ML20086M154

Proposed Tech Specs Re Support for 24-month Fuel Cycle Surveillance Extensions for Unit 3

ML20086M154
Person / Time
Site:	Millstone
Issue date:	07/17/1995
From:	NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20086M153	List: B15263, Application for Amend to License NPF-49.Amend Would Support 24-month Fuel Cycle Surveillance Extensions for Unit 3 ML20086M154
References
NUDOCS 9507240154
Download: ML20086M154 (57)

Text

__. . _ _ _ _ . . - _ _ . _ __

January 3,1995 p > t. "1 M CONTAINMENT SYSTEMS

( 3/4.6.6 SECONDARY CONTAINNENT SUPPLEMENTARY LEAK COLLECTION AND RELEASE SYSTEN 5LCE*

LINITING CONDITION FOR OPERATION 3.6.6.1 Two independent Supplementary Leak Col'4ection and Release Systems shall be OPERABLE with each system comprised of:

a. one OPERABLE filter and fan, and

b. one OPERABLE Auxiliary Building Filter System as defined in Specification 3.7.9.

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

ACTION:

With one Supplementary Leak Collection and Release System inoperable, restore r 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 />.

SURVEILLANCE REQUIRENENTS 4.6.6.1 Each Supplementary Leak Collection and Release System shall be demon-strated 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 a system flow rate of 7600 cfm to 9800 cfm

, and that the system operates for at least 10 continuous hours with 4

the heaters operating.

/ j g e g ae ua c wreitu t.

b. At least once/ psf 7B montes' 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 system by: '

1) Verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.055,and uses the test procedure guidance in Regulatory Posi- -

tions C.5.a C.5.c, and C.5.d of Regulatory Guide 1.52, Revi-sion 2, March 1978,* and the system flow rate is 7600 cfm to 9800 cfe; I 9507240154 95o717 PDR ADOCK 05000423 P PDR NILLSTONE - LMIT 3 3/4 6-19 Amendment No. p. pp. 57.

SYuy '00

l January 3,1995 3 M' #14 C0fffAlfftDff SYSTDis SURVEILLANCE REQUIRENENTS (Continued)

, , , .. . . 2) within 31 days after removal, that a laboratory Verifying,f analysis o a representative carbon sample obtained in accord- -

ance 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,* for a methyl iodide penetration of less than 0.175%; and

3) Verifying a system flow rate of 7600 cfm to 9800 cfm during system operation when tested in accordance with ANSI N510-1980.

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,* i 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%:

d.

At least once h [ c

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.25 inches Water Gauge while operating the system at a flow rate of 7600 cfm to 9800 cfa,

2) Verifying that the system starts on a Safety Injection test signal,

3) Verifying that each system produces a negative pressure of greater than or equal to 0.4 inch Water Gauge in the Auxiliary Building at 24'6' elevation within 120 seconds after a start signal, and 4)- Verifying that the heaters dissipate 5015 kW when tested in accordance with ANSI M510-1980.

,

• ANSI NSs0-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52. Revision 2, March 1978.

gLLETONE-WIT 3 3/46-20 Amendment No. g 9 , F ,

m7

3-M -9 go ckcing January 3,1995 CONTAINNENT SYSTDi$

(

SURVEILLANCE REQUIRDIENTS (Continued)

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of. lass than 0.05% in l accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 7600 cfm to 9800 cfe; and  !

l'

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 7600 cfm to 9800 cfa. 3 I

I l

i t

N LLITONE - int!T 3 3/46-21 Amendment No. J. N. R.

100

• No c/rAA% E $' '9N April 7. 1987 FO R /NF O OM Y ,

FIAh** SYSHMS 324.7.7 CON *ITtOL ROOM EMEPTANCY VDrf!!ATIN SYSTEM LIMITING COCITION FOR OPDATICH 3'.7.7 Two independent control Room Duergency Air riltration systems shall be OPDABLE.

APPLICABILIIY: All MODES.

