ML20247H948
| ML20247H948 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/15/1998 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20247H935 | List: |
| References | |
| NUDOCS 9805210293 | |
| Download: ML20247H948 (7) | |
Text
. _ _ _
PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM SURVEILLANCE'E REQUIREMENTS (Continued) 2.
Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in l
accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. July 1976, and tested in accordance with the methodology provided by ASTM D3803-1989 a,t a temperature of 30 C and a relative humidity of 95%. meets the acceptance criteria of < 5.0% penetration of methyl iodide.
3.
Verifying a system flow rate of 2000 cfm 10% during system operation when tested in accordance with ANSI N510-1975.
c.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1.
July 1976, and tested in accordance with the methodology provided by ASTM D3803-1989. at a temperature of 30 C* and a relative humidity of 95%*. meets the acceptance criteria of < 5.0%
penetration of methyl iodide.
d.
At least once per 18 months by:
1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is 5 5.25 inches Water Gauge while operating the filter train at a flow rate of 2000 cfm 10%.
2.
Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.
3.
Verifying that on a chlorine detector test signal, the control building ventilation system automatically isolates and the control room emergency filtration system cannot be started by a smoke detector or control room ventilation system high radiation test signal.
4.
Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.
- Laboratory testing within the temperature and humidity tolerances provided in Table 1 of ASTM D3803-1989 constitutes compliance with Surveillance Requirements 4.7.2.b.2 and 4.7.2.c.
9905210293 980515 PDR ADOCK 05000324 p
PDR BRUNSWICK - UNIT 1 3/4 7-4 Amendment No.
PLANT SYSTEMS BASES 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)
Surveillance Requirements The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a subsystem in the standby mode starts on demand and continues to operate.
Standby systems are checked periodically to ensure that the automatic start function is consistent with the assumptions in the Control Room Habitability Analyses (References 4 and 6).
Since the environmental conditions on this system are not severe, monthly demonstration of the capability of the sys'em to operate by SR 4.7.2.a is considered adequate.
The > 15 minute run time is i
considered adequate for operation of systems without heaters (Reference 16).
1 SR 4.7.2.b verifies the caoability of the filtration system at least once every 18 months, or 1) following any structural maintenance on the filtration unit HEPA filter or charcoal adsorbers or 2) following painting, fire, or chemical release in any ventilation zone communicating with the system.
Field testing is performed in accordance with applicable sections of Regulatory I
Guide 1.52. Revision 1. and ANSI N510-1975. The use of Regulatory Guide 1.52.
Revision 1 and ANSI N510-1975 is consistent with the guidance provided in Generic Letter 83-13 (Reference 7). Charcoal samples for laboratory testing are obtained per the applicable sections of Regulatory Guide 1.52. Revision 1.
The laboratory testing 1s
' D3803-1989 (Reference 17). performed in accordance with the methodology in ASTM ASTM D3803-1989 is a more current testing standard i
which was developed after the Generic Letter 83-13.
It contains criteria for use with charcoal beds with no humidity control, this is consistent with the design of the CREV system. The acceptance criteria used for the laboratory test is < 5.0% penetration of methyl iodide (Reference 18). This corresponds to a 90% filtration efficiency which is the filtration effi' ~ 'cy assumed in the bounding calculations of control room doses.
As such.
acceotance criteria of < 5.0% penetration of methyl iodide ensures thuc beneral Design Criterion 19 dose limits for control room operators are not exceeded.
SR 4.7.2.c verifies adequacy of the charcoal filtration system following every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.
The time of o)eration is based on the recommendations of Regulatory Guide 1.52. Revision 1 (Reference 8), and early nuclear plant filter testing (Reference 10).
SR 4.7.2.d demonstrates functional capability of the system by verifying
- 1) pressure drop across the HEPA and charcoal filtration units. 2) automatic emergency system initiation upon receipt of a smoke detector or high radiation test signal. 3) the override function of the chlorine protection function, and
- 4) ability of the system to maintain a positive pressure relative to the outside atmosphere during system operation.
The maximum pressure drop of
< 5.25 inches water gauge is based on a CREVS pressure drop analysis TReference 9) and fan capability. This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water gauge margin for filter loading. The positive pressure test is performed to ensure that the control room 1s maintained positive to any potentially contaminated external atmosphere.. including the outside atmosphere and adjacent building atmosphere (s).
Testing of the chlorine override function ensures operability of the chlorine protection mode of the CREVS by demonstrating the capability i
of the system to prevent the emergency filtr:ation units from initiating during a chlorine event.
SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control Room Habitability Analyses (References 4 and 6) following partial or complete replacement of either filtration component. The testing is performed in accordance with the applicable sections of ANSI N510-1975 (Reference 14),
l BRUNSWICK - UNIT 1 B 3/4 7-lh Amendment No.
PLANT SYSTEMS l
BASES
^
J 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) 1 References 1.
10 CFR 50. Appendix A. General Design Criterion 19. Control Room.
2.
Regulatory Guide 1.95. Revision 1. Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.
3.
Updated FSAR. Brunswick Steam Electric Plant. Units 1 & 2.
4.
NUS-3697. Revision 2. February 1983. Control Room Habitability Analysis.
5.
NLU-83-673 TMI Action Item III.D.3.4 - Control Room Habitability. NRC Safety Evaluation dated October 18. 1983.
6.
NUS-4758. Control Room Radiological Reanalysis. August, 1985.
7.
Generic Letter 83-13. Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical l
Specifications of ESF Cleanup Systems. March 2.1983.
3.
Regulatory Guide 1.52. Revision 1. July 1976.
9.
CP&L Calculation G0077A-01 Control Room Emergency Filter System Differential Pressure Analysis.
10.
Original FSAR. BSEP. Units 1 and 2. Appendix K.
11.
IEEE 279-1971. IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.
12.
DBD-37. Design Basis Document for Control Building Heating. Ventilation, ad Air Conditioning System.
13.
NRC-89-103. NRC Safety Evaluation for Control Room Habitability.
February 16. 1989.
14.
ANSI N510-1975. Testing of Nuclear Air Cleaning Systems.
15.
ANSI N509-1976. Nuclear Power Plant Air Cleaning Units.
16.
NUREG-1433. Standard Technical Specifications. General Electric Plants.
BWR/4. Revision 0. September 28, 1992.
17.
ASTM D3803-1989 (Reapproved 1995). Standard Test Method for Nuclear-Grade Activated Carbon.
18.
ESR 97-00078 Revision 1. Charcoal Testing for CBEAF per ASTM D3803-1989.
BRUNSWICK - UNIT 1 B 3/4 7-li Amendment No.
)
~
ENCLOSURE 2 l
l BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS DPR-71 AND DPR-62 CONTROL ROOM EMERGENCY VENTILATION SYSTEM CliARCOAL TESTING REQUIREMENTS (NRC TAC NOS. M99232 AND M99233) i l
REVISED TECHNICAL SPECIFICATION PAGES - UNIT NO. 2 l
5 l
PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM SURVEILLANCE REQUIREMENTS (Continued) 2.
Verifying within 31 days after removal that a laboratory analysis of a re3resentative carbon sample obtained in accordance with legulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. July 1976, and tested in accordance with the methodology provided by ASTM D3803-1989, at a temperature of 30 C and a relative humidity of 95%*. meets the acceptance criteria of < 5.0% penetration of methyl iodide 3.
Verifying a system flow rate of 2000 cfm 10% during system operation when testec in accordance with ANSI N510-1975.
c.
After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1.
July 1976, and tested in accordance with the, methodology provided by ASTM D3803-1989, at a temperature of 30 C and a relative I
humidity of 95%* meets the acceptance criteria of < 5.0%
l penetration of methyl iodide.
j d.
At least once per 18 months by:
1.
Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is 5 5.25 inches Water Gauge while operating the filter train at a flow rate of 2000 cfm 10%.
2.
Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.
l 3.
Verifying that on a chlorine detector test signal, the control building ventilation system automatically isolates and the control room emergency filtration system cannot be started by a smoke detector or control room ventilation system high radiation test signal.
4.
Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.
- Laboratory testing within the temperature and humidity tolerances
~
provided in Table 1 of ASTM D3803-1989 constitutes compliance with Surveillance Requirements 4.7.2.b.2 and 4.7.2.c.
BRUNSWICK - UNIT 2 3/4 7-4 Amendment No.
PLANT SYSTEMS BASES 3/4.7 2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)
Surveillance Requirements The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a subsystem in the standby mode starts on demand and continues to operate.
Standby systems are checked periodically to ensure that the autcmatic start function is consistent with the assumptions in the Control Room Habitability Analyses (References 4 and 6).
Since the environmental conditions on this i
system are not severe, monthly demonstration of the capability of the system
-to operate by SR 4.7.2.a is considered adequate.
The > 15 minute run time is considered adequate for operation of systems without heaters (Reference 16).
l SR 4.7.2.b verifies the capability of the filtration system at least once every 18 months, or 1) following any structural maintenance on the filtration unit HEPA filter or charcoal adsorbers or 2) following painting, fire. 'or chemical release in any ventilation zone communicating with the system.
