ML20248C005

Engineering Study on Control Room Integrity Test Requirement

ML20248C005
Person / Time
Site:	Braidwood
Issue date:	05/31/1989
From:	SARGENT & LUNDY, INC.
To:
Shared Package
ML20248B999	List: ML20248B992 ML20248C005
References
NUDOCS 8906090232
Download: ML20248C005 (85)

Text

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Commonwea'lth Edison Company May 1989 Braidwood Station Units 1&2

-Project No. 8087-83

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ENGINEERING STUDY 0, N CONTROL ROOM INTEGRITY TEST REQUIREMENT O

Prepared By Sargent & Lundy Page 1

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 1)-...

Index L

l Page l-I Introduction.....................................................

4 II Background.......................................................

5 III Control Room Envelope and System Description.....................

8 IV Control Room Envelope Infiltration Paths.........................

10 V

. Integrity Test Evaluation........................................

13 VI Control Room Envelope Degradation Over Time......................

17 VII Conclusion.......................................................

24 References.................................

..................... 27 Attachments......................................................

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Attachments

1) NRC letter from S. A. Varga to D. L. Farrar (CECO) dated 3-4-87, Docket No. 50-456/50-457.

2)

Letter from A. D. Miosi (CECO) to H. R. Denton (NRC) dated 6-3-86; Docket No. 50-456/457.

3)- Letter from S. C. Hunsader (CECO) to H. R. Denton (NRC) dated 4-2-87, Docket No. 50-456/457.

4)

Letter from S. C. Hunsader (CECO) to T. E. Murley (NRC) dated 5 87, Docket No. 50-456/457.

5)

Letter from.S. C. Hunsader (CECO) to H. R. Denton (NRC) dated 12 86, Docket No. 50-456/457.

6) Figure of Control Room Envelope Boundary

7) Control Room Boundary Door Listing

8) Braidwood Station Operating Procedure Bw0P VC-14 Rev. 51

9) Simplified Control Room HVAC System Diagram for Normal Operation O

10) Braidwood Station Operating Procedure Bw0P VC-16. Rev. 0

11) Door Leakage Curve from Atomics International Report NAA-SR-7234

12) Braidwood Station Maintenance Procedure BwMP 3300-047

13) Braidwood Station Operating Procedure Bw0P VC-7, Rev. 5

14) Control Room Boundary, Elev. 451'-0" Leakage Curve

15) Control Room Boundary, Upper Cable Spreading Room Leakage Curve O

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 1.

Introduction As part of the Nuclear Regulatory Commission's (NRC's) acceptance provision for the deletion of the chlorine detectors in the Control Room HVAC (VC) system outside air intakes (Ref. 1), a requirement to demonstrate control room boundary integrity test on an eighteen (18) month basis was to be included. To fulfill this requirement a surveillance test whose purpose is to show that the control room envelope integrity is maintained such that the total infiltration does not negate the toxic (chlorine) gas analysis while the VC system is operating in the isolation (100% recirculation, isolated from all makeup sources) mode was agreed to.

In order to perform this test, the running train of VC will be required to be in the isolated mode of operation for approximately 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />. The running VC train in the isolated condition will be inoperable. The redundant train will be operable and capable of being manually aligned from the control room to emergency operation.

It is not prudent to operate in this configuration (i.e., one train inoperable) for the performance of the inleakage test. The purpose of this report is to evaluate sources of control room infiltration, and provide a technical argument, backed by engineering analysis, based upon what was learned from the initial integrity test, coupled with the processes that exist, sufficient controls are in-place to demonstrate control room envelope integrity on a periodic basis. An evaluation of the initial control room integrity test (Ref. 2) will also be performed.

In addition, any in-place instrumentation and/or station procedures that can monitor, identify, cr limit control room infiltration will also be examined.

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II.

Background

Toxic Gas Analysis Discussion The licensing of the Braidwood Station required a survey of industries and transportation routes in the site vicinity, which may use, store and/or transport chlorine. The information was then used to evaluate the control room habitability at the Braidwood l<

Station. One such survey, conducted in 1983, revealed that, on the basis of weight and shipping frequencies provided in Regulatory l

Guide 1.78 for different modes of transportation, cnlorine was l

transported above the frequency requiring analysis only on the Norfolk & Western Railroad near the site. However, no further analysis was conducted to determine if uninhabitable conditions in the control room could be caused by accidents involving rail tank cars containing chlorine.

Instead, to expedite the licensing of O

the plant, redundant ch,or4ee monitors were provided on each outside air intake of the control room.

As a result of operational and maintenance problems experienced with the chlorine monitors, the necessity of keeping the monitors This evaluation operational at Braidwood was re-evaluated in 1986.

concluded that the probability of a chlorine accident was below the requirements set forth in Regulatory Guide 1.70 and Standard Review Plan 2.2.3 (Attachment 2) and therefore it was acceptable to delete the monitors. This proposal was accepted by the NRC on March 4 1987 (Ref. 1 and Attachment 1). The monitors were deleted and the j.

required manual isolation switches (Attachment 3) added under DC-l VC-42. A provision of the NRC's acceptance included:

A revised technical specification to perform on an 18 month basis, a surveillance to demonstrate that the control room can be isolated (Attachment 4)

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Braidwood Station would be notified in the event of a chlorine accident by representatives from Will County, Illinois (Attachment 5)

Perform a non-technical specification demonstration test to verify that the total control room boundary infiltration rate (with the VC system operating in a 100% recirculation mode) does not negate the toxic (chlorine) gas analysis.

The toxic gas analysis, using an interpolation method provided in i

Regulatory Guide 1.78, showed that a control room habitability evaluation would not be required when the air. exchange rate is 0.39 per hour. This an exchange rate is based on a toxicity limit of 45 3

mg/m resulting from a release of 83 tons of chlorine in a l

railroad car located between four and five miles away from the control room (The nearest distance from the control room to the l O aorroik + westera railroea is 4.s i'es)- ror the ereiewood l

control room, a marimum inleakage of 2633 cfm is required to achieve an air exchange rate of 0.39 per hour (Attachment 3).

Standard Review Plan Discussion Standard Review Plan (SRP) 6.4 on habitability systems states that the calculated infiltration is a summation of the following components:

One half of the CRE gross leakage when pressurized to 1/8-inch H 0.

2 The estimated contribution of opening and closing of doors associated with such activities as the required emergency procedures external to the CRE.

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The enhancement of the infiltration occurring at the dampers upstream of the recirculation fans.

It will be shown herein that the calculated infiltration with respect to the SRP is less than the maximum allowable infiltration determined by the toxic gas analysis.

It is the intent of this report to demonstrate that the calculated infiltration is not only less than the maximum allowable determined by the toxic gas analysis, but is also in compliance with the SRP.

The calculated or measured gross leakage is used to determine the infiltration rate that will be applied in the evaluation of the radiological consequences of postulated accidents. This rate is I

determined as follows:

SRP: "The leakage from the control room when pressurized to 1/8 inch water gauge is calculated on the basis of the gross leakage data. One half of this value is used to represent the base infiltration rate.

l Discussion:

The Control Room envelope is pressurized in two segments, the 451' elevation and the upper cable spreading room. Based upon Attachments 14 and 15 the total leakage when pressurized to 1/8 inch H O is 2

l 4387 CFM (3275 CFM + 1112 CFM). One half that number or 2194 CFM represents the base infiltration rate.

l SRP:

"The base infiltration rate is augmented by adding to it the estimated contribution of opening and closing of doors associated with such activities as the required emergency procedures external to the control room. Normally, 10 CFM is used for this additional contribution.'

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1 Discussion:

10 CFM is used.

l SRP: "An additional factor that is used to modify the base i

infiltration rate is the enhancement of the infiltration occurring at the dampers or valves upstream of the

-j recirculation fans."

Discussion:

The dampers upstream of the recirculation fans which

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are closed during abnormal operation are of =0 CFM of l

infiltration.

The total of the above three components, 2204 CFM is the calculated j

infiltration rate determined in accordance with the SRP 6.4 analysis method. This value is less than the 2633 CFM allowable determined in the toxic gas study.

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III.

Control Room Envelope and System Description l

The Control Room Envelope (CRE) is located in the Auxiliary Building on elevations 451'-0" and 463'-5".

The 451'-0" elevation contains the main control room, auxiliary electrical equipment rooms, HVAC equipment rooms, toilets, kitchen, storage rooms and instrument maintenance shop. The 463'-5" elevation contains the upper cable spreading l

See Attachment 6 for plan view of CRE boundary. A tabular list rooms.

of CRE boundary doors is included in Attachment 7.

Note that no doors exist between the Upper Cable Spreading Rooms and the Turbine Building.

The CRE is maintained at a nominal.125 in. H 0. positive pressure with 2

respect to surrounding areas during all normal and accident modes of plant operation. This pressurization prevents the introduction of i

l airborne contaminants through doors, cracks, etc. to the control room atmosphere. CRE pressure is monitored by the use of differential O

pressure transmitters which sense pressure relative to adjacent areas j

l as follows:

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 V

L O Areas uithin CRE Adjacent Area Indication

• Control Room Auxiliary Building MCP Control Room Turbine Building MCP Control Room Lower Cable Spreading Room LCP Control Room Computer Room - Unit 1 LCP Control Room Computer Room - Unit 2 LCP HVAC Equipment Room -

Miscellaneous Electric LCP A Train Equipment Division 11 HVAC Equipment Room -

Miscellaneous Electric LCP j

B Train Equipment Room Division 21 l

Upper Cable Spreading Room Turbine Building LCP

• MCP = Main Control Pavel LCP = Local Control Panel l

If low differential pressure exists in any of these areas after a 30 second time delay (to avoid nuisance alarms), annunciation occurs on j

both the LCP and MCP. Station Operating procedure Bw0P VC-14 (Attachment 8) is then implemented to identify the cause for the alarm.

The control room HVAC system is composed of redundant HVAC equipment

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trains with common supply and exhaust ductwork and duct accessories.

l Supply air to the control room is a combination of recirculated air from within the control room envelope mixed with makeup air.

In the i

Normal Mode make-up air is induced-through the minimum outside air

intake, in the Accident Mode (LOCA, ESF, etc..) make-up air is induced I

through the the turbine building air intake and is filtered through the j

emergency make-up air filter units. Normal operation of the control room HVAC system is shown schematically in Attachment 9.

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&'

Project No. 8087-83 Upon chlorine spill notification, the control room HVAC system will be transferred to a 100% recirculation mode (Abnormal Mode as described in UFSAR Section 3.11.1) in accordance Station Operating procedure Bw0P VC-16 (Attachment 10). During this mode, all outside air intakes are isolated and CRE pressurization is neutralized. The CRE is expected to be at approximately atmospheric pressure during this time. Since the adjacent areas are either at atmospheric pressure or at a reduced pressure differential with respect to the CRE during those mode, little CRE infiltration is expected to occur through closed doors and cracks. The following sections address the sources of infiltration and their respective nominal infiltration rates.

IV.

Control Room Envelope Infiltration Paths Infiltration and exfiltration occurs as the result of a differential pressure existing across some' flow path. This can be expressed mathematically by the following generalized equation:

Q = K*A*DP" where:

Q = Air flow rate K = Crack dependent coefficient A = Cross sectional area of crack DP = Pressure differential across the crack n = Crack dependent exponent As discussed in Section III, the CRE is normally pressurized.

Pressurization is achieved by the VC system which supplies more outside air to the CRE than it returns. This excess air is allowed for exfiltration and is equivalent to the flow rate in the above equation.

Since the VC system air flow rate is relatively constant, and verified by 18 month Technical Specification Surveillance testing, Page 10

Commonwealth. Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 (3

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any increase in leakage area will result in a reduction of differential With the CRE constantly monitored for pressurization, any pressure.

boundary degradation can be readily identified.

In addition, CRE pressurization is also verified by 18 month Technical Specification Surveillance test.

Potential CRE exfiltration paths are personnel access doors, HVAC ductwork and dampers, and small cracks which may form in masonry walls and floors.

Since the CRE is not pressurized during the 100% recirculation mode, the same exfiltration paths which exist during normal operation become sources of infiltration if the CRE is at a negative pressure with respect to the surrounding areas. A brief description of these potential infiltration paths follows:

- Personnel Access Doors Most control room boundary doors (See Attachment 7 for list of CRE boundary doors) are access controlled which means that the doors are always kept locked and passage limited only to authorized personnel. The doors are fully gasketed around their perimeter and Double doors provided with floor sweeps to minimize air leakage.

have overlapping seals installed to provide leak protection between door panels. While these doors are sealed, infiltration can occur at the floor sweeps and where the door panel meets the frame. 1 provides leakage characteristics for fully gasketed hollow metal doors.

