ML20246D268

Proposed Tech Specs Re Limiting Condition for Operation & Surveillance Requirements Re Control Room Ventilation Sys & Area Exhaust Filter Plenum Ventilation Sys

ML20246D268
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	03/06/1989
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20246D260	List: ML20246D257 ML20246D268
References
NUDOCS 8905100180
Download: ML20246D268 (18)

Text

-. s'

,,s s l

ATIACllMEHLA PEQEDSE D __C H AN GE S_TQ._A P_PENDJE__A,.

. TECIRUCAL_EPECIELCATIRt%_Of_EACILITY QEERATING LICENSES NPF-37 AND NPF-lh

__BXRON__ HEIDMROD Fevised Paggsl. 3/4 7-16 3/4 7-15 3/4 7-17 3/4 7-17 3/4 7-18 3/4 7-18 3/4 7-19 3/4 7-19 3/4 7-20 3/4 7-21 3/4 9-15 3/4 9-15 RC/sc1:0013V 3 8905100160 890306 ,

x PDR ADOCK 05000454 p PDC

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

i PLANT SYSTEMS 3/4.7.6 CONTROL ROOM VENTILATION SYSTEM

~

LIMITING CONDITION FOR OPERATION 3.- 7. 6 Two. independent Control Room Ventilation Systems.shall be OPERABLE. [

' APPLICABILITY: LAll MODES. c  :

. ACTION:

MODES 1, 2, 3 and 4: ,

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

MODES 5 and 6:

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

b. With both Control Room Ventilation Systems inoperable, or with the OPERABLE Control Room Ventilation System, required to be in the makeup .

mode by ACTION a. not capable of being powered by an OPERABLE emer-gency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

. SURVEILLANCE REQUIREMENTS 4.7.6 Each Control Room Ventilation System shall be demonstrated OPERABLE:

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

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the Emergency Makeup System HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters operating; and flow through the recirculation charcoal adsorber for 15 minutes,

c. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communi-cating with the Emergency Makeup System filter plenum by:

1) Verifying that the cleanup system satisfies the in place penetra-tion testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C. S. a, C. 5. c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 5000 :f- 11CFfor the Emergency Makeup System; _ ) li BYRON - UNITS 1 & 2 bSWten 3/4 7-16 4000cfn: and MOD cfn1 ( -

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample from the Emergency Makeup System 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 0.175% when. tested at a tempera-ture of 30 C and a relative humidity of 70%; and Verifying a system flow rate of_peen and (ofo00cfm

3) 00 cf-yococfm

' 10%-for the Emergency Makeup System and 49,500 cfm 10% for the Recirculation System

('

when tested in accordance with ANSI N510-1980.

d.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of Emergency Makeup System operation by verify-ing within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 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 0.175% when tested at a temperature of 30 C and a relative humidity of 70%;

e. At least once per 18 months by:

1) Verifying that the pressure drop across the combined'HEPA filters and charcoal adsorber banks is less than 6.0 inches Water Gauge while operating the Emergency Makeup System at a flow rate of 600 fa _ 0%

gg l

2) Verifying that on a Sa ty In,lection or High Radiation-Control Room Outside Air Intake test signal, the system automatically switches into a makeup mode of control room ventilation with flow through the Emergency Makeup System HEPA filters and "

charcoal adsorber banks and the recirculation charcoal adsorber; (

3)- Verifying that the Emergency Makeup System maintains the control room at a positive nominal pressure of greater than or equal to 1/8 inch Water Gauge relative to ambient pressure in areas adjacent to the control room area when operating an Emergency -

bdween 4000 C7h Makeup System at a flowrate ofg ,000 cfa _10% and the recircula- (

tion charcoal acsorber at a flowrate of 49,500 cfm 10%.

ag ffgg cfm 4)

'reder thu or es&

Verifying that the heaters dissipateA27.21 m b7 kW when tested .)l l

in accordance with ANSI N510-1980.

