ML20247D883

Proposed Tech Specs,Changing Tech Spec 4.7.6.D,control Room Area Ventilation Sys Surveillance Requirements by Extending Carbon Absorber Sampling Frequency from 720 H to 1440 H

ML20247D883
Person / Time
Site:	Catawba
Issue date:	07/14/1989
From:	DUKE POWER CO.
To:
Shared Package
ML20247D867	List: ML20247D861 ML20247D883
References
NUDOCS 8907250324
Download: ML20247D883 (9)

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. j PLANT SYSTEMS 3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM j LIMITING CONDITION FOR OPERATION-3.7.6 Two independent Control Room Area Ventilation Systems shall be OPERABLE.

APPLICABILITY: ALL MODES ,

ACTION: (Units 1 and 2)

MODES 1, 2, 3 and 4:

With one Control Room Area Ventilation System inoperable,. restore the inoperable system to OPERABLE status within 7 days or' be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6:

a. With one Control Room Area Ventilation System inoperable, restore l the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control Room Area , .

Ventilation System git;. ilu. unvuyn i.i . .iUA i;l we er.d r+4"M-d - I j l

b. With both Control Room Area Ventilation Systems inoperable, or with l the OPERABLE Control Room Area Ventilation System, required to be operating by ACTION a., not capable of.being powered by an OPERABLE 1 emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

c. The provisicns of Specification 3.0.4 are not applicable, j SURVEILLANCE REQUIREMENTS 4.7.6 Each Control Room Area Venti',4 tion System shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the control room air temperature is less than or equal to 90 F;

o. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and activated j ,

carbon adsorbers and verifying that the system operates for at:least 10 continuous hours with the heaters operating; -

CATAWBA - UNITS 1 & 2 3/4 7-14 Amendment No. 37 (Unit 1) 8907250324 890714 Amendment No. 29 (Unit 2)

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PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 18 months or (1) after any stru::tural maintenance on the HEPA filter or activated carbon adsorber housings, or l

(2) following painting, fire, or chemical release in any ventilation {'

zone communicating with the system by:

1) Verifying that the cleanup system satisfies the in place l penetration and bypass leakage testing acceptance criteria of' less than 1*' (' hit 1LO.05% -("r !;. 2) and uses the test pro-cedure guidance in Regulatory Position C.5.a, C.5.c, and C.S.d*

of Regulatory Guide 1.52, Revisions 2, March 1978, and the syste<n flow rate is 6000 cfm i 10%;

2) Verifying, within 31 days after removal,.that a laboratory analysis of a representative activated carbon sample obtained {

in accordance_with Regulatory Position C.6.b of-Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide'1.52, Revision 2, March 1978, for a methyl iodide penetration of less tha g and

3) Verifyirig a system flow rate of 6000 cfm + 10% during system operation when tested in accordance with KNSI N510-1980.

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d. After every 390 hours0.00451 days <br />0.108 hours <br />6.448413e-4 weeks <br />1.48395e-4 months <br /> of activated carbon adsorber operation, by If verifying, within 31 days'after removal, that a laboratory analysis W of a representative activated carbon sample obtained in accordance - "t, with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Posi-tion C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyliodidepenetrationoflessthanX%;% d.05

e. At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters, activated carbon adsorber banks, and moisture separators is y less than 8 inches Water Gauge while operating the system at a flow rate of 6000 cfm + 10%;

2) Verifying that on a High Radition-Air Intake, or Smoke Density- ,

High test signal, the system automatically isolates the affected l intake from outside air with recirculating flow through the HEPA filters and activated carbon adsorber banks;

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3) Verifying that the system maintains the control room at a posi-tive pressure of greater than or equal to 1/8 inch Water Gauge relative to adjacent areas at less than or equal to pressuriza-tion flow of 4000 cfm to the control room during system operation;

4) Verifying that the heaters dissipate 2512.5 kW, and

• The requirement for reducing refrigerant concentration to 0.01 ppm may be satisfied by ooerating the system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with heaters on and operating.