1

- Ductwork Positive pressure ductwork from the following non-safety-related HVAC systems located within the CRE represent another potential I

source of infiltration:

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 0

Radwaste HVAC System (VW)

Control Room Offices HVAC System (VV)

Laboratory HVAC System (VL)

The VW system ductwork (approx. 10 ft in total length) is of welded longitudinal joint construction and contains three gasketed companion angle transverse joints. This type of duct construction limits the leakage path to only the companion angle joints.

A portion of the V'I system ductwork supplying and returning air to the Unit 1 and 2 Computer Rooms is physically isolated from the computer rooms during the control room 100% recirculation mode by actuation of the control room manual isolation switches which closes isolation dampers OVV62Y, thru OVV69Y. The ductwork-leakage downstream of the isolation dampers is dependent on damper leakage, and thus is not of concern. Potential damper leakage is discussed later. A portion of this same VV system ductwork, also within the CRE, exists upstream of these isolation dampers. This ductwork (approx. 75 ft. in total length) will be exposed to a positive pressure upon damper closure and may exhibit some leakage. The ductwork is fabricated using sealed Pittsburgh Lock Seam construction and sealed S-cleat transverse joints.

The VL system ductwork (approx. 180 ft. in total length) is fabricated using sealed Pittsburgh Lock Seam construction and gasketed companion angle transverse joints. This type of construction is typically exhibits low leakage when properly installed. However, a small increase in leakage may occur over tiae as the sealant ages.

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- Dampers The Control Room HVAC System minimum outside air intake isolation dampers, smoke purge isolation dampers and VV system isolation dampers represent another infiltration path. The Control. room minimum outside air intake dampers and smoke purge dampers were built and tested to ANSI N509/510 bubble-tight construction and thus will exhibit near zero leakage when properly maintained. The re-maining dampers are of low leakage, heavy duty construction and thus may exhibit some leakage.

.- Cracks The final potential paths of concern are the small cracks typically found in concrete floors, masonry walls, around penetrations and in structural joints. These path types have a tendency to grow in both size and number as the building ages. However, since the CRE is continuously monitored for pressurization; crack enlargement resulting in of any significant exfiltration increase can be identified.

V.

Integrity Test Evaluation In compliance with the NRC's acceptance provision, Supplemental Safety Evaluation Report No. 3 dated May 1987, the first control room integrity test (Bw0D VC-90) was performed in January (Train-A) and February (Train-B) of 1988. The purpose of test Bw0D VC-90 was to determine the total infiltration into the CRE from boundary doors, HVAC ductwork, and isolation damper leakage while the Control Room HVAC System is operating in the 100% recirculation mode.

An engineering evaluation of the VC-90 test for Train-A and Train-B was performed and the results are summarized below.

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 n-Ne Leakage Component.

Measured Leakage (CFM)

Train-A Train-B Ductwork 225 225 Dampers 525 0

Structure (Doors) 9 39 Total 759 264 Total with +10% measurement tolerance allowance 835 290 A test measurement accuracy evaluation was included in Reference 3 for O'

ditctwork leakages. This evaluation was based on the methodology in Reference 4, and-included tolerances for all measured parameters. The resultant measurement tolerance was determined to be 3% of the measured airflow rate. The measurement errors associated with the flow rate error are the barometric pressure error, the velocity pressure error, the pitot traverse error, the dry bulb temperature error, and the wet bulb temperature error (The duct size was not measured as part of this test. Nominal duct sizes were used).

Since the same equipment and the same personnel were used for the test, any inherent equipment errors or errors by personnel would tend to result in a flow that is in error in i.t.a same direction for each set of measurements. That is, the flow estimate would be either high or low for both sets of measurements.

For conservatism a 10% measureme-tolerance allowance will be applied to the overall measured leakages.

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83

,O Train-A The resultant infiltration rate is 835 CFM which is approximately 32% of the toxic gas allowable and approximately 38% of the SRP 6.4 analysis. Of the total leakage measured approximately 63% was due to the smoke purge damper OVC018Y. The remaining leakage was through boundary doors and ductwork.

Ductwork leakages were calculated by taking the differential in airflows in ducts entering and leaving the CRE. Test data for VC Train-A indicated that negative leakage (exfiltration from CRE into ductwork) existed on both the VL and VW system ductwork (Ref. 2).

This data represents a physical impossibility since the ductwork is at postive pressure with respect to the CRE. Thus, Train-A duct leakage yielded inconclusive results.

It should be noted that the VL and VW system ductwork was at a O

notably higher positive pressure during Train-B testing. While the VC-90 test did not address the operational status of the Auxiliary Building HVAC (VA) System, the higher duct pressures are most likely the result of VA system operational line-up which exerts a back pressure on both the VL and VW systems where they discharge to the l

VA Exhaust Tunnel. Therefore, the ductwork leakage experienced during VC Train-B testing represents a worst case condition. Since operation of the VL and VW systems is not impacted by VC system operation (assuming relatively constant room pressures), the Train-B data was used in determining Train-A infiltration.

l Train-B The resultant infiltration rate is 290 CFM which is approximately 11% of the toxic gas allowable and approximately 13% of the SRP 6.4 analysis. The Train-B leakage was primarily caused by ductwork leakage and not by damper OVC018Y, since this damper is isolated from the system during Train-B operation. No damper leakages were Page 15 l

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present during this portion of the test. The remaining leakage was through boundary doors.

I General Damper leakages were determined by using either' pitot tube traverses with an inclined manometer or rotating anemometer traverses. Test data indicates that either no or extremely small damper leakages were present during Train-A and B testing. Smoke purge damper OVC018Y (Train-A Test) was the only damper to exhibit any measurable leakage.

It should be noted that overall CRE infiltration in the VC-90 test, was lower than the limits set by the toxic gas analysis End the SRP review even with the leaking damper.

Door leakages were calculated using data from the permanently installed pressure differential indicators and door leakage data presented in Atomics International NAA-SR-7234 report (Attachment O

11). A review of the pressure differential indicator readings during Train-A testing shows that the CRE was typically at a slightly positive or equal in pressure with respect to its adjacent Only instrument OPDI-VC37D (HVAC Equip. Room Train A to areas.

Misc. Elev. Equip. Room) indicated an approximate 1/8 in, negative pressure differential. This resulted in an estimated door infiltration of 9 cfm. Train-B testing indicated that the following areas containing boundary doors were at a negative pressure resulting in a total of 39 cfm door infiltration.

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-Commonwealth. Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 Instrument Area Pressure Infiltration (in. H O)

(CFM) 2 OPDI-VC037A Control Room to

.03 27.0 Turbine Building i

OPDI-VC0370 HVAC Equip. Room Train A

.03 4.0 Mis. Elec. Equip. Room

- Div. 11 OPDI-VC0380 HVAC Equip. Room Train 8 Misc. Elec. Equip. Room

.10 8.0

- Div. 21 Total Door Infiltration 39 cfm VI.

Control Room Envelope Degradation Over Time A potential concern with the elimination of the CRE inleakage surveillance test is the possibility of unidentified degradation of the control room pressure boundary over the life of the plant. This degradation if not identified could lead to infiltration values in excess of the allowable inleakage of 2633 cfm. The causes for this degradation are opening and closing of boundary doors, potential ductwork sealant degradation, and normal wear, aging, and abrasion of damper blade seals due to stroking. The following sections will explain the most likely method of degradation for each infiltration path and describe existing procedures to identify them.

Boundary Leakage (including doors)

As indicated in Section IV, all boundary doors are fully gasketed and have floor seals installed to minimize exfiltration during normal plant operation. These seals and gaskets can be expected to show gradual signs of wear over time, but catastrophic failure of same is not anticipated.

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.q v-As part of a preventative maintenance program, Braidwood Station performs a visual inspection of all plant fire and security doors on a semi-annual basis. This inspection is executed under maintenance procedure BwMP 3300-047 (Attachment 12) and addresses every CRE boundary door except door D-728 which is only a ventilation barrier. Any damage to door sealing mechankms is identified and subsequently repaired.

In addition, upon actuation of a CRE low differential pressure alarm, station l

procedure Bw0P VC-14 (Attachment 8) is implemented to identify the cause for CRE pressurization loss.

In this procedure, CRE boundary doors are checked for proper closure. Finally, since the VC system air flow is verified by technical specification surveillance testing, CRE differential pressures are not likely to vary from their present values for both VC system normal and abnormal operating modes. The CRE is primarily surrounded by atmospheric condition (i.e., Turbine Building) and other safety-O reieted systems (i.e., Aux 4,4ery 8u41 din 9 svaC and Misceiieneous Electrical Equipment Room Ventilation System) so it can be assumed that adjacent room pressures are also relatively constant. Thus, CRE boundary door differential pressures observed during the VC-90 test are representative of future conditions.

Based on the above discussion, it is not expected that CRE infiltration resulting from boundary doors will increase appreciably with time.

Ductwork Leakage Per Section IV, positive pressure ductwork from the VW, VV and VL HVAC systems penetrate the Control Room boundary.

As previously noted the only leakage path for the VW ductwork is in the gasketed transverse joints. Since the gasket material is Page 18

Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 O

fully qualified for the environment in which it serves, gasket degradation is not a probable occurrence.

In addition, the gasket material is fully compressed between the companion angles, and thus will remain in place over the life of the plant.

Since the ductwork is seismically qualified, failure of the transverse connection is not assumed to occur, thus the transverse joint should not experience any appreciable change in leakage above that observed during the VC-90 test.

A portion of the VV system is physically isolated from the CRE during Control Room Isolation signal actuation by isolation dampers. Since VV system leakage is directly dependent on the leakage of its isolation dampers, ductwork leakage will not be directly result in inleakage to the CRE.

Leakage through the isolation dampers is discussed in a subsequent section. As previously discussed a portion of the VV system ductwork exists upstream of the isolation dampers. Since the ductwork is seismically qualified the leakage path of concern is through sealed seams and joints. The life span of permanent ductwork sealant has been an item of concern, therefore, postulated leakage was calculated assuming unsealed ductwork (Ref. 3).

Based on this calculation, an approximate 930 cfm leakage through seams and joints was estimated. This represents a very conservative number since the duct sealant will not degrade to the point of non-existence.

The VL system is fabricated using sealed Pittsburgh lock seam construction and gasketed companion angle transverse joints.

Since the life span of permanent ductwork sealant has been a item of concern, postulated ductwork leakage was calculated assuming unsealed Pittsburgh seams (Ref. 3). Data for unsealed Pittsburg seam leakage is derived from References 5, 6 and 7.

Based on this calculation, the VL ductwork is estimated to leak approximately 170 cfm through the seams. This represents a O.

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i Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 mD conservative value, since sealant, when applied to the Pittsburgh seam prior to lock forming is not likely to degrade to the point of non-existence.

Damper Leakage The Control Room HVAC system minimum outside air intake isolation dampers, Turbine Building air intake isolation dampers and the smoke purge isolation dampers all provide potential leakage paths. Since the dampers are exposed to pressure differential due to VC System operation, they represent the greatest single infiltration path of the entire CRE. The dampers were fabricated.

to.either bubble-tight construction or low leakage construction.

Bubble-Tight Dampers-The following outside air intake and smoke purge dampers are designed, fabricated and tested to ANSI N509/510 bubble-tight damper construction requirements:

Outside Air Intake Isolation Dampers:

OVC281Y OVC312Y OVC16Y OVC313Y Smoke Purge Campers:

OVC18Y OVC02Y OVC20Y OVC04Y O

(

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Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 p.d Blade seals for these dampers have been environmentally qualified for a 40 year life span, thus seal deterioration due to temperature, radiation and humidity is not of concern. A parameter that is of concern is wear since the outside air intake isolation dampers are routinely cycled during monthly technical specification surveillance testing of the Emergency Make-Up Air Filter Unit. Per station procedure Bw0P VC-7 (Attachment 13) the smoke purge dampers may only be cycled to remove smoke from the Control Room after a fire. This procedure also requires that the dampers be leak tested as soon as practical following operation. Since an unstroked damper is not expected to exhibit leakage over time with qualified blade seals, an 18 month periodic leakage test is not likely to be of benefit. This was shown in the VC-90 test when the dampers exhibited no leakage (except for OVC18Y) after approximately 1 1/2 years of operation. Damper OVC18Y did exhibit approximately 525 cfm O

leakage during the Train-A portion of the VC-90 test.

Dampers OVC312Y and OVC313Y isolate the Emergency Make-Up Air Filter Units from the outside air intake. The Emergency Make-Up Air Filter Units normally draw air from the Turbine Building intake, so these dampers are not routinely cycled during the monthly Technical Specification surveillance testing. Per a similar discussion, these dampers are not likely to experience an increase in leakage over time.

As demonstrated by the VC-90 test, the Control Room bubble-tight dampers have proven their leak tightness after approximately 1 1/2 years in service. Thus, leak testing the dampers on a periodic basis would provide no additional benefit.