ACTIOJ:

PODES 1, 2, 3 and 4: ,

with one control Room Emergency Air Filtration System inoperable, restore the inoperable system to OPDABLE status within 7 days or be, in at least IKrr STMcBY 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 SWJIDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

PEDES 5 and 6:

a. With one control Room Emergency Air Filtration System inoperable, restore the inoperable system to OPDABLE status within 7 days or initiate and maintain operation of the .

remaining OPDABLE Control Room Emergency Air Filtration System in the recirculation mode. l

b. With both control Roca Emergency Air Filtration Systems inoperable, or with the OPERABLE Control Room Emergency Air Filtration system required to be in the recirculation mode by ACTION a. not capable of being powered by an OPDABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILIANCE Pl?JIREMDCS t 4.7.7 Each Control Roca Emergency Air riltration System shall be demonstrated OPDABLE:

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 95 r;

b. At least once per 31 days on a STAGGD e TEST RASIS by initiating,.

from the control room, flow through the REPA filters and charcoat adsorbers and verifying a system flow rate of 1,120 cfm +20L and that the system operates for at least 10 continuous hours with the heaters cperating; i

MILIXItmE - tact 3 3/4 7-15 Amendment No. 2

_ _ _ _ __ __ l

April 7, 1987 b ___  ;

p yTF Ao A '

PIANT KYSTD'.S pgFU 6 t. l!' 0" SURVEII.tANCE REQUIRDH2C'S (Continued)

[ec+g '

/ 7 i

/ .

At least once loer in '=nnthe or (1) after any structural

c. '

maintenance on the EEPA filter or charcoal adsorber housings, .

or (2) following painting, fire, or chemical release in any ventilation zone consuunicating with the system by: a4

1) verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria ,

of less than 0.05% and uses the test procedure guidance in Regulatory Position C.S.a, C.S.c, and C.S.d of Regulatory Guide 1.52, Revisions 2, March 1978,* and the system flow i rate is 1,120 cfm 320t; ,

j

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 j Regulatory Guide 1.52, Revision 2, March 1978,* for a methyl iodide penetration of less than 0.175%; and .

3) verifying a system flow rate of 1,120 cfm 120% during system operation 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 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' ocide 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 lodido penetration of  ;

less than 0.175%; i

/ egh nEcueueoc. iroTsnoAL  !

e. At least once lper as monthalby: l

1) verifying that the pressure drop across the cambined HEPA /C l filters and charcoal adsorber banks is less than 6.75 l inches Water Gauge while operating the system at a flow O ,

rate of 1,120 cfm 120%;

2) verifying that the system maintains the control room at a positive pressure of greater than or equal to 1/8 inch Water Gauge at less than or equal to a pressurization flow of 230 cfm relative to adjacent areas during system 8

operation; and

3) verifying that the heaters dissipate 9.4 11 kW when tested in accordance with ANSI N510-1980.

i i

MII15'KNE - LNIT 3 3/4 7-16 Amenche'nt No. f nro I I

PLANT SYSTEMS .JAN 31 1986 3/4.7.8 Wo ckMG E CONTROL ROOM ENVELOPE PRESSURIZATION SYSTEM' JNFC ' O^" Y LIMITING CONDITION FOR OPERATION

\

t 3.7.8 . Two independent Control Room Envelope Pres::urization Systems shall be OPERABLE.

L ,

, APPLICABILITY: All MODES.

ACTION:  !

a.

With either: one Control Room Envelope Pressurization System inoperable

1. 1 Restore the inoperable system to OPERABLE status within 7 days, or 2.

Initiate and maintain operation of an OPERABLE Control Room i Emergency Air Filtration System in the recirculation mode, or 3.

Be in HOT STANDBY within 6_ hours and COLD SHUTDOWN within th next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

b.

With both Control Room Envelope Pressurization Systems inoperable, within one hour initiate action to restore one inoperable system to OPERABLE status and either:

1.

Initiate and maintain operation of an OPERABLE Control Room Emergency Air Filtration System in the recirculation mode, or 2.

Be in NOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> and suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS

4.7.8 OPERABLE

Each Control Room Envelope Pressurization System shall be demonstrated a.

At least once per 7 days by verifying that the storage air bottles are pressurized to greater than or equal to 2200 psig, ,

b.

