'which by design' results in a'0.25-second residence-time. With three' filter- cells ~ installed the system is capable of F handling 1000 .cfm and-~ main.nining_ the 10.25 second

. residence time.- ~ Additic.*11y, . Ethe air. flow distribution _ test, which- is : conducted- in~accordance

+ with ANSI N510-1980, Section : ~ 8.3.2.2,- : requires an acceptance criteria -(Section- 8.3.2.'4)'of i 20% of the average velocity.- .This implies-a i 20% deviation on the residence time which envelopes the flow acceptance-criteria of i -10% of.-system'_ design flow -(Section c

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18.3.1.8).. Therefore, since all the subsystems meet the

-technical specification flow criteria 'through. the filter 'adsorber (800-1000 cfm) and this is within the

adsorber design, the. average.-residence.' time of 0.25 seconds for the' charcoal filters willibe met. . Margin ~

to the ANSI permitted design flow-i 10% remains.within

!- the systems operation since -we intend -tx) maintain the

system flow rates between. 800-1000 cfm. In this range

! we expect to maintain the residence time at. 0.25

! seconds or longer.

j b) Otherwise,- provide other. bases forL the .radiciodine

! removal ef ficiencies . tx) be used in the butC staff safety analysis.- (See Item 3.b above).

Response-i A residence time of 0.25 seconds will be met .as j discussed above- in response to item 4.d.a),.therefore,

! "other bases" are not required.

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e. RG 1.52, Positions C.S.c and C.S.d provide in-place testing of HEPA filters and charcoal 'adsorber should~ confirm

penetrations of 0.05% at rated flow.- The Standard Technical

Specifications provide that the Lin-place: __ penetration and bypass leakage testing acceptance'criterialis'O.05% where a HEPA filter or charcoal- adsorber efficiencies of 99%'is' assumed,- or 1% where~ a HEPA- filter charcoal adsorber-i efficiencies of 95% or less is -assumed-'in- the safety '

evaluation (use the value assumed for-the charcoal adsorber

! _ efficiently if the value for the HEPA filter is different j l- from the charcoal adsorber efficiency- in..the NRC. staff safety evaluation).

4 t

,,,-;. _ _ - . _ _ , - . . - -, --.m,- - - - - ~ , ,m - - . _ . = - . - - - . - - . - , - - .

__. ._ . _ = . ~. _ . _ . _ _ . .. .. ,_ _ _ . . _ . _ _ _

~

ATTACHMENT (Continutd)

^ Clarify.-.the applicability -of-the acceptance criterion 1 a) as indicated above to.the.BV design and'TS.

Response-4 The recently . completed control room dose '

analyses-

, conducted for : Unit 1 assumed ~ a :HEPA filter. and charcoal 2 adsorber. efficiency 1of. 95 percent for each component.

- This- is consistent: with the analyses conducted for. Unit-

, 2. . Since a 95 percent efficiency is usedLin.the-dose -

calculations, it .is correct -to provide;;a: Technical Specification' value.;of- 1 percent for the. in-place penetration and. by-pass . leakage 1 testing acceptance criteria. As. indicated in your. request for additional information,. ^this. is consistent- with -the~ Standard Technical. : Specifications. Our proposed LTechnical Specification Change ' Request. No. 126, Rev.12, dated, ,

April 16, 1987 provides acceptance. criteria-consistent

! with the Standard Technical Specifications.-

b) Otherwise, . provide. other. bases for the removal 4 efficiency to be used in the' staff analysis.- -(See Item 3.b as above).

! Response Based on the above, "other . bases" for the filter

- removal efficiency are not required.

I f. Provide justification, or amend your proposal-for deviations from STS regarding: ;

l i a) 31 day tests on a staggered. basis.for 10-hoursLwith the heaters operating.

I Response i' The Beaver Valley control- room emergency ventilation i-systems are installed within the control: room pressure-envelope which is an environmentally controlled area..

It is our position that we willinot have a-moisture:

problem since the relative -humidityi in the area is controlled. Additionally, .the' systems are protected-from- the outside environmentalLconditions since their1 3

inlet damper is in the closed position when1the system is not . running. By. running the emergency ventilation system for 15 minutes instead of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months we reduce the potential of damaging. the: filters due to contaminants. '

in the air.

It is also our position-that operating the systems'for extended periods is more damaging,ifor our location,lin.

! that oxidation . accelerates ~the aging of the carbon.-

! Through extended operation,.the heat andnair flow will'

promote this oxidation and degrade the carbon faster.

4 i -

12-

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, , , ., , , ,,-.,y ---,-,~,.-,~-...,y-, , ,r, ---,- , - , -.

