ML20138G117

Proposed Tech Specs 4.7.2.b & 4.7.2.c Revising Surveillance Requirements to Require Testing of Control Room Emergency Ventilation Sys Charcoal & Revising Acceptance Criteria for Subject Charcoal Testing

ML20138G117
Person / Time
Site:	Brunswick
Issue date:	04/30/1997
From:	CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20138G115	List: BSEP-97-0168, Application for Amends to Licenses DPR-71 & DPR-62,revising Surveillance Requirements to Require Testing of Control Room Emergency Ventilation Sys Charcoal & Revising Acceptance Criteria for Subject Charcoal Testing ML20138G117
References
NUDOCS 9705060179
Download: ML20138G117 (17)

Text

.. . -

PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM l SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory

, analysis of a representative carbon sample obtained in l- accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 1976,W eet the l ee-stery t+stk.g criteri: +f Paguhtcry P0: !ticr. C.S.: Of "cguhtery cui& !.52, "r.i:ic 1,Jul.r47(jr

! 3. Verifying a system flow rate of 2000 cfm i10% during i system operation when tested in accordance with ANSI N510- j 1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying

{

i within 31 days after removal that a laboratory analysis of a  ;

representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 19pmaats o ccitim.6.2 the inher2+nry +me+4e; criter n 25 n;;uletery-ef Reguhtery Cuit 1.5,

]

[ "r. !

br 1, July 1075. ,

! d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is s 5.25 inches Water l j Gauge while operating the filter train at a flow rate of 4 2000 cfm 10%.

2. Verifying that on a smoke detector or control room

, ventilation system high radiation test signal, the control

} building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.

3. Verifying that on a chlorine detector test signal, the control building ventilation system automatically isolates and the control room emergency filtration system cannot be started by a smoke detector or control room ventilation

. system high radiation test signal.

l 4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during

system operation.

t y

and tested at 30.010.2 C and 93.0 to 96.0% relative humidity in accordance with th methodology provided by ASTM D38031989, meets the acceptance criteria of <

pene* cation of methyliodide.

9705060179 970430 '

. PDR ADOCK 05000324 P PDR BRUNSWICK - UNIT 1 3/4 7-4 Amendment No. 161

a PLANT SYSTEMS 4 BASES 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Surveillance Reouirements .

The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a subsystem in the standby mode starts on demand and continues to operate.

Standby systems are checked periodically to ensure that the automatic start 3 function is consistent with the assumptions in the Control Room Habitability Analyses (References 4 and 6). Since the environmental conditions on this

~

system are not severe, monthly demonstration of the capability of the system i

to operate by SR 4.7.2.a is considered adequate. The 2 15 minute run time is considered adequate for operation of systems without heaters (Reference 16).

Replace with Asar+f r" ' 7.2.b verifics the co bility cf the filtration system at lc :t cn 0

. or 1) fol$owing any structural maintenance on t E very vior (l nit HEPA filter coal adsorbers or 2) followin , fire, or chemical release in any v ion zone co on with the system.

T esting is performed in accordance icable sections of Regulatory Guide 1.52, Revision 1. 510 1975. ance criteria provides  ;

~

assurance that iciency used in the Control Roo analyses is  !

conse L

. This is consistent with the guidance provided 1 ic  ;

av Q1.19 (Dafaranra TA l l 4

SR 4.7.2.c verifies adequacy of the charcoal filtration system following every I 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The time of operation is based on the recommendations ,

1 of Regulatory Guide 1.52, Revision 1 (Reference 8), and early nuclear plant 1 i- filter testing (Reference 10).

SR 4.7.2.d demonstrates functional capability of the system by verifying

1) pressure drop across the HEPA and charcoal filtration units, 2) automatic

emergency system initiation upon receipt of a smoke detector or high radiation

. . test signal, 3) the override function of the chlorine protection function, and

4) ability of the system to maintain a positive pressure relative to the 2

outside atmosphere during system operation. The maximum pressure drop of s 5.25 inches water gauge is based on a CREVS pressure drop analysis (Reference 9) and fan capability. This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water gauge margin for 1

, filter loading. The positive pressure test is performed to ensure that the '

control room is maintained positive to any potentially contaminated external atmosphere, including the outside atmosphere and adjacent building ,

atmosphere (s). Testing of the chlorine override function ensures operability i of the chlorine protection mode of the CREVS by demonstrating the capability of the system to prevent the emergency filtration units from initiating during i 3 a chlorine event.

SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control Room Habitability Analyses (References 4 and 6) following partial or complete replacement of either filtration component. The testing is performed in accordance with the applicable sections of ANSI N5101975 (Reference 14).

BRUNSWICK - UNIT 1 B 3/4 7 lh Amendment No. 164 l

Insert A SR 4.7.2.b verifies the capability of the filtration system at least once every 18 months, or 1) following any structural maintenance on the filtration unit HEPA filter or charcoal adsorbers or 2) following painting, fire, or chemical release in any ventilation zone communicating with the system. Field testing is performed in accordance with applicable sections of Regulatory Guide 1.52, Revision 1, and ANSI N510-1975. The use of Regulatory Guide 1.52, Revision 1 and ANSI N510-1975 is consistent with the guidance provided in Generic Letter 83-13 (Reference 7). Charcoal samples for laboratory testing are obtained per the applicable sections of Regulatory Guide 1.52, Revision 1. The laboratory testing is performed in accordance with the methodology in ASTM D3803-1989 (Reference 17). ASTM D3803-1989 is a more current testing standard which was developed after the Generic Letter 83-13. It contains criteria for use with charcoal beds with no humidity control, this is consistent with the design of the CREV system. The acceptance criteria used for the laboratory test is < 5.0%

penetration of methyliodide (Reference 18) . This corresponds to a 90% filtration efficiency which is the filtration efficiency assumed in the bounding calculations of control room doses. As such, the acceptance criteria of < 5.0% penetration of methyl iodide ensures that General Design Criterion 19 dose limits for control room operators ,

are not exceeded. l l

l l

l

PLANT SYSTEMS BASES l 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

References

1. 10 CFR 50, Appendix A, General Design Criterion 19. Control Room.

2. Regulatory Guide 1.95, Revision 1. Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.

3. Updated FSAR, Brunswick Steam Electric Plant, Units 1 & 2.

4. NUS-3697, Revision 2, February 1983, Control Room Habitability Analysis.

5. NLU 83 673 TMI Action Item III.D.3.4 Control Room Habitability, NRC Safety Evaluation dated October 18, 1983.

l

6. NUS 4758, Control Room Radiological Reanalysis August,1985.

7. Generic Letter 8313, Clarification of Surveillance Requirements for 1 HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications of ESF Cleanup Systems, March 2,1983. l

8. Regulatory Guide 1.52, Revision 1. July 1976, '

9. CP&L Calculation G0077A 01, Control Room Emergency Filter System Differential Pressure Analysis.

10. Original FSAR BSEP, Units 1 and 2 Appendix K.

11. IEEE 279 1971, IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.

12. DBD 37, Design Basis Document for Control Building Heating, Ventilation, and Air Conditioning System.

13. NRC-89 103, NRC Safety Evaluation for Control Room Habitability, i February 16, 1989.

l

14. ANSI N510 1975, Testing of Nuclear Air Cleaning Systems.

15. ANSI N509-1976, Nuclear Power Plant Air Cleaning Units.

~

16. NUREG-1433, Standard Technical Specifications, General Electric Plants.

BWR/4, Revision 0, September 28, 1992.

l7, $Tf1 D3203-f%9(%pmuc ids') 54 wand Test @t)df;p

/Jvckar Grade Ad;wned Grhon ,,

12. EsR '77-Ooo72 ewsw g, Chm,=wl TEs+;3 % CBer1R p Asrn m@3-RW.

BRUNSWICK UNIT 1 B 3/4 7-li Amendment No. 164 l

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- W8 ^*4& Ja-A 2 ,4.Ja- -mA-4=M k - *e+-< -*-w- ai E6 , 4mEq =-- A-4-n- - beewa-e t

i .

ENCLOSURE 6

'; BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 3 REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM CHARCOAL TESTING REQUIREMENTS 2

1 j MARKED-UP TECHNICAL SPECIFICATION PAGES - UNIT 2 l

t f

I.

i i  !