5) Verifying that the Emergency Makeup System maintains the Upper #

Cable Spreading Area at a positive nominal pressure of greater than or equal to 0.02 inches Water Gauge relative to the ambient 3

pressure in areas adjacent to the upper cable spreading area /

(except for adjacent control room areas pressurized as specified ,

above) when operating an Emergency Makeup System at a flow rate

)

yof b 000 c? c 20% and the recirculation charcoal adsorber at a l bdweco 4000 cTm flowrate of 49,500 cfm 10%.

and (obOD c{m BYRON - UNITS 1 & 2 3/4 7-17

i

, PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

'. i

f. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in place penetration testing acceptance criteria of less than 0.05% in accordance with ANSI H510-1980 for a DOP test aerosol while operating the Emergency Makeup System at a flow rate of 5000 cfm 10%, and l

g. be$ Ween ~fcco cfm and Mc00 dm j 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 5000 cfm i 10%. -

helween %oo cfm and 4600 cfm.

h. l 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 charcoci adsorber by: .

)

(1) Verifying that the recirculation charcoal adsorber satisfies the g

)

in place penetration testing acceptance criteria of less than 2% )

total bypass and uses the test procedure guidance in Regulatory <

Positions C.S.a, and C.S.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 /

s (3) Verifying a system flow rate of 49,500 cfm 10% for'the Recircula-tion Charcoal Adsorber when tested in accordance with ANSI >

( '

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 2 a representative carbon sample obtained in accordance with Regulatory (

Position C.6.b of Regulatory Guide 1.52, Revision 2 March 197E meets '

the laboratory testing criteria of Regulatory Guide 1.52, Rev. iion 2, p March 1978 for a methyliodide penetration of less than 1% when tested at a temperature of 30 C and a relative humidity of 70%.

7 BYRON - UNITS 1 & 2 3/4 7-18

i

, PLANT SYSTEMS 3/4.7.7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent non-accessible area exhaust filter plenums (50%

capacity each) shall be OPERABLE.

APPLICABILITY: MODE 1, 2, 3, and 4.

ACTION:

With one non accessible area exhaust filter plenum inoperable, restore the inoperable plenum to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN withiri the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.7.7 Each non-accessible area exhaust filter plenum shall be demonstrated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by. initiating, from the control room, flow through the HEPA filters and chart:oal adsorbers and verifying that operation occurs for at least 15 minutes;

b. At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communi-cating with the exhaust filter plenum by:

1) Verifying that the exhaust filter plenum satisfies the in place penetration and bypass leakage testing acceptance cr'iteria of less than 1% when using the test procedure guidance in Regulatory Positions C.5.a. C.S.c and C.5.d of Regulatory Guide 1.52, Revi-sion 2, March 1978, and the flow rate is 00,200 uim 10% fe. Ce tr-ir, end 22,000 u-im _10% pcr -beniet

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample from each bank of adsorbers of the train obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing c.riteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for methyl i[odide penetration of less than 1% when tested at the I temperature of 30 C and a relative humidity of 70%: -

%% j between 55,bW cfm anc/ fo 8,200 Cfm

1. Not-app 44caMey"io" t0 July 1,198& fy ./ g ./ n e d M m e p / /c

)\

2(l0D cfm 'er bank for h inb bJakS BYRON - UNITS 1 & 2 3/4 7-19 cd elevaHen)f V59 fed ena'

!and less }han er epal h 22,000cfm 6e & ba kn at elemHon 4 51 fee +;

s

' %' ' ' ' ' , Neen 5 (ofo cfns Qnd (ok200 Cfm 0brDU)h he $d or yoa) % 2g,;00 efm pec hang g,, }fe jpro haAkS a$ eksakons.d  ;

• PLANT SYSTENS .

9 {eci 04 %7 feef and len kan or esua) h 422,600 cfl He htnk a+ clev' aron 45.1 fed '

SURVEILLANCE REQUIREMENTS (Continued)

I 3) Verifying train =aed a system flow rate E' " ^^^ "*- * * ' E .C. ther 'l 22,3004f:110"pr5-hthroughtheexh$ustfilter plenum during operation when tested in accordance with ANSI M510-1980; and Verify 4) c W _ g that with the system operati at a flow rate [of 55,000 thic qh the=tre4eend-227300 c.

through the HEPA filter and charcoal adsorbers, the total bypa flow of the system and the damper leakage is less than or equal to 1% when the system is tested by admitting ee W 00P at the systee intake and the damper leakage rate is determined by either direct measurements or pressure decay esasurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow.

c.