. -. ___ .. . .. . _ ~ ____ _ ._

L ,

. LATTACHMENT~ (Contiinutd)-

~'

' Extended _ operation 1may 1 help remove ~ organics . which; collect ;in the,if11ters, however_we'do-not expect any-build up- of organics-on the charcoal since'the unit is in. an-environmentally controlled area andLisolated from the! same. areas. .The proposed technical-specifications-will- result ini approximately one hour per month where complete ~ automatic < isolation ofzthe' control: room-would not. occur. since these' . fans would bei operating for minutes each, as compared to approximately forty hours--

s .

per month if tested. as suggested Lby the . Standard Technical- Specifications.- .

Our: control': room- dose analysis assume. automatic isolation 1of the:contro11 room l and .immediate pressurization-by the bottled air-' system-j upon. receipt'Lof a.CIB signal, our proposed method of

' testing results in- a lower probability of exceeding GDC-19 as compared to. the' Standard. : Technical-Specifications and is therefore-our preferred. method of testing.

In conclus' ion, it is. our position.that the benefits ;

associated with running the system 1for: 15 minutes,-as proposed, exceed any benefits associated with. running the. systems for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ._ This issue was previously !

accepted for-BV-2 and documented in the FSAR.-

i h 11. Laboratory _ tests within 31. days - after ~ removal with i representative- samples obtained in accordance with RG r

1.52 Position- c.6.b and testing in accordance with i Position c.6.a.

Response

our proposed Technical Specification change identifies a method for obtaining a representative ~ sample for the

, laboratory analysis of the charcoal adsorber media. JWe L have' reviewed this method againstfthe Regulatory Guide-1.52 position- c.6.b~ and have concluded we satisfy the

guidance provided therein. We prefer our wording in

place of the_ wording contained. in~ - the -Standard Technical Specifications since-it-is providing specific.

steps to be taken to obtain'the sample..

Our laboratory testing- follows the recommendations'of ANSI /ASME 510-1980~ which references ASTM D3803 which l has been = formally evaluated- by' the iNRC .and 'is

!' considered an acceptable test' method.- We have adopted the- 30*C and. 70 percent relative:-humidity ~ as test 1 parameters which~ are more conservative and realistic

with respect to actual plant ' conditions. EIn this i

manner we believe we satisfy _the guidance provided in Regulatory Guide 1.52, Rev. 2.,

g. Provide rationale- (or amend the proposed TS).for the'TS not requiring in -Modes 5 and 6 (when irradiated fuel may be-moved' within- the containment) isolation' of. normal-I.

. i i

._ _ . ..A___.,.. . . , ~ . ~ . . _ - - --_,m .. __ _ ...._,.m.._., _;....m., . - . _ , , . - - _

ATTACHMENT (Continu d)1 ventilation on a-CIB-signal'and_ demonstrations-of-emergency' ventilation subsystem and. bottled air. system operability by verifying automatic operation on a CIB signal.

Response

A fuel handling accident' is incapable o'f actuating a CIB signal since it would not create a positive. pressure inside containment. A CIB signal is generated by a high-highJ containment pressure.-

4 4

TABLE 1 BV-1 DESIGN BASIS ACCIDENTS CONTROL ROOM DOSES -

SUMMARY

(30-day Integrated Dose)

DOSE (Rem)

Postulated Accident Thyroid Gamma Beta Small Line Break - LOCA purge at t=8 hr. 29.7 3.6-3 3.3-2 Rod Ejection Accident no purge 4.7 6.1-3 7.5-2 Fuel Handling Accident no purge 3.1 -5.0-2 3.6 Main Steamline Break 23 4.0-3 4.8-2 Steam Generator Tube Rupture 3.2 2.1-3 7.4-2 Locked Rotor Accident 5.7 3.5-4 5.0-3 Loss of AC Power 0.8 7.1-5 2.7-3 Waste Gas System Rupture 4- Line Rupture -----

3.1-3 1.3-2 Tank Rupture -----

7.1-4 1.3 Loss of Coolant Accident (includes ECCS leakage) 25.3 <0.3 < 2.5

1 l

l ATTACHMENT.

mm

'Af M Tapnon. o m 393-6000 I[*e*o'3 May 13, 1987

"."PA 15077-0004 Shippingport 2NRC-7-119 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412 Control Room Habitability Gentlemen:

On April 30 and May 1, 1987, your staff members, Messrs. Knight, Burrows and Pedersen met with us to discuss several specific concerns related to our proposed design and Technical Specifications associated with our combined control room and emergency ventilation systems. During that meeting we provided electrical design drawings reflecting the current status of the various electrical inter-connections associated with the control room habitability systems.

These include the control room radiation monitors and chlorine detectors and the method by which redundancy is provided between the two Units. As discussed at the meeting, these drawings should permit completion of the design review process for the habitability systems.