T l

2 4

A i

4 v

m _

PLANT SYSTEMS 3 /4 . 7 .'2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM l l

SURVEILLANCE REQUIREMENTS (Continued) 1 l

2. Verifying within 31 days after removal that a laboratory I analysis of a representative carbon sample obtained in  !

accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 1976,%e*+e +ha 1'her tery tc:tir.;, crit:ri: Of 9:g W tery %: itic" C.E.: ef 9 ; i tary i i

Cuide 1.5?, ogv4-icr 1, July 1^73 l

1

3. Verifying a system flow rate of 2000 cfm 10% during system operation when tested in accordance with. ANSI N510-1975.

I I

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 j within 31 days after removal that a laboratory analysis of a representative carto, sample obtained in accordance with l Regulatory Positi:>r. C.6.b of Regulatory Guide 1.52, Revision 1, July 1976,W ^^+e +"a l'har'+^*" +^e+4"" ~4t -!: ef Reg &tcry

?;;itier C M.: ef Regehtery Cuide 1.52, 90.i:i:r.1, July 1^70. l

_a

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA

, filters and charcoal adsorber banks is 5 5.25 inches Water [

. Gauge while operating the filter train at a flow rate of 2000 cfm i 10%.

1 2. Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of  ;

the emergency filtration system.

3. Verifying that on a chlorine detector test signal, the control building ventilation system automatically isolates and the control room emergency filtration system cannot be started by a smoke detector or control room ventilation system high radiation test signal.

4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.

Y and tested at 30.010.2* C and 93.0 to 96.0% relative humidity in accordance with the L_ methodology provided by ASTM D3803-1989, meets the acceptance criteria of < 5.0%

penetration of methyliodide.

i 6 BRUNSWICK - UNIT 2 3/4 7-4 Amendment No. 192-

.g l PLANT SYSTEMS l BASES h.-

i 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) i Surveillance Reouirements

The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a

subsystem in the standby mode starts on demand and continues to operate.

Standby systems are checked periodically to ensure that the automatic start .

function is consistent with the assumptions in the Control Room Habitability Analyses (References 4 and 6). Since the environmental' conditions on this system are not severe, monthly demonstration of the capability of the system l to operate by SR 4.7.2.a is considered adequate. The 2 15 minute run time is  !

considered adequate for operation of systems without heaters (Reference 16).

(thplace zo;fA. .rh.er-f 6

" ' .7.2.b acific th:. =-di'it; :f th: "'trati: :;:t :t !c :t ent -

every s, or 1) folIowing any structural maintenance on .tleJrhr$6or l u..it HEPA filte rcoal adsorbers or 2) followin g, fire, or i ' :hemical release in any v on zone con on with the . system.

resting is performed in accordance licable sections of Regulatory Guide 1.52, Revision 1, a a10 1975. nce criteria provides issurance that t .

ciency used in the Control Room nalyses is

onser .

This is consistent with the guidance provided in '

w N r 83 13 Ocference 7;.

SR 4.7.2.c verifies adequacy of the charcoal filtration system following every c

720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The time of operation is based on the recommendations of Regulatory Guide 1.52, Revision 1 (Reference 8), and early nuclear plant filter testing (Reference 10).

SR 4.7.2.d demonstrates functional capability of the system by verifying  :

1) pressure drop across the HEPA and charcoal filtration units, 2) automatic emergency system initiation upon receipt of a smoke detector or high radiation test signal, 3) the override function of the chlorine protection function, and ,

4) ability of the system to maintain a positive pressure relative to the outside atmosphere during system operation. The maximum pressure drop of 5 5.25 inches water gauge is based on a CREVS pressure drop analysis

-(Reference 9) and fan capability. This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water gauge margin for filter loading. The positive pressure test is performed to ensure that the control room is maintained positive to any potentially contaminated external atmosphere, including the outside atmosphere and adjacent building atmosphere (s). Testing of the chlorine override function ensures operability of the chlorine protection mode of the CREVS by demonstrating the nability rP the system to prevent the emergency filtration units from initiating during a chlorine event.

SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control l Room Habitability enalyses (References 4 and 6) following partial or complete replacement of eWaer filtration component. The testing is performed in accordance with we applicable sections of A*lSI N5101975 (Reference 14). '

BRUNSWICK UNIT 2 -

B 3/4 7 lh Amendment No. 195 l l

(

i insert A SR 4.7.2.b verifies the capability of the filtration system at least once every 18 months, or 1) following any structural maintenance on the filtration unit HEPA filter or charcoal adsorbers or 2) following ps.inting, fire, or chemical release in any ventilation zone

, communicating with the system. Field testing is performed in accordance with applicable sections of Regulatory Guide 1.52, Revision 1, and ANSI N510-1975. The use of Regulatory Guide 1.52, Revision 1 and ANSI N510-1975 is consistent with the

guidance provided in Generic Letter 83-13 (Reference 7). Charcoal samples for laboratory testing .~e obtained per the applicable sections of Regulatory Guide 1.52, l 4 Revision 1. The laboratory testing is performed in accordance with the methodology in ' '

ASTM D3803-1989 (Reference 17). ASTM D3803-1989 is a more current testing standard which was developed after the Generic Letter 83-13. It contains criteria for use with charcoal beds with no humidity control, this is consistent with the design of the CREV system. The acceptance criteria u ;ed for the laboratory test is < 5.0%

penetration of methyl iodide (Reference 18) . This corresponds to a 90% filtration efficiency which is the filtration efficiency assumed in the bounding calculations of control room doses. As such, the acceptance criteria of < 5.0% renetration oi methyl iodide ensures that General Design Criterion 19 dose limits for control room operators

, are not exceeded.

y I

I a

s i

e

• 4 PLANT SYSTEMS i

, BASES

j. \

3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) i References

1. 10 CFR 50, Appendix A, General Design Criterion 19, Control Room.

2. Regulatory Guide 1.95, Revision 1, Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.

l I

3. Updated FSAR, Brunswick Steam Electric Plant, Units 1 & 2.

4. NUS 3697, Revision 2, February 1983, Control Room Habitability Analysis.

i

5. NLU-83-673, TMI Action Item III.D.3.4 - Control Room Habitability, NRC Safety Evaluation dated October 18, 1983.

! 6. NUS 4758, Control Room Radiological Reanalysis, August,1985.

7. Generic Letter 8313, Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications of ESF Cleanup Systems, March 2,1983.

! 8. Regulatory Guide 1.52, Revision 1, July 1976,

9. CP&L Calculation G0077A 01, Control Room Emergency Filter System b Differential Pressure Analysis.

10. Original FSAR, BSEP, Units 1 and 2, Appendix K.

11. IEEE 279-1971, IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.

12. DBD 37, Design Basis Document for Control Building Heating, Ventilation, and Air Conditioning System.

13. NRC-89103, NRC Safety Evaluation for Control Room Habitability, February 16, 1989.

14. ANSI N510 1975. Testing of Nuclear Air Cleaning Systems.

i 15. ANSI N509 1976 Nuclear Power Plant Air Cleaning Units.

l 16. NUREG 1433, Standard Technical Specifications, General Electric Plants, l BWR/4, Revision 0. September 28, 1992.

17. AMr1 OMo3-19Er9 (%pprmed (Th), Sta& cud T5+ fletkccif*-

idockrw -Gewle Acdiwded Gwkm.

\ l9. EsQ 97-0007e kistoa e CtaeccarTEs+ng4rCMRfpec Afli W GRQ3-/7I/, I h

BiWNSWICK - UNIT 2 B 3/4 7 li Amendment No. 195 l t

l n

! ENCLOSURE 7 1

BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 j OPERATING LICENSE NOS. DPR-71 AND DPR-62

! REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM

CHARCOAL TESTING REQUIREMENTS TYPED TECHNICAL SPECIFICATION PAGES - UNIT 1

+ .

. =

PLANT SYSTEMS 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTFE l SURVEILLANCE REQUIREMENTS (Continued) l I

2. Verifying within 31 days after removal that a laboratory l

analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1. July 1976, and tested at 30.0 0.2 C and 93.0% to 96.0% relative humidity in accordance with the methodology provided by ASTM D3803-1989. meets the acceptance criteria of < 5.0% penetration of methyl iodide.

3. Verifying a system flow rate of 2000 cfm 10% during system operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1.

July 1976, and tested at 30.0 0.2 C and 93.0% to 96.0% relative humidity in accordance with the methodology provided by ASTM D3803-1989, meets the acceptance criteria of < 5.0% penetration of methyl iodide.

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is 5 5.25 inches Water Gauge while operating the filter train at a flow rate of 2000 cfm 10%.

1

2. Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system.  !

i

3. Verifying that on a chlorine detector test signal, the )

control building ventilation system automatically isolates  !

and the control room emergency filtration system cannot ba l started by a smoke detector or control room ventilation i system high radiation test signal.