%%4ed carWm adsorber %mples are tested ab 30 degere C . '

CATAWBA - UNITS 1 & 2 3/4 7-15 An:endme(nt No 37 (Unit 1) l Anendmegt Nio.29-(&it 2-)w j

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' PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 5)

Verifying that on a High Chlorine / Toxic Gas test signal, the

. system automatically isolates the affected intake from outside air with recirculating flow through the HEPA filters and acti-vated carbon adsorbers banks within 10 seconds (plus air travel  !?

time between the detectors and the isolation dampers).

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After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in place penetration 0.05% (Un L ') in accordance with ANSI for N510-1980and a t?OP test aero ybypass ; leaka sol while operating the system at a flow rate of 6000 cfm i 10%; and g.

After each complete or partial replacement of an activated carbon adsorber bank, by verifying that the cleanup system satisfies the  %

in place penetration and bypass leakage testing acceptance criteri,-

of less than N510-1980 1% (Unit Q 0.05%.(4WM in. accordance with ANSI L for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 6000 cfm i 10%.

A CATAWBA - UNITS 1 & 2 3/4 7-16 Am AmhndmehNo.

ment Ro.)9 o (Un 37,-@h t 1)

PLANT SYSTEMS i i

BASES )

3/4.7.5 STANDBY NUCLEAR SERVICE WATER POND The limitations on the standby nuclear service water pond (SNSWP) level and temperature ensure that sufficient cooling capacity is available to either:

(1) provide normal cooldown of the facility, or (2) mitigate the effects of 1 accident conditions within acceptable limits. {

The limitations on minimum water level and maximum temperature are based on providing a 30-day cooling water supply to safety-related equipment without exceeding its design basis temperature and is consistent with the recommend- '

ations of Regulatory Guide 1.27, " Ultimate Heat Sink for Nuclear Plants,"

March 1974.

The peak containment pressure analysis assumes that the Nuclear Service o Water (RN) flow to the Containment Spray and Component Cooling heat exchangers (

has a temperature of 86.5 F. This temperature is important in that it, in

! part, determines the capacity for energy removal from containment. The peak (

3 containment pressure occurs when energy addition to containment (core decay heat) is balanced by energy removal from these heat exchangers. This balance is reached far out in time, after the transition from injection.to cold leg  ?

recirculation and.after ice melt. Because of the effectiveness of the ice bed (

in condensing the steam which passes through it, containment pressure is insensitive to small variations in containment spray temperature prior to ice meltout.

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To ensure that the RN temperature assumptions are met, Lake Wylie ,

temperature is monitored. During periods of time while Lake Wylie temperature (

is greater than 86.5 F, the emergency procedure for transfer of ECCS flow ) '

paths to cold leg recirculation directs the operator to align at least one (

train of containment spray to be cooled by a loop of Nuclear Service Water )

which is aligned to the SNSWP. '

3/4.7.6 CONTROL ROOM AREA VENTILATION SYSTEM The OPERABILITY of the Control Room Area Ventilation System ensures that:

(1) the ambient air temperature does not exceed the allowable temperature for continuous-duty rat-ing for the equipment and instrumentation cooled by this system, and (2) the control room will remain habitable for operations personnel during and following all credible accident conditions. Operation of the system with the heaters operating to maintain low humidity using automatic control 'for at least'10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.V The l 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 rems or less whole body, or its equivalent, This limitation is con- '

sistent with the requirements of General Design Criterion 19 of Appendix A, 10 CFR Part 50. ANSI N510-1980 will be used as a procedural guide for surveil-lance testing. l I%e, %Q km Atem \laDab yS sIem fihr t>d hve. ho byP"M \id

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gwty.yAew a MM ts * *eaab" > 35 me*yi d bee al5* *s 'ab4l CATAWBA - UNITS 1 & 2 B 3/4 7-3a Am J , i L

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.l ATTACHMENT II NO SIGNIFICANT HAZARDS ANALYSIS j AND ENVIRONMENTAL IMPACT STATEMENT  !

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NO SIGNIFICANT HAZARDS ANALYSIS AND ENVIRONMENTAL IMPACT STATEMENT This analysis providcs a determination that proposed changes to Technical Specifications 3.7.6.A, 4.7.6.C, 4.7.6.D, 4.7.6.F, and 4.7.6.G do not involvc significant hazards considerations as defined by 10 CFR 50.92.