Other items discussed during this meeting included minor, mutually agreed upon changes to our proposed Technical Specification Change No. 126, Revision 2. Included as Attachment A to this letter is a marked up version of the recommended changes and a complete typed version of the proposed change for NRC processing. These have been found acceptable for incorporation into the Control Room Emergency Habitability Systems Technical Specifications. We also determined that our previous submittal of this proposed change had two bases section pages numbered the same but containing different information (B 3/4 9-4). Included in Attachment A is the correct page for the referenced proposed change. We have also included in Attachment A a new action statement on T.S. 3.7.7.1. Item d.1 has been added as a result of our telephone conversation with members of the staff on May 13, 1987.

During the review of the control room radiation monitors, the need for incorporating these instruments into the Unit 1 Technical Specifications was discussed. These monitors were added to Unit 1 as a result of a Unit 2 analysis demonstrating a need to provide control room isolation capability for several accidents defined in the Standard Review Plan. We intend to submit changes to the Unit 1 Technical Specifications incorporating these radiation monitors by July 1, 1987.

In addition to the above concerns, there were three specific questions to which we agreed to provide a written response. Included as Attachment B are the specific concerns and our response to each.

_3 l .

Sanvar. Valley Fowsr' Station, Unit No. 1 Docket No. 50-334 and 50-412, License No. DPR-66 Control Room Habitability Page 2

'The above information addresses all the concerns the NRC identified ~ to us prior to the site visit with the exception of-the footnote in the proposed Technical Specification. stating " emergency 4

power for one train of dampers of the unit in Modes 5 or 6 need not be available". The intent of this footnote is to permit declaring the affected. isolation dampers operable if the backup. emergency power i supply is the only reason for considering the dampers inoperable. ,

l Thus, if the shutdown unit is performing a diesel overhaul it will not be necessary to isolate that units side of the normal.airlintake and exhaust- portion of the ventilation system. By isolating the dampers on the shutdown unit the fresh air make-up may be reduced by 4 greater than 50 percent. Therefore, it is our intent to declare both ,

trains of dampers operable on the shutdown unit. The operating unit l will still have all redundant ESF equipment operable per its

) respective Technical Specifications and be capable of meeting single failure criteria. It .was our understanding the NRC was going to continue their- review and no further action on our behalf was needed at this time.

We believe this rationale is consistent with industry practices in that make-up air to the control rooms for single or dual units would not be isolated to perform diesel generator maintenance. We are concerned that there would be a potential to create an oxygen deficient environment in lower levels' of the control room-pressurization envelope during welding or burning operations if this requirement was imposed.

Upon review of our submittals and discussions with the NRC staff, it was determined that more information regarding the Unit 1 emergency ventilation system design and operation was needed with respect to eliminating bypass flow around the emergency ventilation i system. This issue was identified by Duquesne Light during a previous on-site meeting with NRC personnel. The emergency

ventilation system was originally designed to have parallel air-4 supplies from the outside atmosphere. The primary source was through the series normal air intake dampers which receive signals for auto positioning and the backup source was a manually initiated system.

The primary source is also the normal air intake for the normal j control room ventilation system. During our- system review we determined the potential existed for bypass flow through the maximum air flow damper. This system is illustrated on UFSAR Figure 9.13-2. l This damper is designed to permit a flow of approximately 33,200 cfm and the minimum flow damper permits a flow of 300 cfm. The maximum t flow damper is maintained closed in order to eliminate the potential for high flow rates of potentially contaminated air to the control

room. However, when closed, this type of damper will still permit a 3-4 percent leakage flow. Upon determining this, we elected to

remove the connecting duct work between the primary intake source and j the emergency ventilation system and to install a removable seal near i the maximum flow damper to eliminate damper leakage. This

! effectively eliminates all possibility of bypass flow around the i

.. . .g Benvor. Valley Powsr Station, Unit No. 1 Docket No. 50-334 and 50-412, License No. DPR-66

. Control Room Habitability Page 3 emergency ventilation system. As a result of'this modification, the control wiring for the series intake and exhaust ~ dampers was modified to remove the auto open signal following a 60 minute time delay.,-We also removed the auto start capability of the Unit 1 emergency ventilation system fans by placing their control switches in-the stop position which will now require manual operator action to initiate operation of this system. The testability of'this system in this configuration was defined in our Technical Specification Change Request No. 126, Revision 2. The above description is provided as additional. information in support of the referenced Technical Specification Change.

If you have any questions regarding this submittal, please contact me or members of my staff.