4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system cperation.  !

l I

l l

1 l

BRUNS C K - UNIT 1 3/4 7-4 Amendment No.

PLANT SYSTEMS

. BASES i

3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued) l Surveillance Reauirements The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a subsystem in the stand mode starts on demand and continues to operate.

Standby systems are ch ked periodically to ensure that the automatic start function is consistent with the assumptions in the Control Room Habitability Analyses (References 4 and 6). Since the environmental conditions on this system are not severe. monthly demonstration of the capability of the system to operate b SR 4.7.2.a is considered adequate. The 2 15 minute so time is considered a equate for operation of systems without heaters (Reference 16).

SR4.7.2.b verifies the capability of the filtration system at least once every l 18 months. or 1) followin structural maintenance on the filtration unit HEPA filter or charcoal a s ers or 2) following painting, fire, or chemical release in any ventilation zone communicating with the system. Field testing is performed in accordance with a licable sections of Re ulatorv Guide 1.52.

Revision 1. and ANSI N510-1975. e use of Regulatory Gu de 1.52. Revision 1 and ANSI N510-1975 is consistent with the guidance provided in Generic Letter 83-13 (Reference 7). Charcoal samples for laboratory testing are obtained per the applicable sections of Regulatory Guide 1.52. Revision 1. The laboratory testing is performed in accordance with the methodology in ASTM D3803-1989 (Reference 17). ASTM D3803-1989 is a more current testing standard which was i

developed after the Generic Letter 83-13. It contains criteria for use with l charcoal beds with no humidity control, this is consistent with the design of l the CREV system. The acce tance criteria used for the laboratory test is  !

< 5.0% penetration of meth 1 iodide (Reference 18). This corresponds to a 90% l filtration efficiency whic is the filtration efficiency assumed in the i bounding ~ calculations of control room doses. As such, the acceptance criteria ;

of < 5 penetration of methyl iodide ensures that General Design Criterion l 19 dose limits for control room operators are not exceeded.

SR 4.7.2.c verifies adequacy of the charcoal filtration system following every I 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The time of operation is based on the reconmcndations of Regulatory Guide 1.52. Revision 1 (Reference 8), and early nuclear plant filter testing (Reference 10).

SR 4.7.2.d demonstrates functional capability of the system by verifying

1) pressure drop acro.ss the HEPA and charcoal filtration units. 2) automatic emergency system initiation upon receipt of a smoke detector or high radiation test signal. 3) the override function of the chlorine protection function and

4) ability of the system to maintain a positive pressure relative to the outside atmosphere during system operation. The maximum pressure drop of

< 5.25 inches water gauge is based on a CREVS pressure drop analysis TReference 9) and fan capability. This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water gauge margin for filter loading. The positive pressure test is performed to ensure that the control room 1s maintained positive to any potentially contaminated external atmosphere, including the outside atmosphere and adjacent building atmosphere (s). Testing of the chlorine override function ensures operability of the chlorine protection made of the CREVS by demonstrating the capability of the system to prevent the emergency filtration unit.s from initiating dur'ing a chlorine event.

SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control Room Habitability Analyses (References 4 r.M 6) following partial or complete replacement of either filtration componer.t. The testing is performed in accordance with the applicable sections 'f ANSI N510-1975 (Reference 14).

BRUNSWICK - UNIT 1 B 3/4 7-lh Amendment No.

~.e 1

ENCLOSURES l BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS,1 AND 2 i NRC DOCKET NOS. 50-325 AND 50-324  !

, OPEPATING LICENSE NOS. DPR-71 AND DPR-62 l_ REQUEST FO.R LICENSE AMENDMENTS l CONTROL ROOM EMERGENCY VENTILATION SYSTEM ,

i CHARCOAL TESTING REQUIREMENTS 1 i i  ;

l l l

TYPED TECHNICAL SPECIFICATION PAGES - UNIT 2 j l l I

(

l .. 1 i i

A NT SYSTEMS

.P_L_.

3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM '

SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in 3

3 accordance with Regulatory Position C.6.b of Regulatory

• Guide 1.52. Revision 1. July 1976, and tested at 30.0 0.2 C and 93.0% to 96.0% relative humidity in accordance with the methodology provided by ASTM D3803-1989, meets the acceptance criteria of < 5.0% penetration of methyl iodide.