After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber' operation, by verifying within 31 days after removal, that a laboratory analysis of a repre,-

sentative carbon sample obtained from each bank of adsorbers of the '

train in accordance with Regulatory Position C.6.b 'of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing cri-teria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, when the average for a methyl iodide penetration of less thanof1%

humidity when tested at a temperature of 30*C and a relative 70%.

k, d. At least once per 18 months by: -

1)

Verifying for each filter bank of the train that the pressure drop across the combined HEPA filters and charcoal adsorber banks of less than 6.0 inches Water Gauge while coeratina the exhaust filter plenum at a flow rate 4f=661900=cfmT10E=tarough-the

-tech =d 22,000-efs-*1GE=per=banif; *

2) Verifying that the exhaust filter plenum starts on manual initiation or Safety Injection test signal; and 3)

Verifying that the system maintains the ECCS equi nt rooms at a negative pressure of greater than or equal to in. Water Gauge relative to the outside atmosphere during system operation while operating at a flow rateW-M,900-cfe-*1GE-through-the-

. train-end-2 h 300-cfe ^1 M per: bank.

e.

After each ccaplete or partial replacement of a HEPA filter bank, by verifying that the exhaust filter plenum satisfies the in place l penetration testing acceptance critaria of less than 1% in accord-ance with ANSI N510-1*.40 for a DOP test aerosol while cperating at a flow rata 3

-per=banV;and 9f-4b900-cfact:10%=through=tha= train-and-22 7 300-cfet10L l SH otNp14cabla=to= Unit-2-untiL 0ctobe r-1, 1987v SYRON - UNITS 1 & 2 3/4 7-20 i

7- ,

Q PLANT SYSTEMS-SURVEILLANCE REQUIREMENTS (Continued)

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the exhaust filter plenum satisfies the in place penetration testing acceptance criteria of less.than 1%

in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate ef-55,900 cf: d 1 5 thecugh the train er.d 22,300 cfm 11#4-per-ban h

$belween 55,669 c{m ayyj fp(f,gooc{m $100/1 Ibe min andhrl}nn W 'Y"I So c23 3 l% cfm peebank fo< lie fwoinnh of ekak

• 457 feel ancf '/67 feet and less -lhan or egual lo 22,000 efm for lhe bank af elevalia,, 451 feet, .

e 9

4 4

S BYRON - UNITS 1 & 2 3/4 7-21 l

g

REFUELING OPERATXONS

'.3 - SURVEILLANCE REQUIREMENTS (Continued)

1) Verifying that the Fuel Handling Building Exhaust Filter Plenum satisfies the in place penetration testing acceptance criteria of less than 1% when using the test procedure guidance in Regula-tory Positions C.5.a. C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the flow rate is 21,000 cfm 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with. Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978, and by showing a methyl ~ iodide penetration of less than 10% when tested at a temperature of 30 C and a relative humidity of 95%.

3) Verifying a flow rate of 21,000 cfm 10% through the Fuel Handling Building Exhaust Filter Plenum during operation when tested in accordance with ANSI N510-1980; and

4) Verifying that with the system operating at a flow rate of 21,000 cfm 10% and exhausting through the HEPA filters and charcoal adsorbers, the total bypass flow of the system and the leakage is less than or equal to 1% when the system is tested by injecting-seed-DOP at the system intake and the damper leakage rate is determined

^

(

by either direct measurements or pressure decay measurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow,

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, by showing a methyl iodi,de penetration of less than 10% when tested at a temperature of 30 C and a relative humidity of 95%.

d. At least once per 18 months by:

1) Verifying that the pressure drop across'the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the exhaust filter plenum at a flow rate of 21,000 cfm : 10%;