At least once per 31 days on a STAGGERED TEST BASIS by verifying that each valve (manual, power operated or automatic) in the flow path correct notposition, locked, and sealed or otherwise secured in position, is in its l

s-MILLSTONE - UNIT 3 3/4 7-18

l

\

. . a e

January 31. 1986  ;

4 PLANT SYSTEMS b~b'-I SURVE1LLANCE REOUTREMENTS (Continued)

~

ecrcLs 9EfU E'ha+'  ;

c. . At least once Fff_18_ month) or following a major alteration of the control room envelope pressure boundary by:- ,

1. Verifying that the control room envelope is isolated in response to a Control Building Isolation test signal,

2. Verifying that af ter a 60 second time delay following a Contrel ,

. Building Isolation test signal, the control room envelope pressurizes to greater than or equal to 1/8 inch W.G. relative to the outside atmosphere, and .

3. Verifying that the positive pressure of Specification 4.7.8.c.2 is maintained for greater than or equal to 60 minutes. ,

9 ga

• t e

4 .'

4 %d MILLSTONE - UNIT 3 3/4 7-19 0 5 ?! __

12/08/93 l

Pmf 8- 3 - 3 c.- 7 y 214.7.9 Alf11LIARY BUILDING FILTER SYSTEN e.

LIMITING C00GITION FOR OPERATIM l 3.7.9 Two independent Auxiliary Building Filter Systems shall be OPERABLE with each system comprised of: t

a. one OPERABLE filter and fan, and

b. one OPERATIONAL Charging Pump / Reactor Plant Component Cooling Water Pump Ventilation System. (

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

AGIl0N:

With one Auxiliary Butiding Filter 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 />. In addition, comply with the ACTION requirements of Specification 3.6.6.1.

SERVEILLANCE REQUIRENENTS 4.7.9 Each Auxiliary Building Filter System 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 a system flow rate of 30,000 cfm 110% and that the system operates for at least 10 continuous hours with the heaters operating; M I W # #

, eack eESUEU

b. At least once Car _18 month) 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 communicating with the system by:

1)

Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a. C.S.c. and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978,* and the system flow rate is 30,000 cfm 110%;

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 i

Guide 1.52, Revision 2, March 1978,* meets the laboratory b l

Amendment No. g,87 RILLSTONE 1 UNIT 3 3/47-20

.ews -

03'7/

\ __ _ _ _ . _ _ _ _ _ _ _ _

12/08/93 PLANT SYSTDi$

ERVEILLANCE REQUIRDIDirs testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978,* for a methyl todido penetration of less than 0.175%; and

3) Verifying a system flow rate of 30,000 cfm 1105 during

^

system operation when tested in accordance with ANSI N510-1980.

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 I 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%; i <

/ c_uh (LE FmiewAu u e us

d. At least once her Is'manthh by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.8 inches Water Gau e while operating the system at a flow rate of 30,000 e a 1105,

2) Verifying that the system starts on a Saf$ty Injection test signal, and .x

3) Verifying that the heaters dissipate 180 118 kW when tested in accordance with ANSI N510-1980,

s. After each complete or partial replacement of a HEPA filter bank, by verifying. that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.055 in accordance with ANSI N510-1980 for a D0P test aerosol while operating the system at a flow rate of 30,000 cfm 1105; and

f. After each complete or partial replacement of a charcoal i adsorber bank, by verifying.that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptanca criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 30,000 cfm 1105.

• ANSI M510-180 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

N LLSTONE - IMIT 3 3/47-21 Amendment No. g,87 b s 7/

v8Hre DRPE TEL:301-415-2102 Feb 22'95 15:59 No.016 P.04 r

I L 3u ts REB!faIM_QEEBEUlBIt

(

314.9.12 FUEL BUILDING EXHAUST FILTUt SYSTEN LIMITINE CofmITION FOR OPERATION 3.9.12 Two independent Fuel Building Exhaust Filter Systems shall be OPERABLE. At least one Fuel Building Exhaust Filter System shall be in operat"on whenever any evolution involving movement of fuel within the storage pool or crane operations with loads over the storage pool is in progress.