The proposed change to Technical Specification 3.7.6.A deletes a reference to Control Room Area Ventilation system flow being through the REPA filters and activated carbon adsorbers. This is an administrative change intended to eliminate a redundant statement which could cause misunderstanding. The Control Room Area Ventilation System Filter units have no bypass line. Train A or Train B must operate in the filtered mode continuously.

The proposed changes to Technical Specifications 4.7.6.C 1 4.7.6.F, and 4.7.6.G replace the Unit 1 bypass leakage acceptance criteria of less than 1% with the more conservative Unit 2 bypass leakage acceptance criteria of less than 0.05%. These proposed changes provide for consistency between Catawba Units 1 and 2. The proposed 0.05% bypass leakage acceptance criteria also eliminates ambiguity which may arise due to the shared aspects of the control room area ventilation system.

Two proposed changes to Technical Specifications 4.7.6.C.2 and 4.7.6.D replace the methyl iodide penetration testing criteria of less than 1%

with the more conservative methyl iodide penetration testing criteria of less than 0.175%. This proposed change is to meet the intent of Regulatory Guide 1.52.

An additional proposed change to Technical Specification 4.7.6.D seeks to extend the Control Room Ventilation System carbon adsorber sample time interval from 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> to 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> because existing requirements are overly restrictive.

The Catawba Nuclear Station Control Room Area Ventilation System is equipped with state-of-the-art Triethylenediamine (TEDA) 4-inch thick carbon adsorber beds. The Control Room Area Ventilation System Filter units have no bypass line. Train A or Train B must operate in the filtered mode continuously. When a train is in operation its associated heater also runs continuously. The TEDA carbon beds have not been replaced since initial operation. Attachment 1 contains a proposed change to Technical Specification bases section 3/4.7.6 documenting these operating and design characteristics of the Control Room Area Ventilation System.

Carbon adsorber samples are obtained by the grain thief method which involves insertion of a sampling rod into the bed. Carbon samples are usually taken two to three days after the heater is taken out of service.

Laboratory analysis of carbon adsorber samples are performed by Nuclear Containment Systems Inc., Columbus, Ohio. Testing is conducted at a 30 degree C. temperature, 101 kpa pressure and 70% relative humidity. A proposed footnote to Technical Specification 4.7.6 specifies that all future sample testing be performed at a 30 degree C, temperature.

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I il A total of 67 TEDA carbon adsorber tests have been performed over a period  !

of six years covering typical atmospheric and seasonal conditions. .These j san.ple analysis results revealed no noticeable degradation in the methyl '

iodide removal efficiency of the carbon. The methyl iodide removal sample analysis results ranged from 99.98% to 99.94% efficiency for filter unit ICRA-PFT-1 and from 99.99% to 99.76% efficiency ,fer filter unit j 2CRA-PFT-1. The main reason for the fluctuation on the removal j efficiencies is the' location from which samples are obtained. Samples '

taken from the front of the cacbon bed have been challenged more than samples obtained from the back of the bed. It is Duke Power's practice to sample the front, back, and middle of the bed to obtain results more representative of the carbon bed condition.

I Three samples taken from filter unit 2CRA-PFT-1 exceeded the proposed 1 Technical Specification 4.7.6.C.2 and 4.7.6.D 0.175% methyl iodide ]

penetration criterja. However, it should be noted that up to the'present time methyl iodide removal tests were performed assuming a 2-inch thick  ;

carbon bed. This assumption is highly conservative because Catawba 1 Nuclear Station is equipped with 4-inch thick carbon beds. Duke Power and Nuclear Containment Systems personnel have reviewed the testing-procedures j and determined that if credit is taken for the 4-inch thick carbon beds,

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the methyl iodide % penetration would have been less than 0.01%. The i latest carbon sample was tested taking credit for the 4-inch thick carben bed. The test result indicated that the methyl iodide % penetration was i less than 0.01%. All future tests will be performed taking credit for the 1 4-inch thick carbon beds.