Low Leakage Dampers - The following isolation dampers are of low leakage construction:

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v Turbine Building Air Intake Isolation Dampers OVC25Y OVC09Y Control Room Offices HVAC System (VV)

OVV62Y OVV64Y OVV66Y OVV68Y OVV63Y OVV65Y OVV67Y OVV69Y Dampers OVC25Y and OVC09Y are the Turbine Bldg. Air Intake isolation dampers for the Emergency Make-up Filter Air Units.

Since the Turbine Bldg intake is the normally used emergency intake, the dampers are routinely cycled during the monthly Technical Specification surveillance testing for the filter units.

Per the VC-90 test these dampers exhibited no signs of leakage ofter approximately 1 1/2 years of service. This O

represents e sood indication es to the wear characteristics of these dampers and that 18 month testing is not likely to provide any benefit.

The dampers in the VV system are only cycled by actuating the Control Room isolation switch during the 18 month Technical Specification Surveillance of the Control Room isolation capability, during the inleakage testing or due to operational requirements during an event. Since these dampers are normally not actuated, little or no wear expected to occur on the blade seals.

Per the VC-90 test, these dampers exhibited no measurable leakage after at least two years of service. Thus, a periodic surveillance test is not expected to show any leakage increase with time. From a conservative standpoint, low leakage dampers will typically exhibit some leakage while under pressure. Using previous damper leakage test data performed on other Braidwood dampers of identical construction, an estimated 193 cfm will be postulated to occur from the VV dampers.

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Structural Leakage The remaining source of potential Control room infiltration l

occurs from cracks within the structural floors or masonry walls of the CRE.

This type of leakage tends to increase with the age of the plant.

Per analysis performed in Ref. 3, the CRE on Elev.

451' could degrade by approximately 1 1/2 times from'its original condition prior to the CRE differential low pressure alarm actuates (Figure 1). The projected leakage curve that initiates the low differential pressure alarm is based on a relatively

. constant make-up airflow flow. This is a reasonable methodology since VC system makeup and total system air flows are verified by 18 month Technical Specification Surveillance.

Per design, the CRE will be at approximate atmospheric pressure during the 100%

recirculation mode and thus approximately equal in pressure to its surrounding areas. This was also evidenced in the VC-90 test data.

Since very small average pressure differentials are expected to exist while in this mode, little infiltration through these paths (including doors) is expected. For conservatism, an assumption that the 451' Elev. of the CRE will be at a.01 in.

H O pressure which would correspond to an estimated infiltration 2

rate of 1000 cfm shown in Attachment 14 was used.

The upper cable spreading room (UCSR) portion was found to be able to experience substantial degradation prior to initiating a low differential pressure alarm.

It should be noted that the UCSR has no return air provision, is not normally occupied, and like the 451' Elev. is expected to experience small differential pressures. Therefore the UCSR infiltration will not directly impact CRE habitability.

O Page 23

Commonwealth. Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 pd VII.

Conclusion Based on the previous discussions, the CRE does and will continued to experience some small infiltration flow while the VC system is operated in the 100% recirculation mode. The conservative corrected and evaluated data taken during the VC-90 test is summarized as follows:

Leakage Component Train-A (cfm)

Train-B (cfm)

Ductwork Leakage 225 225 Damper Leakage 525 0

Door Infiltrations 9

39 Total 759 264 Total with 10% margin 835 290

% Toxic Gas Analysis 32 11 (2633 CFM allowable)

% SRP Inleakage Estimate 38 13 (2204 CFM)

From a conservative standpoint, estimated worst case infiltration rates were calculated for dampers, ductwork, and physical boundary. The duct leakage is based on leakage from unsealed Pittsburgh lock formed duct construction.

O Page 24

Commonwealth Edison Company May 1989

Braidwood Station Units 1&2 Project No. 8087-83 v

Substantial increases in damper leakages are not expected to occur for the following reasons. The smoke purge dampers are of bubble tight construction and are not normally cycled. Per station procedure Bw0p VC-7 the dampers may only be cycled in the event of a fire in the Control Room or at the Shift Engineers discretion. The damper is also to be leak tested as soon as possible after cycling. Thus, leak inte-grity of these dampers will be established.

Low leakage damper leakage is based on test data for identically constructed dampers at Braidwood Station.

Boundary leakage is based on discussion in Section VI.

These combined postulated leakages are as follows:

Leakage Component Leakage (cfm)

Boundary Leakage (including doors) 1000 Ductwork Leakage 1100 Damper Leakage 193 Total 2293 This maximum possible leakage, assuming degradation of all components simultaneously, is 4% greater than the SRP 6.4 leakage approximation, and is 13% less than the maximum, toxic gas analysis flowrate.

Braidwood Station's existing operating and maintenance procedures to monitor, identify and rectify a loss of CRE pressurization combined with the previous discussions presented in this report on potential CRE infiltration paths and rates, indicates that adequate means exist to assure control room boundary integrity for future years.

In addition, compliance with SRP 6.4 has also been met. Based on this report, measures equivalent to or exceeding the benefit of performing an 18 month CRE inleakage test already exists at Braidwood. Thus, the Page 25

I Commonwealth Edison Company May 1989, Braidwood Station Units 1&2 Project No. 8087-83

' L/ '

inleakage test would be redundant in nature and since unit availability could be affected during the time of test execution, it is our belief that sufficient justification exists for the deletion of this test requirement.

O O

Page 26

Commonwealth Edison Company May 1989 Braidwood Station Units 1&2 Project No. 8087-83 O

References.

1.

Safety Evaluation Report, Supplement No. 3 2.

Braidwood Station Test Bw0D VC-90.

3.

Sargent & Lundy Calculation L-VC-422, Rev. 0 4.

AMCA 203 " Field Performance Measurements."

.5.

AISI/SMACNA, 1972, " Measurement and Analysis of Leakage Rates from Seams and Joints of Air Handling Systems."

6.-

ASHRAE/SMACNA/TIMA, 1985; " Investigation of Duct Leakage," ASHRAE Research Project No. 338.

O 7.

ASHRAE, 1988; " Duct Leakage: Me surement, Analysis, Prediction Models;"

ASHRAE Research Project No. 447.

l l

l l

l t-O Page 27

1,

{-

Commonwealth Edison' Company Mey 1989 Braidwood Station Units 1&2 Project No. 8087-83

O ATTACHMENTS O

O Page 28

/

+

UNITED sT ATEs

/g

.E i';

NUCLE AR REGULATORY COMMISSION 7

E WASHINGTON, O C. 20555

.t y y7; V J 1 bf]f y.

March 4, 1987 Docket hos. 50-450 and 50 457 Fr. Dennis L. Farrar Director of Nuclear Licensirip Commonwealth Edison Company Post Office Box 767 Chicago Illirois 60690

Dear Mr. Farrar:

Sufn1ECT: REMOVAL OF CONTROL ROOM chi.0P.INE MONITORS By letter dated June 3,1986, the licensee previded an analysis to demonstrate Based that the chlorine monitors for the control room intake are not required.

on the smell probability of a chlorine event, the licensee's commitment to maintain pror.pt notification communications with the county, the requirement to isolate the control room upon receipt of rotice of a toxic qas incident, and the requirement to demerstrate control room integrity on a routine basis, the staf' has deterinined that the removal of the chlorine monitors from the control room intakes is consistent with the cuidelines of SRP Section 6.3 g$

and is, therefore, acceptable, (u:

The staff's evaluation is contained in Enclosure 1.

This evaluation will be included in tbc r. ext SSER publication.

I ha r

r Pro.iect Directorat Division of PWR Lic ino-A

Enclosures:

As stated-cc: See next page

- -. (continued) 1 A.

k[ ' $'r. Dennis L. Farrar

.Braidwood Station commonwealth Edison Company Units I and 2 CC:

Ms. Lorraine Creek Mr. William Kortier-Atomic Power Distribution Route 1, Bnx'182l Westinghouse Electric Corporation Fanteno. Illinois 60950 Post Office Box 355 Pittsburgh, Pennsylvania.15230 Douglass Cassel, Esq.

109 N. Dearborn Street I

Joseph Gallo, Esq.

Chicago, Illinois 60602 Isham, Lincoln & Beale 1150 Connecticut Ave., N. W.

Elena Z. Kezelis, Esc.

Isham, Lincoln & Beale Suite 1100 Three First National Plaza Washington, D. C. 20036-Suite 5200 C.' Allen Bock, Esq.

Chicago, Illinois 60602-Post Offices Box 342 Urbana. Illinois 61801 Mr. Charles D. Jones, Director Illinois Emergency Services Thomas J. Gordon, Esq.

and Disaster Agency Waaler, Evans.& Gordon s110 East Adams Street-

~ Springfield, Illinois 62706 2503 S..Neil 61820 Champaign, Illinois

p. g George L. Edgar gd Ms. Bridget Little Rorem Newman & Holtzinger, P.C.

4 1615 L Street, N.W.

Appleseed Coordinator

'117 North Linden Street Washington, D.C.

20036 Essex, Illinois 60935 Michael Miller, Esq.

Isham, Lincoln & Beale Mr. Edward R. Crass One First National Plaza l

Nuclear Safeguards and 42nd Floor Licensino Division Sargent & Lundy Engineers

- Chicago, Illinois 60603 55 East Monroe Street Chicago, Illinois 60603 h

U. S. Nuclear Regulatory Commission i

Resident Inspectors Office RRfl, Box 79 Bracev111e, Illinois 60407 Regional Administrator, Region III U. S. Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, Illinois 60137 i

I O~

v l

=

J (continued)

STCTION 6.4 CONTROL POOM HAMTABILITY I

By letter dated June 3, 1986, the licensee provided an analysis to demonstrate that the chlorine monitors for the control room intake are not reouired. The analysis involved a resurvey of the offsite sources of chlorine within five iriles of the station, a calculation of the dispersion of the toxic gas and control room infiltration, and a probability evaluation of the rupture of a chlorine tank car on the Norfolk and Western Railroad.

The licensee's analysis stated that the probability of a chlorine tank car rupture within a 5 mile radius of the plant is significantly less than 10-6 7

The licensee's ar.alysis presumed that no toxic gas monitors existed and year.

that the station operator would not don the self-contained breathing apparatus until the chlorine odor was detected (3.5 ppm). The licensee calculated that V(~~TL the concentration existino in the control room 2 minutes after detection would be 13.3 ppm (toxicity is 15.0 ppm). The licensee stated that this ellows cdequate time for the operators to don self-contained breathing apparatus.

The NRC staff has independently reviewed the probability of a chlorine tank car rupture within the 5 mile radius and calculated the concentration in the control room assuming no toxic gas monitors and detection by odor at 3.5 ppm.

The staff's analysis of the probability of a chlorine tank car rupture within 5 miles of the Braidwood f acility was 1.3 X 10-6 / year, which was a factor of The approximately 30 oreater than the probability calculated by the licensee.

reason for this disparity was that the licensee calculated the probability of an accident based upon the frequency of chlorine tank car shipments per year and release per car mile (any type). The calculation should have been based upon the probability of a release per chlorine car mile.

_ _ _ _ _. (contin'ued)

'?-

The sta#f's analysis also showed that if the licensee was dependent upon the operators to detect the chlorine at a concentration of 5.5 ppm and then to initiate action tr protect themselves, than an insufficient period of time exists L

for the operators to don self-contained breathing apparatus before exceeding Consequently, with the absence of chlorine rnnitors, the toxicity 1,imits.

staff.balieves that if a release occurs within 5 miles of the Braidwoood facility, the control room should be placed into the isolation mode prior to This can be detection of chlorine odor by the control room operators.

accomplished bv early notification of a chlorine tank car accident.

By letter dated December 23, 1986, the licensee indicated that representatives from Will County, Illinois have agreed to provide notification The staff

~

to the Braidwood Station in the event of a chlorine accident.

believes that this notification process is an acceptable means of alerting l

Ir addition, the Braidwood Station so that the control room can be isolated.

the station will be recuired to: include with their control room technical specifications a surveillance requirement to demerstrate on an 18 month basis that the control room envelope can be isolated; and include a procedure to ity is

_ demonstrate, on an annual basis, that control room envelope integr maintained, i.e., infiltration into the control room envelope in the isolation mode does not negate the toxic gas analysis and thus, the capability to protect the operators.

O

s Attacraent 1 (continued)

O Althouch the probability of a chlorine release occurring is small, compensatory actions are in place which would be utilized to mitigate the corsequencer of such an event. Based on the small probability of a chlorine event, the licensee's commitment to maintain prompt notification communications with the county, the reoutrement to isolate the control room upon receipt of notice of a toxic cas incident, and the reovirement to demonstrate control room integrity on a routine basis, the staff has determined that the rereval of chlorine monitors from the Fraidwood Station control room intakes is consistent with the guidelines of SRP Section 6.4 and is, therefore, acceptable.

l O

O Chica::o Hhno s 60690 Commonwealth Edison Ow f est Nabces' P;ata C*oca70 mmo4

,,[

T Accress Rem to Post O'hte Box 767 Q

June 3, 1986 Mr. Harold R.