3. Verifying a system flow rate of 2000 cfm 10% during system operation when tested in accordance with ANSI N510-1975.

c. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying within 31 days after removal that a laboratory analysis of a representatise carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 1.

July 1976, and tested at 30.0 0.2 C and 93.0% to 96.0% relative i humidity in accordance with the methodology provided by ASTM 03803-1989. meets the acceptance criteria of < 5.0% penetration of ,

methyl iodide.

d. At least once per 18 months by:

1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is s 5.25 inches Water

• Gauge while operating the filter train at a flow rate of 2000 cfm 10%. ,

2. Verifying that on a smoke detector or control room ventilation system high radiation test signal, the control building ventilation system automatically diverts its inlet flow through the HEPA filters and charcoal adsorber banks of the emergency filtration system. .

3. Verifying that on a chlorine detector test signal the control building ventilation system automatically isolates and the control room emergency filtration system cannot be started by a smoke detector or control room ventilation system high radiation test signal.

4. Verifying that the system maintains the control room at a positive pressure relative to the outside atmosphere during system operation.

BRUNSWICK - UNIT 2 3/4 7-4 Amendment No.

l

- a PLANT SYSTEMS BASES 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTF2 (Continued)

References

1. 10 CFR 50. Appendix A. General Design Criterion 19. Control Room.

2. Regulatory Guide 1.95. Revision 1. Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.

3. Updated FSAR. Brunswick Steam Electric Plant, Units 1 & 2.

4 NUS-3697. Revision 2. February 1983. Control Room Habitability Analysis.

5. NLU-83-673 TMI Action Item III.D.3.4 - Control Room Habitability, NRC Safety Evaluation dated October 18, 1983.

6. NUS-4758. Control Room Radiological Reanalysis. August, 1985.

7. Generic Letter 83-13. Clarification of Surveillance Requirements for HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications of ESF Cleanup Systems. March 2.1983.

8. Regulatory Guide 1.52. Revision 1. July 1976.

9. CP&L Calculation G0077A-01. Control Room Emergency Filter System Differential Pressure Analysis.

10. Original FSAR. BSEP Units 1 and 2. Appendix K.

11. IEEE 279-1971. IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.

12. DBD-37. Design Basis Document for Control Building Heating. Ventilation.

and Air Conditioning System.

13. NRC-89-103 NRC Safety Evaluation for Control Room Habitability.

February 16, 1989.

]

14. ANSI N510-1975. Testing of Nuclear Air Cleaning Systems.

15. ANSI N509-1976. Nuclear Power Plant Air Cleaning Units.

I

16. NUREG-1433. Standard Technical S BWR/4. Revision 0. September 28.pecifications. General Electric Plants.

1992.

17. ASTM D3803-1989 (Reapproved 1995). Standard Test Method for Nuclear-Grade Activated Carbon.

18. ESR 97-00078 Revision 1. Charcoal Testing for CBEAF par ASTM D3803-1989.

1 BRUNSWICK - UNIT 1 B 3/4 7-li Amendment No.

i PLANT SYSTEMS

. BASES' i

4 3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

Surveillance Reauirements l

l The SURVEILLANCE REQUIREMENTS (SR) in this specification verify that a i subsystem in the standby mode starts on demand and continues to operate. l Standby systems are checked periodically to ensure that the automatic start  :

function is consistent with the assumptions in the Control Room Habitability 1 Analyses (References 4 and 6). Since the environmental conditions on this system are not severe, monthly demonstration of the capability of the system to operate by SR 4.7.2.a is considered adequate. The 2 15 minute run time is considered adequate for operation of systems without heaters (Reference 16).