Very truly yours, bs Jke. ,

J. D. Sieber Vice President, Nuclear i

1 l

Beaver Valley Power Station, Unit No.'l Docket No. 50-334 and 50-412, License No. DPR-66

- Control Room Habitability Page 4 cc: Mr. S. M. Pindale, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Peter S. Tam U. S. Nuclear Regulatory Commission Project Directorate No. 2 Division of PWR Licensing - A-Washington, DC 20555

- Mail Stop 316 Addressee only I

Director, Safety Evaluation & Control 4

Virginia Electric & Power Company i P.O. Box 26666 One James River Plaza Richmond, VA 23261 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Pennsylvania Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 l

c. y.__.._. __ __ ._. . . _ . . _ , _ _ . _ . _ _ _ _ . . . _ . _- _- - .

AWA Ct-imetrr N, PLANT SYSTEMS _

3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION FOR OPERATION I 3.7.7.1 The control room emergency habitability' system is OPERABLE .j when:

1

a. Two out of three emergency ventilation subsystems, fans, l associated filters and dampers are OPERABLE, and

b. Five bottled air' pressurization subsystems consisting of two l bottles per subsystem are OPERABLE, and .p.

I 4e bdk unht

c. The series normal air intake and exhaust isolation dampersAare OPERABLE, and capable of automatic closure on a CIB, Control Room High Radiation and Chlorine isolation signal, or closed. ;

I l d. The control room air temperature is maintained 188'F. l APPLICABILITY: 2 3 and 4, or !

a. With either unit

in,,MODES m_r- 4 . 1'i d h m eirrakt.4 M ,

b. During irradiatedfuelmovementgateitherunitand

a. above or l 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 i associated filters OPERABLE, restore at least two subsystems to l OPERABLE status within 7 . days- or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in-COLD SHUTDOWN within the following l 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . ,

i

, a.1 With an emergency ventilation subsystem inlet isolation damper

open and not capable of being closed, the requirements of 3.0.3

-l are applicable.

b. With one: bottled) air pressurization subsystem inoperable, restore five bottled air ~ pressurization subsystems to OPERABLE within 7 l days or-be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in

COLD SHUTDONN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

) 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.

i

Emergency power for one train of dampers of the Unit in MODES 5 or 6 need not be available.

i BEAVER VALLEY - UNITS 1-'. 2 3/4 7-16 l l PROPOSED WORDING

, . - _ , _ . . , - , _ , _ . . _ , . , , - , , _ , _. __,_..-.,, , ,.-..._. ,._ ,,-.,m.._,____,,-,.,,.,--,.

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4

@LANT 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 i STANDBY within .the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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 fuelyshall be suspended. ,, m. - v d 1.*4s

.ve e .cr auta. 4.et

d. With the control room ' air temperature >88'F, return the temperature to 188'F in 7 days or be in at.least HOT STANDBY 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

e. The requirements of 3.0.4 are not applicable.

e i

1

)

I .

BEAVER VALLEY - UNITS 1 2 3/4 7-16A PROPOSED WORDING i

- ..__._,_._--.y. _.,__,,,.,m.. ,,,, , . _ m --_,..,..,._-.4___,..-..,e ...-e,, c., _ . _ _ _ , . . . , . - , .

t

. PLANT SYSTEMS 3/4.9.15 CONTROL' ROOM EMEkGENCY HABITABILITY SYSTEMS l

' l LIMITING CONDITION'FOR OPERATION l

3.9.15.1 The control room emergency habitability system is OPERABLE t

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 k bA =h

c. The se les normal air intake and exhaust isolation dampers are OPERABLE, and capable of automatic closure 4

on a . Control Room High Radiation and -Chlorine isolation signal *, or closed.

i APPLICABILITY: When both units are in either MODE 5 or 6.

ACTION: I'"d5 * " " ' '#

for m.amed '

a. With less than two emergency ventilation subsystems, fans and ' associated filters OPERABLE and irradiated fuel being mov restore at least two subsystems to OPERABLE status with n 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 ,

l OPERABLE within 7 days or suspend all perations involving movement of irradiated fue7 er men *** a id' *" " r r* Add M.

. b.1 With less than four bottled air pressurization subsystems OPERABLE or no emergency ventilation subsystems OPERABLE, suspend all operations involving movement of irradiated fueg er movem+d .4 lo.a.s over <redM bl-

,e mox. W ,& toaas .eeice.A W . [*el

! c. With one open'seri normal air intake or exhaust isolation damper -inoperable # and not capable of closing and irradiated fuel- being mov restore- all series dampers-to OPERABLE status within 7 ys or close at least one series' normal air intake and exhaust isolation damper on each intake and exhaust to-the control room.

.l

Not applicable when output relay . fuses are removed to prevent inadvertant ESF actuatiory^-- Mr *- smpt J-

Emergency backup power not required for any 1 of 2 series dampers.

BEAVER VALLEY - UNIT L 2 3/4 9-16 l.

1 PROPOSED WORDING i l i .

s PLANT SYSTEMS .