Denton, Director Office of Nuclear Reactor Regulation U.S.

Nuclear Regulatory Commission Washington, DC.

20555

Subject:

Braidwood Station Units 1 and 2 Habitability of Control Room Following Postulated Accidents Involving Shipments of Chlorine NRC Docket No. 50-456/457

Dear Mr. Denton:

We are submitting for your review and concurrence a Sargent and Lundy report entitled " Habitability of Control Room Following postulate ~d Kccidents of Chlorine Shipments in the Vicinity of f.BraidwoodStation"datedMay19, 1986.

Included in this report are results of a_survev nf ind"stries and transportation.Ioutes in the

site vicinity which may use, store, and/or transport chlorine, 7b Two analyses were performed to determine the control room habitability in the event of an accidental release of chlcrine.

The first analysis, a study of the dispersion of vapor released from a postulated accident, and the second analysis, a study of the probability that uninhabitable conditions could be caused by a postulated accident, both show that the chlorine detectors presently installed at Braidwood are not requ_ ired.

If this is found acceptable then we requert that chlorine detectors be removed from technical specification considerations.

If you have any questions regarding this matter please address them to this office.

One signed original and fifteen copies of this letter and attachment are provided for your review.

Very truly yours, 5

A.

D.

iosi Nuclear Licensing Administrator

()

/klj encl.

cc:

J.

Stevens 1742K

__- Continued

,m

()

ottacnment 1 May 19.

1986 Page 1 of 7 eacstacalsty of Control Room Followsng Postulated Acescents of Cn l or s rie Sh a ument s an the viesnaty of Bratewood Statzon Int eocuet t en Tne iscensang of tne Brasowooo St at son recuired a survey of ancustrses ano transportation routes an the site vicinsty, whnen raa y uso, store ano/or transoort chlorsne.

The information was tnen useo to evaluate the control room habitability at the Beasowooo Station.

One suen survey, concueted in 1983, revealeo snat. en tre easts of weight ano shipp1ng frequencies provsced an Aegulatory Guace 1.78 for asfferent modes of transportation, en".orane was transporceo aDove the frequency requiring anasysts or. t v en tne Norfolk & Western Ra11roac near the sate.

However, no furtner analysts was conducted to cetermine if uninhabitable concaster.s an t ne control room could be causec by scencents involving rasl tenu cars contaanang enlorsne.

Instead, to emoeotte tne 12 censing of the plant, redundant chlorsne cetectors l

were crovaced on each outside aar intake of the control room.

A r.e w survey.was conducted in Feocuary-May 1986 to supplement tne 2nformation obtainee from the 1983 survey.

The purpose of this stucy ss to provide a cont ro l room habitability analysts of the*

Brasewooo Statson control room due to accidental release of

/\\

enlorsne t raris cort ed on the Norfolk & West ern Railroad lane.

Tw.

k,)

castanct types of analyses were performed.

The first analysts consacereo the disperston of the vapor released from a postulateo aceteent to toe stat ton anc suesecuent infiltration into the control room.

Tnsa arialysts utsiszed the normal ase exchange rate of tne control room cased on the dessgn makeup asr and tne l

c or.t ro l room volume.

The secono consist ee of a cet erminat ion of sne crocaoslaty that uninhaottable condations in the control room coulo De causeo Dy accacents anvolving real tank cars cont a a nt r o en i or t r.e.

Tne oropaD111ty analysis consacered the statsstscal i

cata for rail tanu car accacents ano the meteorological l

oarameters, cased on wind direction and atmospheric stabslaty, tnat coulo cause the development of toute concentrations an the control room.

A cescrsption of the control room HVAC system as cresented an tne Brandwood Fsnel Sa.foty Analysis Report (FSAR)

Section 6.4 and as Drsefly presented here.

Tne followsng dtscussion descr* bas the Regulatory Guides whsch form the basis of the control room habitability evaluatton, the results of two surveys, and the analysis regaroing evaluat s on.of chlorane as a hazard to the Braidwood control room.

Based on the information collected to cate, it is concluded that no specsal protection provassons are recuired at the Braidwood Station.

Cont rol Aopm.dvoC Syst em Deseri et 1 on Two recundant HVAC ecu m pment trazns wath common supply and ennaust euct anc cuct accessories comorsse the control room HVAC system.

Air an the control room ss sucolsed from recirculated g--

age from w3tnin tne Control room enveloDe e r.d m1med w1th makeuo

l Continued (g)

Attachment i Fay 19, 1366 Page 2 of 7

air from the outstee air Intaxe or the turbane bus 1 ding str anta e.

wa tn t ures ne euticang antaxe, the makeuo aar as faltereo througn the emergency falter unats.

The outsade aar antake as useo for makeuo aar curing r.ormal plant operatzen.

Normal c oerat ac n of tne control room HVAC system as shown schematically in E=niott 1 (Reference it.

1963 Su, vev cf Cn i c4 t r.e.. Sn t oment Tae 75AR Sect s on 2.1. 2 oeserzoes sne location of the plant site anc the trarsoortation routes near the s a t e.

The FSAR 5eetson 2.2 oesertbes the nearoy ancustraal, transportation. anc malatary facilitses.

The a ncustraes tnat use, manufacture, or ste.re enlortne wathan sooronsmately 15 males of the Brasewoc.o Statsen were surveyee to cetermine frecuency of shapment anc mooe ef t ransoort at s on.

Tne survey revealeo (Sect s on 2. 2.1 ) that only two towse chemacals were snacoce regularly on Haghway 55:

cenatured alcohol and metnanol.

It was cetermar ec f rom the toxsesty levels of both enemacals that neather presented a hazard to t he Bra towood Station.

Acostaonally, the' survey revealed that toxac chemscals were transoc rteo cn the Norfolk & Western Ra11 road and the Atensson, icoena anc Sant a Fe Railroad.

An analysas was cone fre k

all tomse enemacals shaopec on both railrosos.

All chemacals emcept fer enlorine were elsmanated, on the basas of weaght, 4

shacoang frecuency, and the caffusaon mocel provaced an Aegulatory Guace 1.78 as nazarcs to control room haoitabt i s ty.

Str.ce the control room was eouipped with chlorine detectors an tne cor. trol ec.om -VAC system ant ake a t e cuct s, no further analysis for chlorane was conoueteo.

J 5f_borvev c4 Cniceane Sn oments 5

To sucolement the 1983 survey and to obta s n acoit tonal n r. format 1on on enlor a ne sn a oment s, a survey was conducteo curann Feorvary-May 1986 t o det erma ne a f chlort ne a s t ransoort ed on the ran1reso l a r.es and Magnway 55 passing wathan ftve males of the Brasowood sate.

For th15 survey, information was obtained from the Chlorane Inst a t ut e, a nattonal trade organizat son wath heacouarters an New York, whose members are mostly chlornne producers.

The Institute carraes out research, produces laterature, and an genwral, maantains the most up-to-date snformatton en enlorine an the Unst ed States.

Additionally, industries prevsously contactec in 1983 were contacted agaan to cetermane af these a ncust ries used, storec or t ransoorted chlorane on Haghway 55.

Accorcang to the Chlorine Institute (Reference 2),

only about 1% of chlorine shsooea in the U.S.

as t ransoort eo ey trucks.

Of thas 1 %,

only a small portion would be transoort eo ey tank trucks, anc these are mainly owned by water and wastewater treatment plants that operate these tank trucks for tnear own use.

The Chlorine Inst s t ut e further stated that there are no enlortne manufacturers in 111anons nor Massours, but

/'

enere are three in Wi sec r.s a r.

Two of the W sconsin procueers use (w

i Attachment ' 2 Continued i

,m J

l ist t acnteerit 1 May 19.

1986 Page 3 of 7 a '4 4 the enacrine tnev orocuee.

The tnarc crocucer as loc.stec ar.

vort sowaros, wnsen coes not snso enlorsne in the Northern lastnoas avea anc coes not use somn-tra11er tana trucks.for any of sts sn a oment s (Reference 3).

Several of the surround a rig muntcacarataes (watnse 10 males of the Plant) ano some of tne aarcer oooulet ton cent ers witn an a 30-male radius were surveyed regarotnc tnear use of entortne in water eno wastewater treatment osants.

suntost 2 lasts the towns / cities surveyec' anc tne information provnoeo Oy tne accrocetate personnel.

FSAR

'isole 2.1-10 and Figure 2.1-8 provice the population ano location of tne towns /catzes Insteo sn Exn*Dat 2.

Tne 2nformatton gatnered from andsv2 dual munnespalities a nd a cat es tnat tnere are no chlortne containers larger tnan one ton used for water or wastewater t.reatment an tne vacanity of the branowooo Statson.

Tne majority of the fac111ttes recetvec cnlorine in 150 pound cylancers.

Distributors of chlorine ceitver ootn i ton containers and 150 pound cylinders by truck to sne treatment olants.

In sod s t ion to munt ca nalit z es, four enayor otstraoutors of enlortne, three sn Illsnois and one an inciana, were surveyeo aoout enlorine truew snsoments.

All stated that entorane snaoments ustng trucks were an eather 150 pound cyltnoers or 1 t on cont a n ners.

Accorotng to one distributor (N

teieference

• s.

cnlortne as usually delivered from the producer unang real cars ano tnen cumped s nt o 1 ton cont ainers or 150 couno cylancers.

Accordsng to thss source, semi-traaler tanx trucus are not useo anywnere in the U. S.

for chlorine shaprnent.

Reparosng eniorane sn a oment s on the ra t Iroacs, appropriate cersonnel of tne 111:nois Central Gulf Ra:Iroad (ICG), the Atensson. Tooewa anc Santa Fe Railroad (AT&SF), and the Norfolk 8 west een Raalcoao were contacted.

Accoro sng *o t he ICG, no ton a e enemicais are snappec on its two segment s of ra11 road wntch pass watnan five males of tne Bratowood site- (Reference 5) ano the

• and O total numoer of enlorane earloads on the AT&SF were only cursno 196 a*

eno 1985, reso6&tavely (Reference 6).

Tne 1966 survey revealeo that. on the basis of weight anc snsootno frecueneses orovtoec sn Regulat ory Gunde 1.78 for ostforent modes of transoortatson, enlorane was transported above frecuency recuarang analysts only on the Norfolk & Western sne Rattroso.

In orcer to perform the dtspersion and probability analyses, enlorsne snapment data (number of rastroad cars anc mawamum tonnage of entorane) for the years 1983, 1984, and 1985 were octaanea for the Norfolk & West ern Ra s 1 road.

-___ _ Contini1ed

(

)

/

At t achenent i E

May 19, 1986 Page 4 of 7

~Discersson Analysis and Control Room Infsitratten in Accordance witn R e g_u,J_plorv Gutee

1. 7%

Tne acescent al release constoered an this analysis is the cornolet e ruot ure of a rasl tank car containang 83 tons of Inoutfsed enlorsne w%sen anstantly releases sts contents.

Cnlorine as stored as a lacuso uncer pressure.

Upon release, aooromsmateiv 25% flasnes smrneo s at ely to vapor.

The remasnoer as a Inouse at -30+F, wnsen gracually pos1s off by transfer of heat from tne env s rc.nenent.

Ints scenarso as basec on Regulatory Gusoe 1.78 ano 1.95 (Aeferences 7,.8).

The flashed vapor consittutes tne orsnescal nazarc to tne station.

The ossoarsson ano cropagatton to the brascwood site as predacted in accorcance watn metnoos cesertbed an Regulatory Guide 1.78.

The st abs i s t v class constcereo as casou111, Type F, wnach results an control reors concentrassons wnsen woulo be exceeced an less than 5% of all occurrences.

Euntest 3 cesces bes the bas &s of the analysis and the result s.

Tne control room ase eMchange rate used in the analysts was that of a control room sn the non-smolated mode (Type C classifscatson oer Regulatory Gusde 1.78).

Exhibat 4 shows the results of ossoersson analysts as the es se an concentration with respect to

,s

[

tsme.

According to th ss analysis, the perscnnel of the control

\\

room can avoso eNoosure t o tom ac concentrat ions of chlors ne af an ooproorsate resoonse as mace withan two manutes of the t ame the cresence c.f enlorsne can ce cetected by its ocor (3.5 pom).

Tne resoonse may be the donnsng of atr masks.

The tonac level as 15 com.

Tne ena n s enum concentration (13.3 com) shown an Exnsomt 4 as t ne concent rat ion ex1 sting 2-minutes after the presence of the c*emscas sn tne control room oecornes not s ceable by i t s ocor t o oersonnel.