2) Verifying that on a Safety Injection or a High Radiation test signal, the system automatically starts (unless already operating) and directs its exhaust flow through the HEPA filters and charcoal adsorber banks; and BYRON - UNITS 1 & 2 3/4 9-15 l

4

1 ,

k PLANT SYSTEMS I

, SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying, within 31 days after removal, that a laboratory.

analysis of a representative carbon sample.from the Emergency. '

Makeup System 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 lodide penetration of less than 0.175% when tested at a tempera-ture of 30*C and a relative humidity of 70%; and

3) Verifying a system flow rate of 6000 cfm +-10% for the Emergency Makeup System and 49,500 cfm 110% for the Recirculation System when tested in accordance with ANSI N510-1980.

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of Emergency Makeup System operation by verify- ,

ing within 31 days after removal, that a laboratory analysis of a U representative carbon sample obtained in accordance with Regulatory  !

Position C.6.b of Regulatory Guide 1.52, Revision 2 March 1978, i!

meets the laboratory testing criteria of Regulatory Position C.6.a of It Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide 'i penetration of less than 0.175% when tested at a temperature of 30*C and a relative humidity of 70%;

e. .At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is 'less than 6.0 inches

( Water Gauge while operating the Emergency Makeup System at a ,  ;>

flow rate of 6000 cfm i 10%,

2) Verifying that on a Safety Injection or High Radiation-Control Room Outside Air Intake test signal, the system automatically  ?:

switches into a makeup mode of control room ventilation with flow through the Emergency Makeup System HEPA filters and [

charcoal adsorber banks and the recirculation charcoal adsorber; 1 3)# Verifying that the Emergency Makeup System maintains the control f room at a positive nominal pressure of greater than or equal to j; 1/8 inch Water Gauge relative to' ambient pressure in areas i adjacent to the control room area when operating an Emergency Makeup System at a flowrate of 6,000 cfm 110% and the recircula-tion charcoal adsorber at a flowrate of 49,500 cfm i 10%.

4) Verifying that the heaters dissipate-27.2 .:. 2.7 kW when tested .

in accordance with ANSI N510-1980. /--p reA r % m e p tg,zx/)

5)# Verifying that the Emergency Makeup System maintains the Upper Cable Spreading Area at a positive nominal pressure of greater than or equal to 0.02 inches Water Gauge relative to the ambient pressure in areas adjacent to the upper cable spreading area

1. Prior to 5% Rated Thermal Power (RTP), Cycle 1, these surveillance requirements tare: 3), 5) Verify that the Control Room boundary is maintained at positive

. pressure with respect to all adjacent areas.

BRAIDWOOD - UNITS 1 & 2 3/4 7-15

PLANT SYSTEMS ,

1 3/4.7.7 NON-ACCESSIBLE AREA EXHAUST FILTER PLENUM VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent non-accessible area exhaust filter plenums (50%

capacity each) shall be OPERABLE. l APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

With one non-accessible area exhaust filter plenum inoperable, restore the inoperable plenum to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE RE0VIREMENTS 4.7.7 Each non-accessible area exhaust filter plenum shall be demonstrated OPERABLE:

( a. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that operation occurs for at least 15 minutes;

b. At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communi-cating with the exhaust filter plenum by:

1) Verifying that the Exhaust filter plenum satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% when using the test procedure guidance in Regulatory .

Positions C.S.a, C.S.c and C.5.d of Regulatory Guide 1.52, Revi-sion 2, March 1978, and the flow rate is C0.000 cfm i 10", for the train and '2,000 cfm 110% per bank; . kszt,7f e, 49,3.o eM /

h/ess t% er egni to E3)oo cM

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample from each bank of adsorbers of the train 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 methyl iodide penetration of less than 1% when tested at the temperature of 30 C and a relative humidity of 70%;

• tt :ppliccbh prict t: Occc=bcr 1, 1007.

BRAIDWOOD - UNITS 1 & 2 3/4 7-17

(

[S~ 411 fo 69,300' cfm Weyls Use?