LIMITING CONDITION FOR OPERATION l

col With both series normal air intake or exhaust isolation dampers inoperable # and not capable of being closed, suspend J all operations involving movement of irradiated fuels or move ment A 1..Js evec .cr= Aat4A bl. A

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: j u

a. Automatic operation upon receipt of a containment phase B j isolation signal is not required. l pf l f

4

)

t

. e, l

l a

Emergency backup ~ power not required for any 1 of 2 series dampers.

1 l

BEAVER VALLEY - UNITS l=0 2 3/4 9-17 l PROPOSED WORDING 9

.w , - . . , , . + . . ~ . - - + , -

w , , . , , . - - .

~ PLANT SYSTEMS

q. o

, .3/4.7.7 CONTROL ROOM EMERGENCY HABITABILITY SYSTEMS LIMITING CONDITION.FOR OPERATION 4

3.7.7.1 The control room emergency habitability system is OPERABLE when: ,

a.- Two out of three emergency ventilation subsystems, fans, 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 for both units are OPERABLE, and capable of automatic closure on a

/ CIB, Control Room High Radiation and Chlorine isolation signal, or closed.

f

d. The control room air temperature is maintained <88"F.

APPLICABILITY: a. With either unit

in MODES 1, 2, 3 and 4, or

b. During irradiated fuel movement or movement of loads over irradiated fuel 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 OPERABLE, restore at least two subsystems to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following

30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

a.1 With an emergency ventilation subsystem inlet isolation damper open and not capable of being closed, the requirements of 3.0.3 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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.

Emergency power for one train of dampers of the Unit in MODES 5 or 6 need not be-available.

BEAVER VALLEY - UNIT 1 3/4 7-16 PROPOSED WORDING

__- . _ J, . .. .- ... - - _. - - . _ . - . , -. ----

. Ce

. g,-

jt 7 'r ,

PLANT SYSTEMS 1 ,.y*

. sf _

9'

r 3/4.7.7 CONTROL ROOM EMERGENCY HABITABIITY S_YSTEMS Tf, LIMITING CONDITION FOR OPERATION' ,' r J',< s;.

r

c. W i t W ,l o n e ' o; n p e., 1 ) . series,/ normal air intake or exhaust isolation damper inoperable and not capable of' closing, restore all series

, dampers to OPERABLE)istatus within\7 days or be in at leadt HOT STANDBY 'within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 houds. '!d tf~

col With both/iseries. 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 or movement of loads e,ver irradiated fuel shall be suspended.

d. ,.With thefcontrol room air'xtemperature >88'F but. 1 105*F, return ttle* temperature to 188'F in 7 days or be in at least. HOT Q STANDBY 'within, the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN.within the' 2

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . .

e d'l With the control room air temperature > 105'F, be in at least HOT STANDBY- within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and i;1 COLD SHUTDOWN within-h- the following,,30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

e. - The requir,ements of 3.0.4 are not applicable.

/ i,

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e f

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. .i -

\ BEAVER VALLEY - UNIT 1 3/4 7-16A PROPOSED WORDING-

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS i

4.7.7.1.1 .

The BV emergency ventilation subsystem shall be l demonstrated OPERABLE:

i

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control roomLair 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.

c. At- least once per 18 months or after every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of l 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 housing an '(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 radioactive 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/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 l two inches in diameter and with a' length equal to the thickness cf the bed, or b) Removing a longitudinal sample from an adsorber l 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 length equal to the thickness of the bed.

BEAVER VALLEY - UNIT 1 3/4 7-17 PROPOSED WORDING

y PLANT SYSTEMS DURVEILLANCE 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control room air temperature is 188'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 0.2 hours 0.00119 weeks 2.7396e-4 months 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:

le 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 into MODE 4.

BEAVER VALLEY - UNIT 1 3/4 7-18 PROPOSED WORDING

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS,_ Continued 2.' Subjecting the_ carbon contained Lin at least one test i canister or at. least. two carbon samples removed'from one of the. charcoal'.adsorbers to~aflaboratory. carbon

sample' analysis and verifying a removal efficiency.of 1

. 199% 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, 170% relative-

' humidity, and 30*C il/2*C; other- test conditions 4

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 andLwith.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 t- - volume equivalent to at 'least- two inches in diameter and with a' length equal to the thickness:

r of the bed.

3. Verifying a system flow rate of 800 to-1000 cfm during' i 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 1from either 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 1 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.

F

Input from Unit 2 is not applicable until prior to initial entry into MODE 4.

BEAVER _ VALLEY UNIT 1 -3/4 7-18a-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 UNIT 1 3/4 7-18b PROPOSED WORDING

t,. ,

-PLANT-SYSTEMS

, l 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 I when: =

L a. Twd out of three emergency ventilation subsystems,-fans and associated filters.and dampers-are OPERABLE, and' r .