Tne oesigna,tton mausmum 1s usec-since the analysas constoers varnous wanc speeds anc tne value gsven as tne hspnest vaAue octasneo watn all wind speecs.

preemos;stv of Causino uns nnae s t acl e Cond s t i ons sn the Control Room cue to the Ruoture of a Chlorsne Tank Car on the Norfolk &

hy31ern Re21roaa bance the dispersion analysis showed that the chlorine concentration (13.3 opm) was ouite close to the toxic concentration (15 pom), a probability calculation was performed.

Tne Standarc Review plan (SRP) and Regulatory Guide 1.70 provsce cratersa for acceptance based on probabsisty calculations (References 9, 10).

Sectson 2.2.3 of the SRP provides criterna for cetermsnano af a tense release need be conssdered a cesign easts event.

Soecifscally, at states:

The orocactisty of occurrence of tne snattatsng events leacang to potentaal consequences in excess of to CFR part 400 exposure gusdelsnes should be est 1 mat ed ussng

)

assumotnons tnat are as representative of the spect(se site sq) u__o______._________._.______.__.________

- - _ _ _ _ _ Continued

[.

,-~ _

\\

At t aCnmer.; 1 May 19.

1 966-

&ane b of ^

as as erecticacie.

In accatson. oecause of tne low orecac142ttes of tne events unoer consaceration, cata are ceren not avataaose to oermat accurate calculation of crocac142tles.

Accorotnply. sne emoecteo rate of occurrence or cotentsaa exoosures an excess of the 10 CFR Part 100 gusceaanes of amorowamately 10-6 o,r y,,r 3.

,ge,og,og, gf, wnen comotnea witn reasonsole cueistative arguments. tne rea4astic cecoso s 11t v can ce snown to oe lower.

4 orocaos a a t y casculatson was cerformeo for enlortne snaoments e r.

tne morfole 6 western Aaalroaa Izne in the vaca naty of Brazowooo station.

Tnts orocac141ty was calculateo ey tne followsng metnoo.

5tattstacas meteorological cata (Table 2.3-25 of.tne FSARs for tne Bratowoeo site (30-foot level) were useo wnsen consistee of occurrence procabslaties of st aon lity class anc wino maonatuce.

Tne procaonlatv that tne control room could be mace unannsostacle was calcul at ea from three orobable events:

1) the orocanalstv that an acencent could occur within each sector; 2) tne orocaositty tnat tne wsnd nau a direction which would carry releasec vaoor to the control room, and 3) that the stabality class woulo os F or G.

A caffusaon analysis in accoroance w1th Heculatory Guace 1.78 anc 1.95 snowed that only a G stabalsty class woulo result sn unannabstable conditsons (tou t e

,e's concentrations of 15 com two minutes after detection by ocor) in Ine brazowooc control room cue to rupt ure of an 83 ton rail tar,

(%

car on tne Norfolk & Western Railroad I n ne.

Since the F stantistv class snowec haastable condatsons only by a small ma r o i n.

it was also ancluceo an the probabs t a t y analyst s.

Only sne cortton of the ras 1 road wathan a d2 stance of 5 miles from tne stataon reousreo consaceration an this analys ts according to neoulatory Gutoe 1.78.

Tne followano calculation was cerformeo 3

= Dw(D)

(Ecuation 1) l Pr(Ls u F(C) = IL(D) va =

D=

1 Wneret orocacilaty of acendent resultang an control Da =

room unannaDatab111tv Creleases]

[ year J

orocao 11tv of release Creleases2 tr C)

=

- [carma le 3 frecuency of shtoment

[ cars)

FtC)

=

[ year 3 l

lenotn of track uncer consideration (miles)

LsDs

=

/

l

. - ~

I L Continued 1

1 1.

f '.

l:

-1

.m At t ecosacret !

1 e.y 13.

in l

y, Aage 6 of 7 l

l<

orc occa t aty snat unoer 7 ano 5 staosixty classes.

swiDs =

a enemscal w a r.o - a s. o s ew s no sr. a,otrect2on suen Snat t owaro tne cont rol room a s e antase re4 ease is carrieo s b a rnens i on A ess a. D 1s tne o2 rect 2 on f rom wnsen the wano is o4owing tSee Euntost 5)

.- s snowr. S r.

cwntcat

o. coserine (tilass t f teo as a non-faammaele t, a s s nas.accicent tre4 eases frecueneses of:

a v -6 g,.,1,,, g) v.019 w

-rsus a Cearmale 3 ene fosiewing'ensorsne sn a ctnent cata were ootained for the neorr o i x & western Ha11roao inne (Reference 11):

Garloads of Chlortne Veer 36 19ed 49 196*

24 1985 As snown in Exh101t 7 n

3

.{

0.04939 (msIes) 1.L ( D s x Pw(D) =

\\

D=

1

• 9 sn s ornent s/ vear, ano usang Ecuatson (1), the as sorn t ng orocaotisty of entorane release ts:

sa = 0.049 x 10 g7,3, 3, g,9 g

), o,o4939 g,3 3,g

-6 tearmale 3

[ year 3

~0

=

x 10 treleases!

C year 3 as conservative anc the cronacalaty assessment lower because of ine use of Enns resiastte crocactisty can ce shown to be even sne'followsng conservatssms an tne acescent release probab21staes No creast was tawen Emproveo safety from recent tank car modifications 4

The accaderit for tne neac ounct ure resist ance syst em.

release propabilaty cata were from 1971-77 stat astscs before such as a tanx occame mandatory.

car mocaftcat2ons the tanw n.o creo t t was tawen for operator sncapacatation events 2n exposures in excess of 10 CFR 100 tnat wouso not result Tnts analysss assumed all such events resultec Oniv one out of ten operator incapacatatson p u n ce s a ries.

an an overewoosure (Reference 12. 13).

n c.v ere u pos ure.

events wouic result

{e\\

%)

1 l

L Continued l

L l

Attacnment a nav 19.

t3a6 Pace 7or 7 ws snown in f.xntoit

6. t ne reurnoer of cnior3ne ra 11roso car-sn i orcent s 15 1065 cer year for-an execsure ras-of 10 -6 ivr.

do % ust.oyt v r. tne casas of weagnt ano sntootro frecueneses crovaceo are weculatorv uusce 4.76. eniotine ts'shacoeo on tne Norfol< &

er, tern Aaairoac lane aro tne maxtmum numoer-of enlorine retiroso car s sntooeo curang 1983-1965 on tne Norfolk & Western Rasitoao

. t r.e as reoorteo to oe only 49, wnalysts of tne control roc.ra naostacality an accoroance-warn neou4atory Gusco 1.76 snows snat sne enlorine concentration an sne control room coes not eacn tne toxic level 2 manutes after sne cetect ion av tts ocor.

Esnee tne analysis snowed haottacle cono tt sons only ov.a srna l l ena rg a n.

a probability analysts was cerf orrneo wn sen snowoo t hat the Braa dwooo St at 2on control - room as naostacle for an exoosure ra sx of 10-6 per year for up to 1065 sn a crnent s of en t orine on 'tne Norfolu & Western Railroad l a r.e.

Tnt s cronao111t y as snown to be even lower wnen cualitatsve assurnet sons are taken into account.

ine.results of tnese two analyses show tnat chlorine detectots are not reoutree at tne Brasowood Station.

It should be noted O

tnat an accot'cance witn olant emergency plans and procecures, i

self-contaantno creatnsng aooaratus as proviced for assurance of control room naostamalsty an the event of possaolo detectaon of enlorine ano smowe cue to accioents.

e is

i

. Attachment 2 Continued x

f i

V(

w ieferer. gen Co. r.:.: r,we e t t m 6c a son Cornoany, Byron /&ratowooo Station Fanas u e t.-

r,a a vs a s. Aeoort. volume e. Seetson 6.4 e.

4 m a t e n.e i l. Cnlorane Inststute. New York. Personai Commurt-att:n watn baruent & L u no y.

Maren 11.

1986.

2.

. artes w a ll a aris. Trar,soort at z on Manager. Vulcan Cnemacat moraoa v.

Personas Cc.rnrour.a cat son wa t n Sargent & Lunoy.

may 13.

1966.

Vallev t merna cal C ord oa n y.

Personal Commun*cataon watn Sargent & Lunoy, May 16. 1986.

w. Garoner. Superantencent of Transoortatson, 111&noas f

Central Gulf Railroad, Personal Communication watn Sargent & Lunoy, Maren 5, 1986.

6.

L.

Zaneer, Atchason Tooeka and Santa Fe Raalread, Personal Communicat son wa tn Sargent & Luncy, Maren 5, 1986.

7.

U. S.

NRC Regulatory Guade 1.78, "Assumotaons for Evaluatar.g O

t 9e Habitaca l s ty of a Nuclear Power plant Control Room Durar.g a Postulated Hazardous Chemacal Release."

8.

u S.

vaC Regulatory Guace 1.95,

" Protection of Nuclear powe, Plant Control Room Doerators Against an Accacental Cnlor a r -

Aelease.*

9.

(s. 5.

NRC Star. caro Revtew plan. "Evaluataon of Potent 1al Aceacer.ts." Sectaqn 2.2.3 NUREG-0800, Rev.

2, July 1961.

20.

U. S.

NRC Regulatory Gutee 1.70, "Stancaro Format anc Cont ent of Safety Analysis Reports for Nuclear Power Plants",

Sectaon 2. 2. 3.1.

11.

Norfol* & Hesteen Raa1 road, Mr.

G.

Walker, personal Communication watn Sargent & Lundy, FeDruary 14 and 27 and merch 21, 1986.

12.

D.

E.

Bennet, D.

C.

Heath, NUREG/CR-2650, SAND 82-0774 R4 "Allowsole Shaoment Frecueneses for the Transport of Towac Gases Near Nuclear Power Pl aret s " Prepared by Sandaa National Lacoratorzes, October 1982.

13.

Ducuesne Lacht Co ncany Report ~to NRC " Beaver Valley Power Statson Control Room Haba t aba l s t y, " December 28, 1981.

a lettee cateo Aoral 1.

1986 from A.

D.

Maosa (Commonwealth 6ctson Company) to H.

R.

Dent on (Nuclear Regulatory Commas-a a or, s, eos t -styleent_. Cor t roj Goom_ Maoataea1atv Ana)1s w fgr Etajcwpoo Sta_t a en.

_ _ _. _ Continued 1

l

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a*o D.

kaimer. " a ssues er o Dirneris a orit, w.

{ee:ca* ' Car 51:et A Cericenot urt. '

O. S.

De pa rt enent of vt a.s 2 : e t at i c.n.

eceral 3 4a,0 A3-7 3 < 56.

na t a roao worna r.a st ras s on Aeoort ivo.

l

+

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l

_ _ _ - _ _ _ _ _ _ - _ _ _ Continued O,

Exhibit 1 5!

May 19,1986 E-

!r Page 1 of 1 7gl 9

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_ - _ _ - _ _ Continued

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innasts i Aav 19. n!

...e 00081( ulF in site w asstf#E# 1947 FelCILitIES caESTD 97 72s&/CITIE1 sITwth 10 mils.M 30 EMS OF T4 WWIIDdID ETATIk e! fain 10 sids gia7Df0f g3)$7D TUfgri katommac 100 les cylimers (gest 5 gallen ens lineuts)

Casi Catt tascaucing (niserd

!W las cyiseers (Isonna e

Faceville 150 los eyitusrs flaoutsi e

Ersner htZil 150 Its cylinsors (lassis) fonte Wilsi g m sis (Ill 130 les cylsveers (liestal v1THIh 30 sids Chicago M(Ell

! ten contaters (laousel Jelays 150 les cylseners illessel I ten contanwes (laestel enmasse i ton etatatirs (1:suasi i ten containes illeutel hursamais e

150 Its cylieners (liestel

\\

kaoley e

i tan contators flieund) tamsevaile 130 las cylanners (laeussi ISO les cylassiers (lassist 6censort 150,las cylteers (1:ssid)

I tem contaiers (Isouts)

Crest nall 150 Its eyismers (1 ssis)

ISO !ss cylivmors (lacessi 1

treetasm facalsty, raw facility, or se enlarte snac,

.. - _ _ _ _ - - _... - _ _ ' Continued

/~N

)"

Exhibit 3 May 19, 1986 Page 1 of 1.

~ CONTROL ROOM HABITABILITY ANALYSIS Material Spilled liquified chlorine.

Weight 83 tons Distance from Control Room s

4.5 miles-Atmospheric Stability Class F

Ambient Air Temperature 90*F Concentration-Detectable by Odor 3.5 ' ppm Toxic Concentration (2 Minute Exposure) 15 ppm Maximum Concentration at,Braidwood Site 378 ppn Maximum Concentration in Control Room 13.3 ppu 2 Minutes After Detection Control Room Makeup Air 6000 ft /m 3

Control Room Volume (Reference 14) 405164 ft3

- Wind Speed Causing Maximum Concentration 6.15 mph in Control Rocun af ter 2 Minutes o

^

l s.

