ML20215K362

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Clarifies Util Position W/Respect to Implementing Requirements Presented in SA Varga Re Removal of Control Room Chlorine Detectors.Proposed Changes to Tech Specs (NUREG-1223) Encl
ML20215K362
Person / Time
Site: Braidwood  
Issue date: 05/06/1987
From: Hunsader S
COMMONWEALTH EDISON CO.
To: Murley T
Office of Nuclear Reactor Regulation
References
RTR-NUREG-1223 3044K, NUDOCS 8705110167
Download: ML20215K362 (4)


Text

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r C0ffMINNlwealth Edloon One First National Plaza. Chicago, Illinois Address Reply to: Poet Omco Box 767 Chicago, Illinois 60690 0767 i

i May 6, 1987 Mr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 i

Subject:

Braidwood Station Units 1 and 2 Removal of Control Room Chlorine Detectors I

4 NRC Docket Nos. 50-456/50-457 i

References:

(a) March 4, 1987 S. A. Varga letter to D.

L. Farrar (b) April 2, 1987 S.

C. Hunsader letter to H. R. Denton (c) April 22, 1987 S.

C. Hunsader letter to T. E. Murley

Dear Mr. Murley:

i The purpose of this letter is to clarify Commonwealth

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Edison's position with respect to implementing the requirements presented in reference (a), dealing with the removal of the Control Room chlorine detectors.

Reference (a) provided the NRC staff review and evaluation of Commonwealth Edison's submittals that sought approval to remove the chlorine detectors.

Reference (b) provided Commonwealth Edison's committment to provide manual isolation capability of the control room envelope and to subsequently demonstrate this isolation capability on an 18-month basis, thereafter, via a Technical Specification surveillance.

i Attachment A provides an advanced submittal for NRC review I

i of the Technical Specification addition addressing this surveillance, i

Reference (c) provided Commonwealth Edison's response to reference (a) and stated that Commonwealth Edison takes exception to the requirement of demonstrating control room integrity.

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T. E. Murley, Director May 6, 1987 i

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Until resolution of the matters presented in reference (c) is obtained, Commonwealth Edison will adhere to the requirements of reference (a).

A station procedure is being developed to address 1

the control room integrity demonstration as required in reference (a).

j Please address any questions concerning this matter to this office.

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Very truly yours, j

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S. C. Hunsader j

Nuclear Licensing Administrator i

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J. Stevens NRC Resident Inspector i

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3044K I

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Attachment A Proposed changes to NUREG-1223 Technical Specifications Braidwood Station Revised paae:

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%d pkced in nt (cc irc u Mlw ode oC Q Rm, PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

(except for adjacent control room areas pressurized as specified above) when operating an Emergency Makeup System at a flow rate of 6,000 cfm i 10% and the recirculation charcoal adsorber at a flowrate of 49,500 cfm i 10%.

f.

Af ter each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in place penetration testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a 00P test aerosol while operating the Emergency Makeup System at a flow rate of 6000 cfm + 10%; and g.

After each complete or partial replacement of a charcoal adsorber bank in the Emergency Makeup System by verifying that the cleanup system satisfies the in place penetration testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydro-carbon refrigerant test gas while operating the system at a flow rate of 6000 cfm i 10%.

h.

At least once per 18 months or (1) after any structural maintenance on the charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the recirculation charcoal adsorber by:

(1) Verifying that the recirculation charcoal adsorber satisfies the in place penetration testing acceptance criteria of less than 2%

total bypass and uses the test procedure guidance in Regulatory Positions C.5.a, and C.S.d of Regulatory Guide 1.52 Revision 2, March 1978, and the system flow rate is 49,500 cfm i 10% for the recirculation charcoal adsorber; (2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample from the recirculation charcoal adsorber 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 Regulatcry Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1% when tested at a temperature of 30*C and a relative humidity of 70%; and (3) Verifying a system flow rate of 49,500 cfm i 10% for the Recircula-tion Charcoal Adsorber when tested in accordance with ANSI N510-1960.

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After each complete or partial replacement of a charcoal adsorber bank in the Recirculation Charcoal Adsorber System by verifying that the cleanup system satisfies the in place penetration testing acceptance criteria of less than 0.1% in accordance with ANSI H510-1980 for a halogenated hydrocarbon refrigerant test gas while operating at a system flowrate of 49,500 cfm i 10%.

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After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of Recirculation Charcoal Adsorbcr operation by verifying within 31 days af ter removal, that a laboratory analysis of a representative carbon sample obtained in accordanc~ -.ith Regulatony Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978 meets the laboratory testing criteria of Re0ulatory Guide 1.52, Revision 2, March 1978 for a methyl iodide penetration of less than 1% when tested at a temperature of 30 C and a relative humidity of 70%.

ORAIDWOOD - UNITS 1 & 2 3/4 7-16