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 for both units are OPERABLE, and capable of '

automatic closure on a 4 Control Room High Radiation and Chlorine isolation signal *, or closed.

t 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 i moved or movement of loads over irradiated fuel, restore at '

least two subsystems to OPERABLE status within 7' days or close at least one series normal air intake and exhaust i 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 l OPERABLE within 7 days orfsuspend all operations involving '

movement of irradiated fuel or movement of ' loads- over 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 -

. or movement of loads over 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 or movement of loads over irradiated fuel, 1 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.

1 I

Not applicable when output relay fuses are removed to' prevent ,

inadvertant ESF actuation for a single ~ unit. l j # Emergency backup- power not required for any 1 of- 2 series !

! dampers.

,i BEAVER VALLEY - UNIT 1 -

3/4 9-16 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 or movement of loads over 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.

l l

I

Emergency backup power not required for any 1 of 2 series dampers.

BEAVER VALLEY - UNIT 1 3/4 9-17 PROPOSED WORDING

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

I .

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", 10'CFR 50.

', '3/4.7 9 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS) t-

'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) i 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 from the Reactor Containment 4

building penetrations into the contiguous -areas ventilated inr 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 operationi 4

was also assumed in that portion of the Design Basis Accident (DBA)

LOCA analysis which addressed ESF leakage following 'the LOCA, l 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 7'9.39(c) limits' for plutonium. . Leakage of sources excluded

, from the requirements of this specification represent less than one i 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 i

f i -BEAVER VALLEY UNIT 1 B 3/4 7-5 PROPOSED WORDING L _

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", 10 CFR 50.

i i

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BEAVER VALLEY - UNIT 1 B 3/4 9-4 PROPOSED WORDING l

O ATTACHMENT B N \

Question: Applicant must provide identification of technical specifications for operability- and surveillance. of-chlorine and radiation- instrumentation channels, actuation logic, _ master. relays and- slave- relays associated with . automatic control room isolation on high-chlorineLand radiation signals.

Response: The control room Jarea radiation monitoring instrumentation channels are. specified in- BVPS-2 Technical'. Specification ~.(Tech Spec)-3/4.3.3.1.- The LCO specifies the minimum number of channels operable, the applicable modes and action statements. Surveillance for i channel check, channel' calibration and channel function test are specified in Table'4.3-3. These surveillances are conducted shiftly, monthly and every- 18 months

! through station procedures. The control-room isolation ;

function on high radiation is included by the OPERABILITY criteria for- the Control Room Emergency Habitability Systems as per .the LCO from Tech Spec 3/4.7.7.1.

Verification of actuation of components for control room isolation on high radiation is demonstrated in the Tech specs by Surveillance 4.7.7.1.1.d.2 and 4.7.7.1.2.d.2 by ,

verifying every 18 months that- on a control room high t radiation test signal from either unit, .the systems 4 closes all series isolation ventilation system. dampers.

These surveillances are conducted through station

procedures. The response time for control room' isolation 2 on high radiation will be added to the BVPS-2 Tech specs j in Table 3.3-5.

similarly, for high chlorine, the LCO from Tech Spec

) 3/4.3.3.7 specifies the minimum number of chlorine detection system channels, -the applicable modes and

. action statements. Surveillance- 4.3.3.7 specifies a j channel functional test every 31 days and .a channel calibration at least once per 18 months for the chlorine detection system. The response time for-the chlorine -

system will be added to the LCO for the BVPS-2 Tech Spec l 3/4.3.3.7. These surveillances are conducted through station procedures. Similarly to the' high' radiation function, the control room isolation . function on high chlorine is included by the OPERABILITY criteria for Control' Room Emergency Habitability Systems in the LCO of Tech Spec 3/4.7.7.1. Implicit in the definition of l OPERABILITY (see Section 1.6 of the Tech Specs). is the assumption that all necessary attendant instrumentation, i controls, normal and emergency electric power systems or other auxiliary equipment that 'are required fe' the l 4

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

7 4 6 ATTACHMENT B (Continued)- -

i ~

1-system, subsystem, train, component-or device lto_ perform its function (s) are also capable ~o ft performing their related safety function (s). This includes the actuation logic, master relays and slave relays. associated with the automatic control -room isolation on high chlorine.- .This

. definition is . consist'ent uwith the definition- (and.

~

practice) ~

established and implemented for over ten years for the operation-of Beaver Valley Unit 1.