AEELLCABILITY: Whenever irradiated fuel with less than 60 days decay is in j the storage pool. ,

ACTION:

a. With one Fuel Building Exhaust Filter System inoperable, fuel movement within the storage pool or crane operation with loads over the storage pool may proceed provided the OPERABLE Fuel Buildi ,

Exhaust Filter System is capable of being powered from an OP LE emergency power source and is in operation and discharging through -

at least one train of HEPA filters and charcoal adsorbers.

b. With no Fuel Building Exhaust Filter System OPERABLE, suspend all operations involving movement of fuel within the storage pool or crane operation with loads over the storage pool until at least one Fuel Building Exhaust Filter System is restored te OPERABLE status.

c. The provisions of Specifications 3.0.3 are not applicable.

SURVEILLANCE REQUIRDtENTS 4.9.1%4The above required Fuel Building Exhaust Filter Systems shall be l- l demon 8trated OPERABLE: ,- l

t. Within 31 days prior to moving fuel within or loads over the storage  !

pool when irradiated fuel with less than 60 days decay is present by  :

initiating, from the control room, flow through the HEPA filters and charcoal adsorbers, and verifying a system flow rate of 20,700 cfm 1105 and that the system operatas for at least 10 continuous hours with the heaters operating; ggy,s crew b.

At least onceC8 monthon the HEPA filter or charcoal or (Ma(dsorber following hof ??1) after a painting, fire, or chemical release in any vetilation 'ione communicating with the system by: ,

MILLSTolE: - UNIT 3 3/4 g-13 Amendment No. J. 77 105 sur

( o 3 ?!

1

b~3k "k %

April 7, 1937 REFUELING

• OPDATICHS SURVE!!IAN2 REQUIREMDr:S (Continued) .

)g

, ' 1) verifying that the cleanup system satisfies the in-place-penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c and C.S.d of Regulatory 4 Guide 1.52, Revision 2, March 1978,* and the system flow rate is 20,700 cfm 310%;

2) verifying, within 31 days after removal, that a  ;

laboratory analysis of a representative carbon sangle  !

, obtained in accordance with Regulatory Position C.6.b of l l

Regulatory Guide 1.52, Revision 2, .urch 1978,* mee~ts the l

. 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%; and

3) Verifying a system flow rate of 20,700 cfm 310% during  !

eystem operation when tested in accordance with ANSI i N510-1980. 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,-

within 31 days after remov>J. that a laboratory analysis of a representative carbon sangle obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, meets the laboratory testing criteria of. Revision 2, March 1978,* Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978,* for a methyl

• iodide penetration of less than 0.175%;

fLE G U El'* A G'

d. At least onee]per 18 monthjs by:each #NTEAVAL

1) verifying that the pressure drop across the ceabined HEPA filters and charcoal adsorber banks is less than 6.8 inches Water Gauge while operating the system at a flow rate of 20,700 cfm f ot. l f[  ;

V l

1 i

MIME 204E - tNIT 3 3/4 9-14 Amendment No. 2 CJB

o 3-ww January 31, 1986 REFUELIl4G OPERATIONS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying that the system maintains the spent fuel storage pool area at a negative pressure of greater than or equal to 1/4 inch Water Gauge relative to the outside atmosphere during system operation, and

3) Verifying that the heaters dissipate 150 1 15 kW when tested in accordance with ANSI N510-1980.

e. Af ter each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 20,700 cfm 2 10%; and

f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 20,700 cfm 1 10%.