Attachment' 2 Cont'inued

~

0; e

i Exhibit 4-

.)

May 19,1986 Page l'of-1 2 0 t

' ~~

15 Toxic concentration h

120 seconds

.oc

.a g 10 t

y U

eo a

o 5

u Detectable by odor u

C 0V O

i f

I i

2500 2550-2600 2650 2700 Time elapsed after spill, seconds Concentration in control room after 83 ton spill of chlorine at 4.5 miles O

' Attachment ' 2. Continued.

-Exhibit 5

=

May 19, 198 Page 1 of 1 I

1 Control Room Norfolk Western l

RailroaL-Y Line f

-l

+$

ESE LO SE SSE l-Schematic showing relationship between the Norfolk & Western Railroad Line, WIND Sectors and the Control Room O

L

. Continued!

lj.

1 Exhibit 6

(,

May 19,- 1966 Page 1 of 1 ACCIDENT FREQUENCIES PER MILLION CAR-MILES FOR HAZARDOUS MATERIALS COMMODITIES DAMAGE THRESHOLD

_. _50

>S100

>S5000 Explosives 1.30 0.63 0.210 Non-Flammable' Gas 1.'00 0.15-0.019*

Flammable' Gas-O.94 0.20 0.094 Flammable Liquid 1.20 0.32-0.110 Flammable' Solid 0.69 0.17 0.058 Oxidizer 1.60 0.66 0.069 Organic Peroxide

.l.40 1.40 Toxic 1.10 0.43 0.079 Radioactive 3.00 1.30 0.420 Corrosive 2.50 0.45 0.090 All Hazardous Material

-1.40 0.33 0.086 a

• chlorine is classified as a non-flammable gas.

'aterials Transportation Board Data SOURCE:

M 1971-1977; i

Arthur D. Little, Inc., Estimates.

Excerpted from U.S.. DOT FRA/ORD-79/56 (Reference 9).

-~

_. _ - _ _.. _ _ - Continu'ed :

Ia I --

I Exhibit 7' j-g May 19,1986 Page 1 of 1 CONTROL ROOM RISK ANALYSIS FOR SHIAMENTS OF CHLORINE ON THE NORFOLK AND WESTERN RAILROAD LINE Length of Railroad Summation of F and G probability of occurrence section length stability class proba-(All wind speeds for witha n f1ve miles bilities multiplied 1

wind F & G stability classes) of site by section length 5,cgor AwtD)

L(D)

L (D) w [Pw(D) j ow(D)]

l

+

F G

i ESE 0.0079

0. W43 1.63 O.01989 SE

'O.0084 AM5 1.87 O.02412 SSE 0.0090 C 60.'t8 0.42 0.00538 i

3 IL(D) x Pw(D) = 0.04939 (miles)

D=1 i

i

'f A.

i e

l 1

i l

1 I

l i

l 1

1 i

i l

1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ Continued l

l n )'

i Exhibit 8

• ~/.

May 19, ige page 1 og i NUMERICAL EXAMPLES OF RISK EXPOSURE LEVELS Number of Shipment s Centrol Room of Chlorire Der Year Ewoosure Risk 10-8 49 4 x 10-7 106 1 x 10-6 1065 1 x

\\

O 6

i

'l l

R-_.______.________________._____

.i

' Cornenonweetth Edison :

r

{ f - One Fast Nabonal P'ata. Cheogo. Enors D/'

s Adtkees Reply to. Post Usos Bon 757 Cheago,Ibrwa 30000 0767

[ i' April 2, 1987-Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Nashington, DC. 20555

Subject:

- Braidwood-Station Units 1 and 2 Removal of Control Roon Chlorine Monitors NRC Docket Nos. 50-456/50-457

Reference:

(a)

June'3, 1986 A.D. Miosi letter to H.R. Denton (b)

December 23,-1986 S.C. Hunsader letter to H.R. Denton~

(c)

March 4, 1987 S.A. Varga letter to D.L. Farrar

Dear Mr. Denton:

References (a) and.(b) provided' Commonwealth Edison's justification for the removal of the chlorine monitors from the control room ventilation system at Braidwood Station.

Reference-(c)

Q' provided the NRC approval to remove the_ chlorine monitors pending a commitment by Commonwealth Edison to perform additional Technical Specification surveillance.

This letter provides Commonwealth Edisons' commitments regarding this matter.

l The chlorine monitors will be removed from the control room i

ventilation systen design prior to initial reactor criticality of Braidwood Unit 1.

Manual isolation capability of the control room envelope will be provided and this capability will'be subsequently demonstrated on an 18 month basis, thereafter, via Technical-Specification surveillance.

Regulatory Guide 1.78, position 5(b), describes the analysis required for a maximum. concentration-duration accident.

It requires that the continuous release of hazardous chemical from the largest safety relief valve on a stationary, mobile, or onsite

~

source falling within the guidelines of Table C-2 be considered.

Using the interpolation method provided in Appendix A of Regulatory Guide 1.78 for chlorine in conjunction with Table C-2, a control room habitability evaluation would not-be required when the air exchange rate is 0.39 per hour.

This is based on a toxicity limit of 45 mg/m3 being present in quantities less than 83 tons j

(the maximum cargo weight in the railroad tank car) at a location between four and five miles away from the control room.

G l

.. \\.

For the Braidwood control room volume of 405,164 cubic feet, a maximum in leakage of 2633 cubic feet per minute (CFM) is required to maintain an air exchange rate of 0.39 per hour.

Due to the level of integrity designed into the Braidwood control room envelope, we are confident that the infiltration test will yield results much smaller that 2633 CFM and that further habitability analysis and subsequent inlaakage testing will not be necessary.

A test will be performed to determine infiltration into the control room envelope when the control room is in the isolation To ensure plant design conditions are accurately represented, mode.

this test will be performed after Unit 2 construction activities and final preoperational testing of the Auxiliary Building Ventilation System are completed, currently scheduled to be completed prior to Since bubble tight dampers have been installed as Unit 2 fuel load.

of the control room boundary, the measured infiltration is part expected to be relatively small.

NRC review and acceptance of these commitments is requested.

Please address any questions concerning this matter to this office.

O fc4 a-S. C. Hunsader Nuclear Licensing Administrator

/klj cc:

J.

Stevens Resident Inspector 2930K 4-

4 s

C:nunrnw alth Edi;:n One First National Plan Chicago. Illinois Address Reply to: Post Othce Box 767 Chicago, Illinois 60690 - 0767 j

j l

May 6, 1987

'~~

l 1

Mr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S.

Nuclear Regulatory Commission Washington, DC 20555

Subject:

Braidwood Station Units 1 and 2 Removal of Control Room Chlorine Detectors NRC Docket Nos. 50-456/50-457

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:

/D The purpose of this letter is to clarify Commonwealth

~

x/ 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.

Attachment A provides an advanced submittal for NRC review of the Technical Specification addition addressing this surveillance.

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.

\\,.

! (Continued)

I

g. Murley. Director May 6, 1987 1

r~N I

t-

'w/

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

reference (a).

A station procedure is being developed to address the control room integrity demonstration as required in reference (a).

Please address any questions concerning this matter to this office.

Very truly yours, l(f

= =%

S.

C. Hunsader Nuclear Licensing Administrator cc:

J.

Stevens NRC Resident Inspector

-s w

3044K l

l l

1

.' (Continue'd) -

l

.i i

I i

Attachment A es

~ %,

Proposed changes to NUREG-1223 Technical Specifications Braidwood Station Revised pace:

3/4 7-16 3044K l

l l

l l

O l

j

y s

_m

.m m-

~-

+ hL rec.irc u la Ucn o d c.

& o p e r o W n.

fANTSYSTEMS (Continued)

SURVEILLANCE REQUIREMENTS (Continued)

J (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 L

flowrate of 49,500 cfm i 10%.

[

f.

After sach 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 D0P 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 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 (o)

Positions C.S.a, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 49,500 cfm 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 Regulatory 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 10% for the Recircula-tion Charcoal Adsorber when tested in accordance with ANSI N510-1980.

i.

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 N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating at a system flowrate of 49,500 cfm 10%.

j.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of Recirculation Charcoal Adsorber operation by verifying within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatony c

Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978 meets i) the laboratory testing criteria of Regulatory Guide 1.52, Revision 2, s'

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%.

8RAIDWOOD - UNITS 1 & 2 3/a 7-16

[

3' i

/ J N Comm::nw;alth Edison.

/

'i k 4 )M Orn First Nrtional Plaza. Chicago Illinois Adoress Fieply to: Post Office Box 767

' 'b7 - Chicago, Illinois 60690 0767

, if December 23,.'1986 1

Mr.' Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

[. -

Washington, D.C.

20555

Subject:

Braidwood Station Units 1 and 2 Habitability of Control Room Following Postulated Accidents Involving Shipments of Chlorine NRC Docket Nos. 50-456 and 50-457 References (a): June 3,1986 letter from a.D. Miosi to H.R. Denton.

(b): NUREG-1002 Safety Evaluation Report supplement No. 2, dated October, 1986

Dear Mr. Denton:

IO Reference (a) provided Commonwealth Edison's analyses to determine O

control room habitability in the event of an accidental release of chlorine near Eraidwood Station. Reference (b) presented this matter as an unresolved item that was under staff review. On November 26, 1986, this item was discussed with the NRC Staff and general concurrence was received that the chlorine detectors may be removed if appropriate emergency planning notification measures are established to address a chlorine accident.

Since that time, discussions have been held with representatives of Will Co.,

Illinois and-they have agreed to provide notification to Braidwood Station in the event of a chlorine accident. Formal concurrence on this matter is expected from them by January 26, 1987.

Please address any comments on these questions to this office.

One signed original and fifteen copies of this letter are provided for your review.

Very truly yours,

. C. Hunsader Nuclear Licensing Administrator im cc:

J. A. Stevens - NRR 2543K w___-_-____

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Attechment 8 EwCP VC-14 Revisicr. 51-MAIN CONTROL ROCM PRESSURE LOW

(

'(

A.

STATEMENT OF APPLICAE LITY This procedure describes steps which can be performed to help determine the cause of low pressure within the Control Room Area.

B.

REFERENCES-1.

P&ID a.

M-96 Sheet 1 through 5, MCR HVAC System 2.

Technical Specifications 3/4.7.6.

3.

LCOAR - BwCS 7.6-la.

C.

PRERIOUISITES None D.

PRECAUTIONS None E.

LIMITATIONS AND ACTIONS

(

If pretsure is low in the Control room Area, immediately notify the Shift Engineer. The Shift Engineer shall determine operability status and implement LCOAR _BwCS 7.6.a-la as appropriate.

F.

MAIN BODY

• • • • eeeeeeeeeeeee

.**********een NOTE

• The following steps can be performed in any

• convenient order. The order listed is the

• reconsnended sequence if cause of low pressure

• is not known.

• • • • ............e**********enenee.***eenne***

1.

CHDCK position indication of the operating train dampers at OPM02J for abnormal alignment of the system:

DA/0B TRAIN NORMAL MAKEUP DAMPER

• POSITION POSITION a.

OVC17Y/0VC01Y OPEN OPEN b.

OVC19Y/0VCO3Y OPEN OPEN c.

OVC20Y/0VC04Y CLOSED CLOSED APPROVED 1

NOV 2 1987 8075P(081487)

SR AIDWOOD on-sar etwig w l

\\

Attachmwnt 8 (continu d) ~

BwCP VC-14 Revision 51 OA/DB-TRAIN NORFE VJ72UP

" [V X

DAMPER =

POSITION-POSITIOtJ T.

1.

d.

OVC18Y/0VCO2Y CLOSED CLOSED e.

DVC24Y/0VC68Y' CLOSED' OPErJ or DUAL

'(modalating) f.

OVC281Y/0VC282Y OPEN CLOSED g.

OVC32Y/0VC16Y OPEN CLOSED h.

OVC312Y/0VC313Y CLOSED CLOSED i.

OVC25Y/0VC09Y CLOSED OFDJ j.

OVC033Y/DV;172Y OPDJ OPDJ k.

OVC43Y/0VC44Y OPEN CLOSED 1.

OVC21Y/0VC05Y CLOSED OFDI m.

OVC22Y/0VC06Y CLOSED OFDJ 2.

CHECK the shutdown train. isolation dampers indicate CLOSED at OPM02J.

a.

CA Train: Return fan OVC17Y Supply fan OVC33Y b.

OB Train: Return fan OVC01Y Supply fan OVC172Y 3.

CHECK the area differential pressure indicators to determine which area or areas have the low pressure problems:

AREA AP NORMK LOCATION INDICATOR INDICATED READINC OPM02J OPDI-VCO37 Control Roc. - Aux Bldg

> +0.125" l.