• # *P* / Y*

PLANT SYSTEMS 23s loo ofm J

SURVEILLANCE REQUIREMENTS (Continued)

3) Verifying'a system flow rate of ..,,.. ... . - ......... .... l tr;in ;nd 22,300 ;f; 11^"' per bank through the exhaust filter 1 plenum during operation when tested in accordance with ANSI N510-1980; and

4) Verifying that with the system operating at a flow rate of-50,^00

.. __. ....__,.. ... ...... .... ...... .. __ per bank and exhausting through the HEPA filter and charcoal adsorbers, the total bypass flow of the system and the damper leakage is less than or equal to 1% when the system is tested by admitting eeM DOP at the system {

intake and the damper leakage rate is determined by either direct measurements or pressure decay measurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained from each bank of adsorbers of the train in accordance with Regulatory Position C.6.b of Regulatory

~ Guide 1.52, Revision 2, March 1978, meets the laboratory testing cri-teria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision.

2, March 1978, when the average for a methyl iodide penetration of less than 1% when tested at a temperature of 30'C-and a relative humidity'of 70%.- ., ..

d. At least once per 18 months by:

-1) Verifying for each filter bank of the train that the pressure drop across the combined HEPA filters and charcoal.adsorber banks of less than 6.0 inches Water Gauge while operating the exhau -

filter plenum at a flow rate of ...... ... -

-t--i- --d 22,300 f: la*' per bank; 4

2) Verifying that the exhaust filter plenum starts on manual initiation or Safety Injection test signal; and

3) Verifying that the system maintains the ECCS equipment rooms at a negative pressure of greater than or equal to 1/4 in. Water Gauge relative to the outside atmosphere during system operation while operating at a flow rate of ... ... . . _.- .... ..... ....

....... .... ...... .. . per bank,

e. After each complete or partial replacement of a HEPA filter bank, by verifying that- the exhaust filter plenum satisfies the in place penetration testing acceptance criteria of less than 1% in accord-ance with ANSI N510-1980 for a DOP test aerosol while operating at a flow rate of ... ,.. . _, .- .... ..... .... .rei n and 22,000 cf; 1100 per bank; and BRAIDWOOD - UNITS 1 & 2 3/.4 7-18

r --

. PLANT SYSTEMS -,

\

SURVEILLANCE REQUIREMENTS (Continued) 1

f. After each complete or partial replacement'of a charcoal adsorber bank, by verifying that the exhaust filter plenum satisfies the '

in place penetration testing acceptance criteria of less than 1%

in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 55,900 cf: 11^*' through the train and 20,000 cf;;; 11% per bank.

gg,g,qito6%soodm} /ess then egual de 2 3/* *

• i.

BRAIDWOOD - UNITS 1 & 2 3/4 7-19

i REFUELING OPERATIONS

(

SURVEILLANCE REQUIREMENTS (Continued)

1) Verifying that the Fuel Handling Building Exhaust Filter Plenum satisfies the in place penetration testing acceptance criteria of less than 1% when using the test procedure guidance in Regula-tory Positions C.5.a. C.S.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the flow rate is 21,000 cfm i 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C 6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978, and by showing a methyl iodide penetration of less than 10% when tested at a temperature of 30*C and a relative humidity of 95%. <-

l:

Verifying a flow rate of 21,000 cfm i 10% through the Fuel Handling 3)' Building Exhaust Filter Plenum during operation when tested in [

cccordance with ANSI,N510-1980; and

4) Verifying that with the system operating at a flow rate of 21,000 cfm 110% and exhausting through the HEPA filters and charcoal adsorbers, the total bypass flow of the system and the leakage is less than or equal to 1% when the system is tested by injecting se44-DOP at the system intake and the damper leakage rate is determined by either direct measurements or pressure decay measurements at a test pressure of 2 inches of water and the auxiliary building exhaust fans are operating at their rated flow.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-  ;

sentative. carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a ,

I of Regulatory Guide 1.52, Revision 2, March 1978, by showing a methyl '

iodide penetration of less than 10% when tested at a temperature of 3C*C and a relative humidity of 95%.

d. At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the exhaust filter plenum at a flow rate of 21,000 cfm i 10%;