4.9.12.2 The Fuel Building Exhaust Filter System shall be verified to be operating within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the initiation of and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during either fuel movement within the fuel storage pool or crane operations with loads over the fuel storage poolfy u%emeve-f W <*di Of ~

% ej. Ja \c t s h c. <t (,o do gs d e c .g. 4 '~ 4% 5 6 '#3c 9 4 3 t

l 1

l I

• ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

MILLSTONE - UNIT 3 3/4 9-15 4 c5?3 l

~~~

' ' ~

^

g-3 c,,_7 tj 12/08/93 CO NAlfftEM SYSTDt3 ~

aAses J f

3/LLF.1 SUPPLEMENTARYLEAKC04ECTIONANDRELEASESYSTEM(Continued)

$ntrai11aacaJtenviramanis 5

Cumulative operation of the SLCRS with 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 31-day frequency was developed in consideration of the known reliability of fan motors and con-trols. This test is performed on a STAGGERED TEST BASIS once per 31-days.

~

l b. c. e. and f These surveillances verify that the required SLCRS filter testing is performed in accordance with Regulatory Guide 1.52, Revision 2. ANSI N510-1980 shall be used'in place of ANSI N510-Ig75 referenced in Regulatory Guide 1.52. Revision 2. The surveillances include testing HEPA filter l

- performance, charcoal adsorber efficiency, system flow rate, and the physical l properties of the activated charcoal (general use and following specific i operations). ga l g gf automatic startup ensures that each SLCRS train responds properly.

The A-spnthWrequency is based on the need to perform this surveillance under the conditions that apply during a plant outage and the potential for an eplanned transient if the surveillance was prformed with the reactor at puwer. The surveillance verifies that the 5.CRS starts on a SIS test signal.

It also includes the automatic functions to isolete the other ventilation systems that are not part of the safety-related postaccident operating configuration and to start up and to align the ventilation systems that flow ,

through the secondary containment to the accident condition.

• The main steam valve building ventilation system isolates.

• Auxiliary building ventilation (normal) system isolates.

• Charging pump / reactor plant component cooling water area cooling subsystem aligns and discharges to the auxiliary but ding filters and a filter fan starts. -

• l(ydrogen recombiner ventilation system aligns to the postaccident configuration. i

• The engineered safety features building ventilation system aligns to the postaccident configuration.

a j

Il - 18117 3 33/46-8 Amendment No. 87 o 5 '? 't

[_ i - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____

i

l Docket No. 50-423 j B15263 .

I l

l J

l Attachment 2 Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications 24-Month Fuel Cycle

. Plant Systems Surveillance Extensions Retyped Pages 4

u L

July 1995 l

CONTAllBlENT SYSTEMS l 3/4.6.6 SEC0lWARY CONTAlletENT ,

SUPPLEMENTARY LEAK COLLECTION Ale RELEASE SYSTEN I LIMITING ColelTION FOR OPERATION 3.6.6.1 Two independent Supplementary Leak Collection and Release Systems .

shall be OPERABLE with each system comprised of:

a. one OPERABLE filter and fan, and

b. one OPERABLE Auxiliary Building Filter System as defined in Specification 3.7.9.

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

ACTION:

With one Supplementary Leak Collection and Release 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 />.

SURVEILLANCE REQUIREMENTS 4.6.6.1 Each Supplementary Leak Collection and Release System shall be demon-strated OPERABLE:

i

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 a system flow rate of 7600 cfm to 9800 cfm and that the system operates for at least 10 continuous hours with the heaters operating,

b. At least once each REFUELING INTERVAL or (1) after any structural l maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone '

communicating with the system by:

1) Verifying that the system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Posi-  ;

tions C.5.a, C.5.c, and C.S.d of Regulatory Guide 1.52, Revi- i sion 2, March 1978,* and the system flow rate is 7600 cfm to ,

9800 cfm; I

l MILLSTONE - UNIT 3 3/4 6-19 Amendment No. J. JJ, J7, om 199

u ,

CONTAHetENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying, within 31 days after removal, that a. laboratory analysis of a representative carbon sample obtained in accord-ance 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,* for a methyl iodide penetration of less than 0.175%; and

3) Verifying.a system flow rate of 7600 cfm to 9800 cfm during system operation when tested in accordance with ANSI N510-1980.