Field Guide 1.52. performed in accordance with appticable sections of RegulatoryThe use of Reg testing is Revision 1, and ANSI N510-1975.
Revision 1 and ANSI N510-1975 is consistent with the guidance provided in Generic Letter 83-13 (Reference 7).
Charcoal samples for laboratory testing are obtained per the applicable sections of Regulatory Guide 1.52. Revision 1.
The laboratory testing 1s performed in accordance with the methodology in ASTM D3803-1989 (Reference 17). ASTM D3803-1989 is a more current testing standard 4
which was developed after the Generic Letter 83-13.
It contains criteria for i
use with charcoal beds with no humidity control, this is consistent with the design of the CREV system.
The acceptance criteria used for the laboratory test is < 5.0% penetration of methyl iodide (Reference 18). This corresponds to a 90% filtration efficiency which is the filtration efficiency assumed in the bounding calculations of control room doses. As such the acceptance criteria of < 5.0% penetration of methyl iodide ensures that General Design 3
Criterion 19 dose limits for control room operators are not exceeded.
SR 4.7.2.c verifies adequacy of the charcoal filtration system following every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.
The time of o)eration is based on the recommendations of Regulatory Guide 1.52, Revision 1 (leference 8), and early nuclear plant filter testing (Reference 10).
SR 4.7.2.d demonstrates functional capability of the system by verifying
- 1) pressure drop across the HEPA and charcoal filtration units, 2) automatic emergency system initiation upon receipt of a smoke detector or high radiation test signal. 3) the override function of the chlorine protection function, and
- 4) ability of the system to maintain a positive pressure relative to the outside atmosphere during system operation.
The maximum pressure drop of
< 5.25 inches water gauge is based on a CREVS pressure drop analysis TReference 9) and fan capability.
This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water gauge margin for filter loading.
The positive pressure test is performed to ensure that the control room 1s maintained positive to any potentially contaminated external atmosphere, including the outside atmosphere and adjacent building atmosphere (s).
Testing of the chlorine override function ensures operability of the chlorine protection mode of the CREVS by demonstrating the capability of the system to prevent the emergency filtration units from initiating during i
a chlorine event.
SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control Room Habitability Analy~ses (References 4 and 6) following partial or complete replacement of either filtration component. The testing is performed in accordance with the applicable sections of ANSI N510-1975 (Reference 14).
l BRUNSWICK - UNIT 2 B 3/4 7-lh Amendment No.
PLANT SYSTEMS i
BASES 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)
References l
1.
10 CFR 50. Appendix A. General Design Criterion 19. Control Room.
2.
Regulatory Guide 1.95. Revision 1. Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.
3.
Updated FSAR. Brunswick Steam Electric Plant, Units 1 & 2.
I 4.
NUS-3697, Revision 2. February 1983. Control Room Habitability Analysis.
5.
NLU-83-673 TMI Action Item III.D 3.4 - Control Room Habitability. NRC Safety Eva uation dated October 18, 1983.
6.
NUS-4758. Control Room Radiological Reanalysis. August, 1985.
I 7.
Gerieric Letter 83-13. Clarification of Surveillance Re uirements for i
HEPA Filters and Charcoal Adsorber Units in Standard T chnical I
Specifications of ESF Cleanup Systems. March 2.1983.
)
8.
Regylatory Guide 1.52. Revision 1. July 1976.
9.
CP&L Calculation G0077A-01. Control Room Emergency Filter System Differential Pressure Analysis.
10.
Original FSAR. BSEP. Units 1 and 2. Appendix K.
11.
IEEE 279-1971. IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.
12.
DBD-37. Design Basis Document for Control Building Heating. Ventilation, and Air Conditioning System.
13.
NRC-89-103. NRC Safety Evaluation for Control Room Habitability.
February 16. 1989.
14.
ANSI N510-1975. Testing of Nuclear Air Cleaning Systems.
15.
ANSI N509-1976. Nuclear Power Plant Air Cleaning Units.
16.
NUREG-1433. Standard Technical Specifications. General Electric Plants.
BWR/4. Revision 0. September 28, 1992, 17.
ASTM D3803-1989 (Reapproved 1995). Standard Test Method for Nuclear-I Grade Activated Carbon.
18.
ESR 97-00078 Revision 1. Charcoal Testing for CBEAF per ASTM D3803-1989.
1 l
l BRUNSWICK - UNIT 2 B 3/4 7-11 Amendment No.