2) Verifying that on a Safety Injection or a High Radiation test signal, the system automatically starts (unless already operating) and directs its exhaust flow through the HEPA filters and charcoal adsorber banks; and BRAIDWOOD - UNITS 1 & 2 3/4 9-15

, ATTACHMENZ_B DETAILED DESCRIPTION AND

SUMMARY

The first change revises Technical Specification 3/4 7.7, Non-Accessible Area Exhaust Filter Plenum Ventilation System (VA) flowrates from 66,900 cfm i 10% for the train and 22,300 cfm i 10% per bank to between 55,669 cfm and 68,200 cfm for the train and less than or equal to 23,100 cfm

! per bank for the two banks at elevations 459 and 467 feet and less than or equal to 22,000 cfm for the bank at elevation 451 feet for Byron and from 55,671 to 69,300 cfm for the train and less than or equal to 23,100 cfm per bank for Braidwood. This change is based on the final design flowrates that have been established for the VA non-accessible exhaust filter plenums as a result of the Testing Adjusting and Balancing (TAB) of the VA System at Byron l and Braidwood Stations respectively. A modification will change the flow l controller setpoint to account for a density calculation. As a result of TAB, acceptable system performance characteristics were achieved such that the Auxiliary Building and Fuel Handling Building are maintained at a negative pressure and required ALARA and equipment qualification (EQ) parameters in non-accessible areas are maintained within limits. The basis for the operability of the non-accessible area exhaust filter plenum ventilation system ensures that radioactive materials leaking from the ECCS equipment within the pump rooms following a LOCA are filtered prior to reaching the environment. The operation of the system and its effect on offsite dosage calculations was assumed in the safety analyses. The maximum flowrate is based on 110% of filter rated capacity. The minimum per train flowrate is based on the required flow to meet ALARA and EQ parameters as determined from testing and analyses. The VA System is a shared system between Unit 1 and Unit 2. The current VA flowrates in Technical Specification 3/4 7.7 were provided before testing was completed for Unit 2. Now that the flow balance testing is completed the revised flowrates reflect the final values.

An editorial change on pages 3/4 7-19 and 7-20 for Byron and page 3/4 7-17 for Braidwood deletes the "*" and footnotes since they are no longer applicable. A typographical change on page 3/4 7-19 corrects the spelling of lodide for Byron Station.

A more accurate description of the VA System testing results by changing " cold DOP" to "DOP" on page 3/4 7-20 for Byron and page 7-18 for Braidwood. Per ANSI N510-1980, paragraph 3.9, either " cold" or " hot" DOP is acceptable for testing since both produce a polydisperse liquid aerosol with a droplet size distribution. Paragraphs 3.10 and 3.11 of the above reference describe the hot and cold DOP usages. No differentiation is needed and the deletion of the word " cold" allows testing to be performed consistent with ANSI N510-1980 requirements without an unnecessary restriction to use cold DOP. Also, for Specification 4.9.12 b.4), delete the word " cold" as a reference to DOP for the same reason as given above.

The next change is for Dyron Station only, since Braidwood has not completed the control room ventilation special differential pressure measurement test. The VC System emergency makeup system flowrate low limit has been changed from 6000 - 10% (5400) to 4000 cfm in order to allow a wider operating range due to a lower controller flowrate setpoint. The revised design flowrate is a result of the incorporation of actual airflow densities into the instrument drift considerations for the VC System. With the additional instrwnent drif t due to air density changes the flowrate controller setpoint will be changed from 6000 cfm to 5586 cfm to preclude exceeding the high limit. The maximum flowrate remains unchanged at 6000 4 10% or 6600 cfm which is 110% of the filter rated capacity. Test data and design margin analysis demonstrate that 4000 cfm will maintain a + .125 inwg pressure in the control room as required for habitability in accordance with the UFSAR and .02 inwg between the upper cable spreading room and adjacent areas (except the RC/sc1:0013V:4

.. . . - _ _ _ . /

t

• DETAILED DESCRIPTION AND

SUMMARY

(cont.)

l l

• control room). Though the revised design flowrate is within the current i Technical Specification flowrate range it has decreased in value and, thus, l reduces the margin available to the minimum limit which significantly reduces  ?

the operating margin. Therefore, to allow greater operating flexibility while maintaining design considerations the proposed change is requested.