OPM02J OPDI-VC038 Control Room - Turbine Bldg

> +0.125" OVC01JA OPDI-VC037A Control Room - Turbine Bldg

> +0.125" OVC01JA OPDI-VCO37C Control Room - #1 Computer Rm

> +0.125" OVC01JA OPDI-VCO37D OA VC HVAC Rm - Div 11

> +0.125" Misc. Elect. Equip. Rm DVC01JB OPDI-VCO3BA Control Room - #2 Computer Rm

> +0.125" 0VC01JB OPDI-VCO3BD OB VC HVAC Rm - Div 21

> +0.125"

,/

Misc. Elect. Equip. Rm APPROVED 2

8075P(081487)

NOV 2 1987 SR AIDWOOD.

Of*-s#TE pa virw

Is Attgegegt 8 (continued)

~

E Revision 51

/m -

NOTE

,2

~

• If pressare is low in most areas, the problem a

• is'probably due to the VC system line-up or a

• 1arge penetration / door being open in the

• pressure boundary.

If pressure is low in only

• a few areas, the problem is probably due to

• penetrations / doors being open in that particular*

• area or an adjacent ventilation system (VA, VE, *

• VV) operating in an abnormal line-up.

..e..............................................*.

F.

4.

CHECK the doors in the area or areas of' concern to verify they are CLOSED. The area should be checked for open penetrations, conduits, cable pans, etc, which penetrate the pressure boundary at this time also. Refer to Figures VC-14-1 and VC-14-2 for location of doors and pressure boundary perimeters.

NOTE

• Only pressure boundary doors are listed below.

• Doors inside the boundary which separate areas

• should be CLOSED also.

(For example, #1 Controla

• Room to al Aux Elect Equipment Room door.)

[

PROBLEM DOOR AREA NUMBER FIGURE #

a.

0A VC D41B VC-14-2 HVAC Room D420 VC-14-2 b.

s1 Aux Elect Equip Room D428 VC-14-2 c.

1. 1 Computer Room D432 VC-14-2 D430 d.

1. 2 Computer Room D440 VC-14-2 D441 D442 e.

1. 1 Control Room SD109 VC-14-2 f.

42 Control Room SD171 VC-14-2 g.

1. 2 Aux Elect Equip Room SD174 VC-14-2 h.

OB VC SD445 VC-14-2 HVAC Room D446 VC-14-2 i, U2SR SD180 VC-14-1 SD183 VC-14-1

/

SD181 VC-14-1

\\

SD182 VC-14-1 APPROVED NOV 2 1987 8075p(081487)

BRAIDWooD ON.ssig egy,g w

_ _ _ _ _ _ _ _ _ _ (continued)

BwCP VC-14 Revision 51 T. : 5.

CHECK for audible air leakage from open or partially open o

's access doors durir.g walkdown of the CA HVAC Room, OB HVAC Room, and especially the Upper Cable Spreading Rooms.

CAUTION ONE ACCESS DOCR OPEN ON THE SYSTEM DUCTWORK CAM *

• ADVERSELY AFFECT THE PRESSURE IN ALL AREAS OF

• THE CONTROL ROOM ENVELOPE.

6.

CHECK the position of the 8 two-position flow control dampers in the Upper Cable Spreading Room (USCR) Areas to verify alignment to the A train or B train position (whichever train is operating):

NOTE

• Damper position is checked by observing the

• actuator stem position indicator which is marked *

• with "A" and "B" positions.

NOTE

• Refer to Figure VC-14-3 for damper locations.

g

(

NOTE

• Dampers are listed below in order of walkdown

• starting on the Unit 1 side of the UCSR and

• proceeding to the Unit 2 side.

DAMPER #

AREA SERVED UCSR LOCATION OVC035Y OA HVAC Rm Supply P, 11-12 OVC095Y Unit #1 Aux Elect Equip Rm Supply P-Q, 11-12 OVC094Y Unit #1 Aux Elect Equip Rm Return N-P, 11-12 OVC133Y Unit #1 Control Rmm Return N-P, 17 OVC217Y Unit *2 Control R.,om Return N-P, 21 DVC182Y Unit #2 Aux Elect Equip Rt Feturn N-P, 24-25 OVC175Y Unit 62 Aux E!tet Equip Rm S.spply P-Q, h 25 OVC199Y OS HVAC Rm Supply N-P. 24-25 1'

APPROVED

(~(

NOV 2

$87 4

BRAIDWooD 8075P(081487) cm.scre nvis.

L_

E Attachment i 8 ' (continued)

BwCP_VC-14 Revision 51 n.

=r.

7.

CHECK for abnormal alignment of adjacent. area ventilation' 1

' system on MCB OPMC2J or local panel listed below:

SYSTEM NOR.*E LINEUP LCP/ LOCATION

a. : W:- Control I supply: OWOICA or. 0WO13/f '1 '~ K-24 Room Offices OWO1CB EM Electronics Shop

. Ventilation 1 return:

0WO2CA or OWO2CB b.

VA - Aux Bldg 2 supply: OVA 01CA or DVA01JA/463'-Q-15 Ventilation-OVA 01CB and OVA 01JB/463* S-15

'0VA01CC'or OVA 51JC/463' Q-21 OVA 01CD or OVA 01JD/463* S-21' 2 exhaust: OVA 02CA or OVA 02CB and 463' OVA 02CC or OVA 02CD No booster fans c.

VE'- Div 11 1 supply:

IVXO4C IVX01J/426* P-10 1 exhaust: IVE04C d.

VE -'Div 12 1 supply:

IVE01C-IVE01J/451' Q-8 1 exhaust: IVE05C e.

VE - Div 21 1 supp 2VX01J/426' P-26 f.

VE - Div 22 1 supply: 2VE01C 2VE01J/451' P-26 1 exhaust: 2VE05C f

APPROVED h

NOV 2

$87

(

Q

'R*'D*00D 5

oSans acview 8075P(081487)

__2________________________________________._______

Attagh gg{ (continued)

J Revis:en 51 Figure VC-14-1

..s

/

I

\\_/

UcsR pocgs TCP OF AUX BLD3 STAIEhTLL SDlB0 SD183

\\

\\

/

/

f h

\\~

\\

/

g

\\

/

SD182 SD181 (OA HVAC ROOM)

(OB hTAC ROOM)

%/

?

i APPROVED

,- m I

)

NOV 2 1987

'O 6

ena,owooo on ms arv'rw 8075P(081487)

O

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5<

=328%5 vt l

Attggmg8 (continued)

Revision 51 t

FIGUFC VC-14-3 f.

2. - POS:! ION DVPER LCCATIONS

-OVC217Y OVC133Y q

\\

\\

/

OVC175Y OVC095Y s

/

@ OVC,199Y g

f f-OVCO35Y g'0VC152Y OVC094Y-

/

g-

^

s b

O l

l 5

L.

l l:

L f%

APPROVED

-()

(Final) 8 NOV 2 1987 8075P(081487) owIsN$svicw

l.

Y.

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LBwCP VC-16 w,, Attachment 10 Revision 0 OPERATION OP THE CONTROL ROOM HVAC SYSTEM

/-,.

IN~THE RECIRCULATION MODE k)

A.

STATEMDTI 0F APPLICABILITY This procedure outlines-the steps necessary to place OA/0B Control Room HVAC System in the Recirculation mode of operation

~ in the event' of a chlorine / toxic chemical spill in the vicinity

.of the station.

B.

REFERENCES 1.

P& ids a.. M-96, Diagram of Control Room HVAC System.

b.

M-ll3, Diagram of Control Room Offices HVAC System.

2.

Electrical Prints a.

~20E-0-4030VC series.

b.

20E-0-4030W10.

3.

Station Procedures BwCP VC-1, Startup of the Control Room HVAC System.

~

C.

PREREQUISITES.

1.

A chlorine / toxic chemical spill / leak has taken place in the vicinity of the station.

2.

A Control Room HVAC System is in operation per BwCP VC-1.

D.

PRECAUTIONS None.

E.

LIMITATIONS AND ACTIONS None.

P.-

MAIN BOLY 1.

PLACE Cont Rm HVAC &nual Isolation switch in the ISOLATE position at OVC01JA.

2.

PLCE Coat Rm HVAC Manual Isolation switch in the ISOLATE posi' ion at OVC01JB.

4 APPROVED l.

NOV 2 1987 1

7374P(103187) enxiowooo on sers arview

AttCchm2nt 10 (Continued)

BwCP VC-16 Revision 0 Z,Y

.V

/

F.

3.

At OPM02J, VERITY /DJSURE the following damper positions for Control Room HVAC System 0A/0B that is in operation:

,s a.

OVC17Y/01Y, MCR Rtrn Air Fan Init Dmpr, OPDJ.

b.

OVC19Y/03Y, MCR Rtrn Air Fan Outit Dmpr, OPDJ.

c.

OVC20Y/04Y, MCR Max Outside Air Dmpr, CLOSED.

d.

OVC18Y/02Y, MCR Exh Dmpr to Turb Bldg, CLOSED.

e.

OVC24Y/08Y, M/U Air Fltr 0A/0B Outit Isol Dmpr, CLOSED.

f.

OVC03CA/B, M/U Air Fltr 0A/0B M/U Fan OA/0B, OFF.

g.

OVC32Y/282Y, MCR Outside Air Damper, CLOSED.

h.

OVC281Y/16Y, MCR Outside Air Damper, CLOSED.

i. OVC312Y/313Y, Outside Air to M/U Fltr Isol Dmpr, CLOSED.

j. OVC25Y/09Y, Turb Bldg Air to M/U Fltr Isol Dmpr, CLOSED.

k.

OVC33Y/172Y, MCR Supply Air Dmpr, OPDJ.

1.

OVC43Y/44Y, Recirc Char Absorb Byp Dmpr, CLOSED.

m.

OVC21Y/05Y, Recire Char Absorb Init Dmpr, OPDJ.

n.

OVC22Y/06Y, Recire Char Absorb Outit Dmpr, OPDJ.

4.

In the Upper Cable Spreading Room, elev. 469', VERIFY /DJSURE the following Computer Rooms #1 and #2 damper positions:

a.

0W63Y/62Y, Computer Room #1 Sup Dmpr, CLOSED (M-16/N-16).

b.

0W65Y/64Y, Computer Room #1 Exh Dmpr, CLOSED (L-16).

c.

0W67Y/66Y, Computer Room #2 Sup Dmpr, CLOSED (0-18).

d.

0W69Y/68Y, Computer Room 4t2 'Exh Dmpr, CLOSED (M-20/L-20).

l-5.

Locally VERITY /STOP the following:

a.

OVC06C, Control Room HVAC System Locker Rm Toilet Exh Fan.

b.

OVC07C, Control Room HVAC System Kitchen Exh Fan.

c.

OVC08C, Control Room HVAC System Stor Rm Toilet Exh Fan,

,(J' APPROVED NOV 2 1987 7374P(103187) o7.@%, f, l

1

]

4,,, p rt X Attachment 10 (Continued).

BwCP VC-16 i

}R."

Revision 0-1' F.

6.

When the outside air has been declared acceptable, perform the following-to return the Control Room HVAC System to

)

. normal:

a.

PLACE Cont Rm HVAC Manual Isolation switch in the NORFAL position at OVC0lJA.

b.

PLACE Cont Rm HVAC Manual Isolation switch in the' NORFAL position at OVC0lJB.

c.

VERITY / ENSURE the following damper positions at OPM02J:

1)

OVC282Y/32Y, M~R Outside Air Dmpr, OPEN..

2)

OVC281Y/16Y, MCR Outside Air Dmpr, OPEN.

3)

OVC312Y/313Y, Outside Air to M/U Fitr Isol Dmpr, OPEN.

4)

OVC43Y/44Y, Recirc Char Absorb Byp Dmpr, OPEN.

5)

OVC21Y/05Y, Recirc Char Absorb Init Dmpr, CLOSED.

6)

OVC22Y/06Y, Recire Char Absorb Outit Dmpr, CLOSED.

d.

VERIFY / ENSURE the following damper positions for Computer Rooms #1 and #2 located in the Upper Cable f7 Spreading Room, elev. 469':

'd 1)

OW63Y/62Y, Computer Room #1 Sup Dmpr, OPEN (M-16/N-16).

2)

OW65Y/64Y, Computer Room #1 Exh Dmpr, OPEN (L-16).

3)

OW67Y/66Y, Computer Room #2 Sup Dmpr, OpEN (0-18).

4)

OW69Y/68Y, Cm.puter Room #2 Exh Dmpr, OPEN (M-20/L-20),

e.

Locally VERIFY / START the following:

1)

OVC06C, Control Room HVAC System Locker Rm Toilet txh Fan.

2)

OVC07C, Control Room HVAC Syst u Kitchen Exh Fan.

l:

l.

3)

OVCOEC, Control Room HVAC System Stor Rn Toilet Exh Fan.

l APPROVED NOV 2 1987 3

3 7374P(103187)

,s g w g o

AUimMR TESTING 1

. ATOhuCS INTERNATIONAL A Divlelen of North Amerleen Avietlen, Inc.