SR4.7.2.b verifies the capability of the filtration system at least once every 18 months, or 1) following any structural maintenance on the filtration unit l

J HEPA filter or charcoal adsorbers or 2) following painting fire, or chemical  ;

release in any ventilat; ion zone communicating with the system. Field testing 1 is performed in accordance with applicable sections of Regulatory Guide 1.52. l Revision 1. and ANSI N510-1975. The use of Regulatory Guide 1.52. Revision 1 and ANSI N510-1975 is consistent with the guidance provided in Generic Letter 83-13 (Reference 7). Charcoal samples for laboratory testing are obtained per  !

the applicable sections of Reaulatory Guide 1.52. Revision 1. The laboratory '

testing is performed in accordance with the methodology in ASTM D3803-1989  ;

(Reference 17). ASTM D3803-1989 is a more current testing standard which was developed after the Generic Letter 83-13. It contains criteria for use with I charcoal beds with no humidity control. this is consistent with the design of '

the CREV system. The acce tance criteria used for the laboratory test is

< 5.0% penetration of meth 1 iodide (Reference 18). This corresponds to a 90%

filtration efficiency whic is the filtration efficiency assumed in the calculations of control room doses. 1 bounding of < 5.0 % penetration of methyl iodide ensures that General Design CriterionAs such, t 19 dose limits for control room operators are not exceeded.

SR 4.7.2.c verifies adequacy of the charcoal filtration system following every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The time of operation is based on the recommendations of Regulatory Guide 1.52. Revision 1 (Reference 8), and early nuclear plant filter testing (Reference 10).

SR 4.7.2.d demonstrates functional capability of the system by verifying

1) pressure drop across the HEPA and charcoal filtration units. 2) automatic emergency system initiation upon receipt of a smoke detector or high radiation test signal. 3) the override function of the chlorine protection function, and

4) ability of the system to maintain a positive pressure relative to the i outside atmosphere during system operation. The maximun pressure drop of

< 5.25 inches water gauge is based on a CREVS pressure drop analysis <

TReference 9) and fan capability. This maximum pressure drop ensures the system is capable of delivering rated flow with 1 inch water g6uge margin for ,

filter loadina. The positive pressure test is performed to ensure that the '

control room is maintained positive to any potentially contaminated external atmosphere, including the outside atmosphere and adjacent building '

atmosphere (s). Testing of the chlorine override function ensures operability of the chlorine protection mode of the CREVS by demonstrating the capability of the system to prevent the emergency filtration units from initiating during a chlorine event.

SR 4.7.2.e and SR 4.7.2.f verify that the filtration capability of the HEPA and charcoal adsorber banks is consistent with that assumed in the Control Room Habitability Analyses (References 4 and 6) following par +,ial or complete replacement of either filtration component. The testina is performed in accordance with the applicable sections of ANSI N510-1975 / Reference 14).

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PLANT SYSTEMS BASES '

3/4.7.2 CONTROL ROOM EMERGENCY VENTILATION SYSTEM (Continued)

References

1. 10 CFR 50. Appendix A. General Design Criterion 19. Control Room.

2. Regulatory Guide 1.95. Revision 1. Protection of Nuclear Power Plant Control Room Operators Against an Accidental Chemical Release.

3. Updated FSAR. Brunswick Steam Electric Plant. Units 1 & 2.

4. NUS-3697. Revision 2. February 1983. Control Room Habitability Analysis. I 1

5. NLU-83-673 TMI Action Item III.D.3.4 - Control Room Habitability. NRC l Safety Evaluation dated October 18, 1933.  !

6. NUS-4758. Control Room Radiological Reanalysis. August. 1985. .

1

7. Generic Letter 83-13. Clarification of Surveillance Requirements for l HEPA Filters and Charcoal Adsorber Units in Standard Technical Specifications of ESF Cleanup Systems. March 2.1983. J

8. Regulatory Guide 1.52. Revision 1. July 1976. l

9. CP&L Calculation G0077A-01. Control Room Emergency Filter System l Differential Pressure Analysis.

10. Original FSAR. BSEP. Units 1 and 2. Appendix K

11. IEEE 279-1971. IEEE Criteria for Protection Systems for Nuclear Power Generating Stations.

12. DBD-37. Design Basis Document for Control Building Heating. Ventilation, and Air Conditioning System.

13. NRC-89-103. NRC Safety Evaluation for Control Room Habitability.

February 16, 1989.

14. ANSI N510-1975. Testing of Nuclear Air Cleaning Systems.

15. ANSI N509-1976. Nuclear Power Plant Air Cleaning Units.

16. NUREG-1433. Standard Technical Specifications. General Electric Plants.

BWR/4. Revision 0. September 28, 1992.

17. ASTM D3803-1989 (Reapproved 1995). Standard Test Method for Nuclear- 'l Grade Activated Carbon.

18. ESR 97-00078 Revision 1. Charcoal Testing for CBEAF per ASTM D3803-1989.

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