Pursuant to 10 CFR 50.492, this analysis provides a determination that the proposed ammdment to the Technical Specifications involves no significant hazards constaet . ions if operation in accordance with the proposed amendment would nw -

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

The proposed changes to Technical Specification 4.7.6.C.1, 4.7.6.C.2, 4.7.6.D. 4.7.6.F, and 4.7.6.G do not increase the probability or consequences of any previously evaluated accident. These changes may actually enhance the ability to mitigate the consequences of previously evaluated accidents since the more conservative bypass leakage and methyl iodide acceptance criteria will provide additional assurance of system l reliability. Carbon sample analysis results indicate that over the course f of six years there was no noticeable degradation in the carbon adsorber methyl iodide removal efficiency. Increasing the Technical Specification 4.7.6.d sample time intervals to 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> has no significant impact to the efficiency of the carbon adsorbers and Control Room Area Ventilation System operability. The control room ventilation system design basis are not affected. These requested changes do not adversely affect the control room ventilation system ability to fulfil its intended safety function.

Therefore, the proposed changes cannot increase the probability or consequences of any previously evaluated accident.

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The proposed changes to Technical Specifications 4.7.6.C.1, 4.7.6.C.2, and 4.7.6.D do not create the possibility of a new or different accident from any accident previously evaluated. The more conservative bypass leakage and methyl iodide penetration acceptance criteria and the proposed 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> sampling interval do not postulate any new failure modec. These changes have no adverse effect on the function, operation, or efficiency of the Control Room Area Ventilation System and do not affect any parameter for which the system was designed. Therefore the proposed Technical Specification change cannot create the possibility of a new or ,

s different kind of accident from any accident previously evaluated.

The proposed changes to Technical Specification 4.7.6.C.1, 4.7.6.C.2, 4.7.6.D, 4.7.6.F. and 4.7.6.G do not reduce any margin of safety. These changes do not adversely affect any safety limit, setpoint, or operating 1 ..

pareneter associated with a margin of safety. The more conservative

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bypass leakage and methyl iodide penetration acceptance criteria do not -

decrease equipment reliability. The proposed acceptance criteria will l actually provide increased assurance of the control room ventilation (y l

! system reliability and of its ability to fulfill its intended safety V i

i function. The Catawba Nuclear Station Control Room Ventilation System

• J l Carbon adsorbers are capable of extended operation without any significant El l

reduction in their methyl iodide removal efficiency. Laboratory carbon /

sample analysis results indicate that the proposed carbon as sorber ,;-

sampling interval of 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> will not reduce the efficien;y of the .;

Control Room Ventilation System in any significant manner. Therefore, the L~

proposed Technical Specification changes do not involve a significant reduction in a margin of safety. ,, ,

The proposed change to Technical Specification 3.7.6.A is an 'i:

administrative change intended to eliminate a redundant statement. The Control Room Area Ventilation System filter units have no bypass line.

The system is designed so that either train must operate in the filter i made continuously. When a train is in operation, its associated heater also runs continuously. Technical Specification Bases Section 3.4.7.6 has '

been revised to document these design and operational characteristics of -

( the Control Room Area Ventilation System. This administrative change has l no impact in'the design and operation of the Control Room Area Ventilation l System. This change does not involve significant hazards considerations.

The commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing examples of amendments that are considered not likely to involve a significant hazards consideration (Federal Register, Vol. 48, No. 67, pg 14870). Example (iv) involves "A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated". The proposed extension of the Technical Specification 4.7.6.d carbon adsorber o

sampling interval to 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> is similar to Commission Example (iv).

The proposed extension in the sampling interval is justifiable because previous operation of the Control Room Ventilation System indicates that the 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> sampling frequency will have no effect on the efficiency or reliability of the TEDA carbon adsorber beds.

Based upon the preceding analysis, Duke Power Company concludes that the proposed amendments do not involve any significant hazards considerations.

The proposed Technical Specification changes have been reviewed against the criteria of 10 CFR 51.22 for the environmental considerations. As shown above, the proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or cumulative occupational

( radiation exposures. Based on this, the proposed Technical Specification changes meet the criteria given in 10 CFR 51.22(c)(9) for a categorical' exclusion from the requirement for an Environmental Impact Statement.

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