{ '

Verification of actuation is demonstrated by' Surveillance a 4.7.7.1.1.a.2 and 4.7.7.1.2.d.3 through verification of-correct . control isolation with a. .high chlorine . test signal. That portion of the control room isolation that-

' goes through the Solid' State Protection System-(SSPS)'is-

} tested monthly on a- ' staggered test basis during j' functional testing.. '

i Question: How does DLC plan to ensure that:the status or a change

, in status (i.e., OPERABILITY /inoperability) of. subsystems or components 'in the Control Room Emergency Habitability 8

System on one side of the control; room is adequately r

, relayed to the operators on the other side of the control room. ,

i Response: The Emergency Safeguard Equipment- Checklist of Station Administrative Procedure (SAP. 41) " Clearance Procedure" i

will be revised. This revision will require the

, concurrence by initials of .BVPS-1 and BVPS-2. Nuclear

Shift Supervisors prio'r to removal from. service'of the '

following equipment from either unit:

, - 1) 4160 kv bus AE l~ 2) 4160 kv bus DF j 3) Emergency Diesel Generator-

! 4) Any equipment- that. is a part of the Control Room ,

Emergency Habitability Systems j Question: Provide justification why an automatic BISI indication is 4

not warranted when output relay fuses are' removed to prevent inadvertent ESF actuation per'the=LCO 3.9.15.111n the proposed Tech ' Spec on Control Room Emergency Habitability Systems when'both units are shutdown.

Response: DLC does not expect to conduct this action more than once

! a year. The asterisk note will be modified to state that 4

this action will only be allowed ~for one Unit at:a time. l

This will ensure that all dampers will'be fully operable l to bring fresh air into the control room. In addition, I at each of the output relay test panels on each unit, a i

i t

i

,,.r,- n ,,. ,r--,, ,-+, -w----v-,,-,,+-y,. - - - , , - - , ,-, ,,nc m_,., ,.g,-, , , , , , -, m.r.,,-e-,,.,-gen..,w,, ,g- .- ,,,.,n,- ..,n, ,,, > -e . e p

ATTACHMENT B (Continued)-

permanent caution tag will be-installed near.the output

, relay power. fuses. This caution tag will-clearly define the following prior to fuse removal:

At BVPS-2 Control Room j . 1) Notify BVPS-1 Nuclear-Shift Supervisor and Exhaust-

2) Isolate Intake Dampers (2HVC 201A(B)(C)(D)], if the other units chlorine detectors are inoperable.

3) 'Back-light " Control Room Ventilation- Isolation"

pushbutton at bypassed and inoperable status indication panel.

At BVPS-1 Control Room i

1) Notify BVPS-2 Nuclear Shift Supervisor

2) Isolate Intake and Exhaust- Dampers (VS-D-40-1A (B)(C)(D)], if other units chlorine detectors are inoperable.

3)- Back-light " Control Room Ventilation. Isolation" pushbutton at Emergency Safeguard Panel.

t 5

e h

a ATTACHMENT'

I l

l l

E

'Isr0C :

Te eceone t412. 333-67A Bon 4 SNppingport. PA 15077-0004 May 12, 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Technical Specification Change Request No. 126, Rev. 2, Confirmatory Items Gentlemen:

In our submittal of April 16, 1987 we provided the above referenced change request. Therein, we stated that it would be necessary to provide follow-up documentation confirming that radiation doses to the control room operators would meet acceptance criteria and that they would be adequately protected from a chlorine gas release.

In order to demonstrate the control room operators are protected in accordance with 10 CFR 50, Appendix A, GDC-19, a complete set of new Beaver Valley Unit 1 analyses were performed in order to be consistent with the analyses completed for Beaver Valley, Unit 2.

The results of these analyses demonstrate that with the implementation of the identified modifications, the control room operators will be protected in accordance with GDC-19 and that there are no significant differences in the radiological consequences of the BVPS-1 and BVPS-2 accidents.

Additionally, we compared the control room operators doses, both before and after the control room emergency ventilation system modifications, to demonstrate there was no significant increase in j hazard to the operators. The results are tabulated on Table 1 which '

show an actual decrease in dose to the thyroid as a result of these modifications. The overall dose is demonstrated as being reduced to the control room operators. This reduction in dose is a result of two independent factors; 1) the control room volume is increased which results in a more diluted concentration in the control room and

2) the increased air make-up rate results in an increased purge rate l of the control room with filtered air. '

The major contributor to the operators dose is the assumption that there is 10 cfm unfiltered in-leakage to the control room in accordance with SRP guidelines. At one hour after the accident, the containment is returned to subatmosphoric conditions and the only remaining release is that from ECCS leakage which is filtered prior

f. -

Banver Valley Powar Station, Unit No.:1: l P - Docket No. 50-334,. License No. DPR-66. -!