Finally, a change is proposed for Specification 4.7.6.e.4) for Byron and Braidwood to verify the heater dissipates greater than or equal to 21.1 kW rather than 27.2 1 2.7 kW. ANSI N-509 requires that the heater be sized to limit the relative humidity of the air stream entering the adsorbers to approximately 70% RH at the design flowrate. An engineering evaluation was performed that determined the minimum heater capacity required is 21.1 kW.

l RC/sc1:0013V 5

v"- - - ' - , , - - , . ~ , , , -- ,

LL '

h32AN 9

• EVALUATION OF SIGNIFICANT HAZARD CONSIDERATIONS

^

Commonwealth Edison has evaluated the proposed amendment and determined that it involves no significant hazards' consideration. According to 10CFR50.92(c), a proposed snendment to an operating license involves no significant hazards considerations if operation of the_ facility in accordance with the proposed amendment would not

1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or l

2. Create the possibility of a new or different kind of accident from l any accident previously evaluated; or i

3. Involve a significant reduction in margin of safety. l l

The proposed snendment makes several changes to Technical Specifications. Thece changes are the 1) VA flowrates, 2) correction of a j typographical error, 3) the deletion of the word " cold" when describing the DOP used for VA system testing, 4) the changes in the VC flowrates for Byron Station, 5) the deletion.of a footnote that is no longer applicable, and 6) l6 the change in heater dissipation rate.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. The VA j non-accessible area ventilation system will be operated as described in the j design and intent of the,UFSAR. The VA non-accessible area ventilation system bases is to ensure that radioactive materials, leaking from the ECCS equipment i within non-accessible pump rooms'following a LOCA, are filtered prior to

' reaching the. environment. Though UFSAR changes will be required to reflect the proposed flowrates, the bases remains satisfied. The VC proposed flowrate l change ensures that a pressure of greater than or equal to 1/8 inch water )

gauge relative to ambient pressure in areas adjacent to the control room, and j

.02 inch water gauge relative to the Upper Cable Spreading Room and adjacent l areas (except the control room), are maintained. This is consistent with the l design and intent of the UFSAR, however, the proposed flowrates will need to  !

be reflected in the UFSAR. The bases for the VC System is satisfied such that  !

the allowable temperatures will be maintained in the control room and the  ;

control room will be maintained habitable for operations personnel during and  !

following all credible accident conditions. Deletion of the word " cold" from !

the description of DOP used in testing has no effect on the VA System  !

operation per UFSAR design and/or analysis and has no significant l consequences. The change removes an overly conservative restriction and l revises Technical Specifications to allow testing consistent with ANEI l N510-1980. The typographical correction does not affect any accident. The i deletion of the footnote has no effect on any accident since the footnote is l' no longer applicable.

l The Control Roam Emergenc} Make-Up Air Filter Unit heaters were i designed to comply with ANSI N-509 and Regulatory Guide 1.52-1976 requirements of limiting the relative humidity (RH) entering the carbon adsorbers to 70% Ril at the design flowrote. The heater performance was evaluated considering a main stemn line break (MSLB) accident and a loss of coolant accident (LOCA). l The heaters are not required for the MSLB accident since only a fractica of a 1 percent of lodine removal efficiency for the carbon adsorbers is needed to reduce the postulated Control Room thyroid dose below 10CFR50, Appendix A, {

GDC-19 limits. For the LOCA, air conditions were assumed to conservatively l i

l 1

RC/sc1:0013V:6 ,

l

. EVALUATION OF SIGNIFICANT HAZARD CONSIDERATIONS (cont.)

reflect atmospheric conditions. It was determined that the relative hunidity can be limited to approximately 70% with a heater capacity of 21.1 kW. The proposed Technical Specification change is consistent with this determination, l

therefore, the probability and consequences of an accident remain unaffected.