4

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NAA-SR-7234 III-114 lh

BwMP-3300-047 Fevision 2 2 SEMI AN!rUAL I!!SPECTIO:1 Cr TIRE / SECURITY DOORS 4

..}q

(

A.

IPUPPOSE To inspect the operability of the closing mechanism and latches on fire / security doors, B.

REFERENCES 1.

Vendors Installation and Maintenance Manual.

2.

BwAP 1110-1, Fire Protection Program System Requirements.

3.

NFPA'80.

4.

10CTR50 App. R.

C.

PREREQUISITES Work request package shall be completed up to and including 1.

Shift Supervisor's approval for work to begin.

and the 2.

Notify the Station Fire Marshal, or designes, Radiation Dept. prior to performing the surveillance.

Arrange with Security to provide an escort prior to 3.

performing the Surveillance on security doors.

D.

PRECAUTIOtiS 1.

All personnel must adhere to Braidwood Radiation Standards.

All maintenance shall be performed in accordance with the 2.

Maintenance Department administrative procedures, E.

LIMITATIONS AND ACTIOt[5 In the event the Acceptance Criteria is not met on Required 1.

Fir'e Doors during the performance of this procedure, IMMEDI ATCLY notif y the Shif t Engineer to initiate BwAP 1110-1A7. The Fire Marshal should be notified.

2.

Required Fire Doors will be flagged with a e on the data sheets in EmMP 3300-047A1.

Security doors will be addressed in EwHP 3300-047A3.

APPROVED I'

FEB 16 G89 9RMDWOOD ess-stts mswsw

.. -O.

1

.I 1333K(020689)

_ _ - - _ = _ - _ - _ _ - _ _ - _ _ - _ _ _ _ - - _ _ _ _ - _ _ _ _ _ _ - _.. - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - _ - _ _ - _ _ - - _ _ -

DwMP 3300-047 Raisi n 2 2 (continued) 3.

In the event the Acceptance Criteria is not met on Security Doors during the performance of this procedure, immediately

.,jy notify the Shift Engineer and the Security Maintenance

, - (,)

Coordinator or the Shif t Security Administrator.

l 4.

Finding a security door UNSAT during the performance of this Surveillance will not make the entire Surveillance UNSAT.

5.

Inspector _shall indicate completion of steps on Data Sheet by placing "S" for satisfactory items and "U"

for unsatisfactory items. Unsatisfactory items she.11 be identified on the " Corrective Action Report" Data Sheets Indicating action taken.

This may be in the form as minor j.

maintenance perforced on this inspection or resolved by writing separate Work Requests. In any event, all unsatisfactory items must be resolved.

6.

Only United Laboratories (U.L. ) listed or factory Mutual (F.M.) approved replacement hardware shall be used.

T.

MAIN BODY

• enen***e****meannemannenemane****me*** men **en*****

NOTE This surveillance may be performed as a complete or partial surve.111ance.

...............e**

...............................a*

• • • a.......

NOTE

(

Roll up doors with fusible links must have

'N./ -

• 1 link disconnected to allow closing. The door should drop immediately upon disconnection *

• of fusible link.

• • • e

• aae*************

1.

INSPECT Closure Mechanism for the followings a.

BOLTING: Loose / Missing.

b.

LUBRICATION: Light coating of Lub. (i.e. - LPS2, Penetrating Oil, 3-1 011).

c.

LINKAGE: Distorted / Deformed / Bent, d.

p?SCONNECT 1 end of fusible link to allow door to close II roll up door is being inspected.

e.

CLOSING SPEED: Moderate Closing Speed - Door Latches closcd under its own pewer, i

I f.

DCOR BINDING Door opens / closer, with no dreg.

I I

g.

EKDEllGI f usible link II pr.tvieusly disconnected in AFPRCVED step T41.d.

FEB 161989

(

2 s~

b R MChWOOO 1333K(020689) on sin necew b

b

DwMP 3300-047 Revision 2

'

• 2 (cont

• hied) 2.

IIISl'ICI door latches & locks. f or the (011owing:

5 a.

DOLTING:

Loose / Missing.

.j

-J

'y/

i b.

HANDLE / TJ10B : Proper Return of Handle / Knob (both I

directions).

c.

LUBRICATION: Light coating of.Lub. (i.e. - LPS2, Penetrating 011, 3-1 Oil).

d.

DOOR LOCK: Latches when closed.

e.

CROSS BARS: Return to Lock Position.

3.

INSPECT doors and door jambs for the following:

a.

Appearance..

b.

Holes.

c.

Other Unacceptable indications / damage.

4.

RECORD inspection on Data Sheet, BwMP 3300-047Al and/or BwMP 3300-047A3.

EECORD unsatisfactory items on Corrective Action Report, a.

BwMP 3300-047A2.

b 6

• 5.

PERFORM minor maintenance under this inspection. PERFORM major repairs under separate work request.

6.

NOIITY supervisor when completed for review and approval of Procedure.

7.

EETURN equipment back to its normal operating condition.

G.

ACCEPTANCE CRITERIA Each door and its associated equipment shall operate properly.

H.

CHECKLIST / DATA SHEETS 1.

BwMP 3300-047Al 2.

BwMP 3300-047A2 3.

BwMP 3300-047A3 l

APPROVED l.

FEB 161989 (rinal)

._mo y'm 1333K(020689) w__m m_____.___m

. Attachment 13 3,gp ye_7 Revision 5 PURGE OF THE CONTROL ROOM WITH 100%

3 OUTSIDE AIR l

)

A.

STATEMDIT OF APPLICABILITY:

i This procedure describes the steps required to purge the Control Room with 100% outside air locally at _PLO4J/;PLO5J or remotely at OPM02J.

B.

REFERENCES:

1.

P&ID:

a.

M-96-1 through M-96 Control Room HVAC System.

.2.

Electrical Prints, a.

6/20E-0-4030VC01/02 Control Room HVAC Supply Fan OA/0B.

b.

6/20E-0-4030VC03/04 Control Room HVAC Return Fan CA/0B.

c.

6/20E-0-4030VC19 through 6/20E-0-4030VC22 Control Room-HVAC Return air.and Purge dampers OA/0B train.

5.

3.

Station Procedures.

BwCP VC-1, Startup of the Control Room'HVAC System.

a.

b.

_BwCA PRI-5 Control Room Inaccessibility Unit __.

C.

PREREQUISITES:

1.

Permission has been obtained from the Shift Engineer to l

place the Control Room HVAC System in the PURGE mode.

2.

The Control Room HVAC is NOT receiving any of the following signals:

ESFAS (Engineered Safety Features Actuation Signal).

a.

b.

Radiation Control Signal.

(Gaseous channel only).

l NOTE

• Initiation of one of these Isolation ~ Control

• signals will isolate the Purge and allow the l'

• Control Room HVAC System to operate in the

• Isolation / Recirculation mode.

• • • • • • • • • • • • • • • • • • e********************************

3.

The supply and return fanc associated with the Control Room HVAC System are operating in accordance with BwCF VC-1.

l

?'

APPROVED NOV 201987

~1~

BRAIDWooD

• • • "5ac"5*

8983P(111457)

! 3 (continued) swop vc_7 Revision 5

-D.

PRECAUTIONS:

L /

1.

If purging smoke.from the Control Room, ensure the fire is completely out prior to performing this procedure, to prevent fanning or restart of the fire.

2.

When the Outside Air Temperature approaches freezing, then monitor Control Room HVAC System Chilled Water Cooling Coil Temperatures closely to avoid cooling coil damage.

3.

OVC20Y and OVC04Y, Outside Air Purge Intake Dampers and OVCO2Y and OVC18Y, Purge Exhaust Dampers may not re-seal when closed following purge operation. For this reason, thift procedure shall be performed only to purge smoke f rom the Control Room following a fire or at the Shift Engineers discretion. The dampers shall be leak tested as soon as practical following operation.

E.

LIMITATIONS AND ACTIONS:

None.

F.

MAIN BODY:

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • n********************

NOTE f

.(

• To place the Control Room HVAC System in the

• Purge Mode from the Control Room, perform

• step 1.

• To place the Control Room HVAC System in the

• Purge Mode from the Remote Shutdown Panel,

• perform step 3.

• To remove the Control Room HVAC System from the *

• Purge Mode from the Control Room, perform

• step 2.

• To remove the Control Room HVAC System from the *

• Purge Mode from the Remote Shutdown Panel,

• perform step 4.

• • • • • • • • • • • • • • e.. *********************************

1.

To place.the Control Room HVAC System in the PURGE mode at OPM02J, perform the following:

a.

ENSURE the Control Room HVAC Purge TRANSFER Switch Division l_ is in the REMOTE position at _PLO4J/_PLO5J.

b.

PLACE and HOLD the Control Room HVAC PURGE Switch Division l_ in the PURCE position on OPM02J.

c.

ENSURE the following dampers shift to their PURGE positions as follows:

(

APPROVED NOV 201987 "R*'DWOUD ON. SITE RE VIEW 8983P(111487) j

. 3 (continued)

BwCP VC-7 Revision 5 j

I l [

t F.

1.

c.

1)

OVC20Y/04Y, Outside Air Purge Intake Damper indicates OPEN.

i l

l 2)

OVCO2Y/18Y, Purge Exhaust Damper indicates OPDI.

i 3)

OVC19Y/03Y, Return Fan OA/0B Discharge to the Mixed Air Plenum indicaten CLOSED.

d.

RETURN the Control Room HVAC PURGE Switch Division l_ to the AUTO position.

e.

CHECK OVC32Y/16Y and OVC281Y/282, Outside Air Intake Dampers indicate OPEN.

2.

To remove the Control Room HVAC System from the PURGE mode at OPM02J, perform the following:

a.

PLACE the Control Room HVAC PURGE Switch Division 1_ in the RESET position.

b.

ENSURE the following dampers shift to their NORMAL position as follows:

1)

OVC20Y/04Y, Outside Air Purge Intake Damper indicates CLOSED.

'g)

(

2)

OVCO2Y/18Y, Purge Exhaust Damper indicates CLOSED.

3)

OVC19Y/03Y, Return Fan OA/0B Discharge to the Mixed Air Plenum indicates OPEN.

c.

PLACE the Control Room HVAC PURGE Switch Division l_ in the AUTO position.

d.

REQUEST Tech Staff perform leak test of OVC20Y/04Y, Outside Air Purge Damper and OVCO2Y/18Y, Purge Exhaust Damper.

3.

To place the Control Room HVAC System in the PURGE mode at

_PLO4J/05J, perform the following:

a.

PLACE the Control Room HVAC Purge TRANSFER Switch Division 1_ in the LOCAL position.

b.

PLACE and HOLD the Control Room HVAC PURGE Switch Division 1 in the PURGE position.

c.

DISURE the following dampers shift to their PURGE positions as follows:

1)

OVC20Y/04Y., Outside Air Purge Intake Damper indicates OPDJ.

/'S)

APPROVED

!U f40V 2019c7 B R AIDWooD on mz ncview 8983P(111487)

__ 3 (continued)

BwCP VC-7 Revision 5 F.

3.

c.

2)

OVCO2Y/18Y, Purge Exhaust Damper indicates OPEN.

3)

OVC19Y/03Y, Return Fan OA/0B Discharge to the Mixed Air Plenum indicates CLOSED.

d.

RETURN the Control Room HVAC PURGE Switch to the AUTO position.

e e.

CHECK.0VC32Y/16Y and OVC281Y/282Y, Outside Air Intake ~

Dampers ~ indicate OPEN.

f.

PLACE the Control Room HVAC PURGE TRANSFER Switch Division l_ in the REMOTE position.

4.

To remove the Control-Room HVAC System from the PURGE mode at

_PLO4J/05J, perform the following:

a.

PLACE the Control Room HVAC PURGE Switch Division l_ in the RESET position.

b.

ENSURE the following dampers shift to their NORMAL positions as follows:

1)

OVC20Y/04Y, Outside Air Purge Intake Damper indicates CLOSED.

2)

DVC02Y/18Y, Purge Exhaust Damper indicates CLOSED.

3)

OVC19Y/03Y, Return Fan OA/0B Discharge to the Mixed Air Plenum indicates OPEN.

c.

PLACE the Control Room HVAC PURGE Switch Division l_ in the AUTO position.

d.

PLACE the Control Room HVAC PURGE TRANSFER Switch Division l_ in the REMOTE position.

e.

REQUEST Tech Staff perform leak test of OVC20Y/04Y, Outside Air Purge Intake Damper and OVCO2Y/18Y, Purge

't Exhaust Damper.

i

(

APPROVED NOV 201987 4

1 (Final)

BRAfDwoop ON sitt acyrgw

_4_

,8983P(ll1487) 1

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