' Technical Specification - Change . Request No. 126, Rev.-2, i

.- Confirmatory Items l

Page 2 to release -from the plant areas. From.this time on, the source in'

the control. room is diluted as the emergency ventilation system-i purges- this air from -the-control room envelope. _outleakage is via.

normal control ~ room- leakage- paths. The increased air flow rate '

l increases the rate of purge and results in a lower dose to the j- operators.

i In order to further- illustrate this point, ~a dditional f calculations were performed. Table 2'provides calculation results ;

i -which demonstrate that as the flow increases the dose decreases. The i

! calculations are. for the combined control room with all parameters i 2

= remaining- the same except forcthe make-up air flow rate (emergency i ventilation intake _ rate). You should note that the doses on Table 2 are higher. than on Table' 1 for the 690 cfm make-up air flow rate

! (minimum required flow to maintain the combined control room at a pressure of 1/8- inch water gauge above atmospheric) to the' combined 4

control room. The reason for this is an assumed efficiency.of 90% on

, the main filter banks, Supplemental. Leak Collection and Release

}~ System (SLCRS), versus a 95% efficiency forithe SLCRS on Table 1.

Since Table 2 is being provided to demonstrate dose decreases as. flow

~

4 increases, the 90% SLCRS efficiency is not a significant issue.' Our analyses of record, Table 1, assumes a 95% collection efficiency, Table 2 is for illustration only*. Furthermore, it is worth noting

that at an- assumed 90% SLCRS collection efficiency we are still j capable of demonstrating compliance to GDC-19. -

[ The second item requiring confirmation addressed the ability to i

protect the operators from a chlorine release accident. At the time ,

of our. April 16, 1987 submittal, we were conducting analyses to -

demonstrate our installed chlorine detectors would provide the required protection. Since that time we have determined the system response was inadequate and we' are in the process of replacing it l with a system similar to that which has been installed in. Unit 2. i The details of the problems associated with these detectors will be discussed in further detail in separate correspondence submitted in +

accordance with 10 CFR 50.73. We are obtaining vendor data and

, conducting additional investigations into the- expected operating i characteristics of the new chlorine detectors. A new analysis has .

2 not been completed at this time. We do commit, however, to providing i chlorine protection such that the toxicity limits are not exceeded in the control room in the first two minutes after the operators are.

i made aware of the presence of chlorine. This is consistent with

Regulatory Guide 1.95, Section B and our stated position in the no significant hazards censideration for Technical Specification Change Request No. 126, Rev. 2. We will'be operating in.accordance with our i Technical Specification on chlorine detectors, and the related NRC l SER, in the interim until this modification is completed. .There are no changes to our Technical Specifications required,as a result of f our upgrading our chlorine detectors.

i l l :

l

-x .

i. ' Beaver Vall'ey-Power Station, Unit'No.'l l

" Docket No. 50-334, License-No. DPR-66 i

Technical Specification Change Request No. 126, Rev. 2, Confirmatory Items i Page l 1

If ' your have-any questions regarding this submittal, please call me or members of my staff..

Very truly yours, 4

. J. Carey.

Senior Vice President, Nuclear cc: Mr. S. M. Pindale, Resident Inspector U. S. Nuclear Regulatory Commission ,

Beaver Valley Power Station Shippingport, PA 15077 i U. S. Nuclear Regulatory Commission Regional Administrator ,

Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Peter S. Tam ,

U. S. Nuclear Regulatory Commission 1

Project Directorate No. 2 l Division.of PWR Licensing - A Washington, DC .20555

- Mail Stop 316 j Addressee only i

^

Director, Safety Evaluation & Control

Virginia Electric & Power Company j P.O. Box 26666 One James River Plaza

Richmond, VA 23261 3

Mr. Thomas M. Gerusky, Director i Bureau of-Radiation Protection Pennsylvania Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 i

4

)

1 5

,' TABLE 1 0

BV-1 LOCA - Control Room Doses

-(includes ECCS Leakage Summary)

(30-Day Integrated Doses)

Before Modifications (1) After Modifications (2)

Doses (Rem)

Thyroid. 25 17-Gamma 0.23 < 0.3 Beta 2.1 < 2.5 (1) Ref: Calc. 14110.39-UR(A)-457-0; assumes a 360 cfm air make-up flow rate to the Unit 1 control room volume.

4

, (2) Ref: Calc. 14110.39-UR(B)-450-1; assumes'a 690 cfm air make-up flow rate to the combined control room volume.

t k

(

i

\

_ ~ . . .

b y TABLE 2 (1)

=

BV LOCA - Control Room Doses

- Versus Emergency Ventilation Intake Rate 30-Day Integrated Intake Rate Dose (Rem) 690 cfm 1000 cfm Thyroid 26 23 Gamma < 0.3 < 0.3 Beta < 2.5 < 2.5 (1) Ref: Calc. 14110.39-UR(B)-450,-1 (TABLE 3-E)'

l l

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