The proposed changes do not create the possibility of a new or different kind of accident from any previous analyzed. The new VA flowrates are a result of the Testing Adjusting and Balancing (TAB) or' the VA System and achieved acceptable system performance characteristics per system design as outlined in the UFSAR though the UFSAR flowrates need to be changed. All cooling requirements, as well as pressure requirements, are maintained per the design and intent of the UFSAR as described in the bases for the VA non-accessible area system which is to ensure the system operability such that radioactive materials leaking from the ECCS equipment within the pwnp rooms following a LOCA are filtered prior to reaching the environment. The VC flowrates are changed due to a need for an increased range after actual air densities were considered for instrument drift. The changed airflow meets the requirement to maintain greater than or equal to 4.125 inch Water Gauge (inwg)

Jn the control room and .02 inwg between the upper cable spreading room and adjacent area (except the control room). The bases for the VC System remains satisfied as the allowable temperatures will be maintained in the control room, and the control room will be maintained habitable for operations personnel during and following all credible accident conditions. The deletion of the word " cold" from the DOP description has no effect on system operation per UFSAR design and/or analysis and thus has no effect on the significant hazards considerations. The typographical correction has no effect on any accident. The deletion of the footnote, which is no longer applicable, has no l effect on the creation of any accident. The change to required heater capacity is based upon analysis which establishes a minimwn heater capacity that envelopes the accident analysis results. Since no new equipment is being added or control changes being performed, the possibility of a new or different kind of accident is not created.

The proposed changes do not involve a significant reduction in the margin of safety. The VA System flowrates as a result of the TAB will still maintain all ECCS pump room pressures as required. The bases for Technical Specification 3/4 7.7 will be met as the system has been balanced, such that the airflows provide negative pressures in the Auxiliary Building and Fuel Handling Building and ensure that ALARA and EQ parmneter s are maintained in j accordance with the UFSAR. This ensures that all radioactive materials leaking f rom ECCS equipment in the pump rooms following a LOCA are filtered prior to reaching the environment. Thus the VA flowrates will be revised in i accordance with Byron and Braidwood specific system performance j characteristics and analysis. The VC system flowrate change still ensures that control room pressure reinains within the botodary for control room habitability per Technical Specification 3/4 7.S bases. This provides for the ,

bases being sctisfied in that the allowable temperatures in the control room will be maintained and the control room will remain habitable for operations potsonnel during and following all accident conditions. The deletion of the word " cold" from the DOP description changes have no effect on the margin of l safety for Technical Specification 3/4 7.7 and 3/4 9.12 as described in their bases.

i RC/sc1:0013Vt7 l

t i.

P

• EVALUATION OF SIGNIFICANT HAZARD CONSIDERATIONS (cont.)

.. 1 1

The typographical correction has no effect on the margin of safety. The I deletion of the footnote, which is no longer applicable, has no effect on the l' margin of safety. The Technical Specification Bases states that operation of the system with the heaters operating for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The proposed change limits the relative humidity entering the adsorbers to 70% in accordance with ANSI N-509 and Regulatory Guide 1.52-1976 design requirements. Therefore the margin of safety is not affected.

Therefore, based upon the above analysis, Commonwealth Edison concludes that t he proposed amendments to the Technical Specification does not involve a significant hazards consideration.

1 I

RC/sc1:0013V:8 1

,O'

o

• EVALUATION OF SIGNIFICANT HAZARD COMSIDERATICWS (cont.)

1 The typographical correction has no effect on the margin of safety. The deletion of the footnote, which is no longer applicable, has no effect on the margin of safety. The Technical Specification Bases states that operation of the system with the heaters operating for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The proposed change limits the relative humidity entering the adsorbers to 70% in accordance with ANSI N-509 and Regulatory Guide 1.52-1976 design requirements. Therefore the margin of safety is not affected.

Therefore, based upon the above analysis, Commonwealth Edison concludes that the proposed amendments to the Technical Specification does not involve a significant hazards consideration.

RC/sc1:0013V:8

_ _ - _ _ _ _ _ _ . . _ . >