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,* for a methyl iodide penetration of less than 0.175%:

d. At least once each REFUELING INTERVAL by: l

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.25 inches Water Gauge while operating the system at a flow rate of 7600 cfm to 9800 cfe,

2) Verifying that the system starts on a Safety Injection test signal,

3) Verifying that each system produces a negative pressure of greater than or equal to 0.4 inch Water Gauge in-the Auxiliary-Building at 24'6" elevation within 120 seconds after a start signal, and

4) Verifying that the heaters dissipate 50 15 kW when tested in accordance with ANSI N510-1980.

• ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

MILLSTONE - UNIT 3 3/4 6-20 Amendment No. g, J7, 77, om JPP

4

> l

PLANT SYSTEMS f SURVEILLANCE REQUIREMENTS (Continued) ,

I

c. At least once each REFUELING INTERVAL or (1) after any structural l l maintenance on the HEPA filter or- charcoal adsorber housings, i or (2) following . painting, fire, or. chemical - release' 'in any ventilation zone communicating with the system by:

1) Verifying that the system satisfies the 'in-pl ace l penetration and bypass leakage testing acceptance criteria '

of less than 0.05% and uses the test procedure guidance.in '

Regulatory Position C.5.a,~ C.5.c, and C.5.d of Regulatory Guide 1.52, Revisions 2, March 1978,* and the-system flow .

rate is 1,120 cfm 20%;

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,_ Revision 2, March 1978,* for a- .

methyl iodide penetration of less than 0.175%; and.  :

3) Verifying a system flow rate of 1,120 cfm 120% during ,

system operation when . tested in accordance with ANSI  :

N510-1980. l i

d. 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 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%,  :

)

e. At least once each REFUELING INTERVAL by: l

1) Verifying that the pressure drop across the combined HEPA -!

filters and charcoal adsorber banks is less than 6.75-  !

inches Water Gauge while operating the system at a flow  ;

rate of 1,120 cfm i20%;

2) Verifying that . the -system maintains the control ' room at a  !

positive pressure of greater than or equal to 1/8 inch l Water Gauge at less than or equal to a pressurization flow  !

of 230 cfm relative to adjacent areas- during system i operation; and

3) Verifying that the heaters dissipate 9.4 1 kW when tested in accordance with ANSI N510-1980.

MILLSTONE - UNIT 3 3/47-16 Amendment No. 1, 0370 l

1 PLANT _5YSTEMS canvrut i mer arruitarurure, reanHans)

c. At least once each REFUELING INTERVAL or following a major l alteration of the control room envelope pressure boundary by:

1. Verifying that the control room envelope is isolated in response to a Control Building Isolation test signal,

)

L 2. Verifying that after a 60 second time delay following a Control 2 Building Isolation test signal, the control room envelope pressurizes to greater than or equal to 1/8 inch W.G. relative to the outside atmosphere, and

3. Verifying that the positive pressure of Specification 4.7.8.c.2 l 1s maintained for greater than or equal to 60 minutes.

l 1

I MILLSTONE - UNIT 3 3/4 7-19 Amendment No. J 0371 l

1

_._ _j

PLANT SYSTEMS 3/4.7.9 AUXILIARY BUILDING FILTER SYSTEM LIMITING COM ITION FOR OPERATION 3.7.9 Two independent Auxiliary Building Filter Systems shall be OPERABLE with each system comprised of:

a. one OPERABLE filter and fan, and

b. one OPERATIONAL Charging Pump / Reactor Plant Component Cooling l Water Pump Ventilation System. l l

APPLICABILITY: MODES 1, 2, 3, and 4.  ;

ACTION:

With one Auxiliary Building Filter 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 />. In addition, comply with the ACTION requirements of Specification 3.6.6.1. ,

SURVEILLANCE REQUIREMENTS i

4.7.9 Each Auxiliary Building Filter System 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 a system flow rate of 30,000 cfm 10% and that the system operates for at least 10 continuous hours with the heaters operating;

b. At least once each REFUELING INTERVAL or (1) after any structural l maintenance on the HEPA filter or charcoal adsorber housings, or(2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978,* and the system flow rate is 30,000 cfm 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon samph obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,* meets the laboratory MILLSTONE - UNIT 3 3/4 7-20 Amendment No. 7, 77, 0371

PLANT SYSTEMS SURVEILUUICE REQUIREMENTS l 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%; and

3) Verifying a system flow rate of 30,000 cfm 110% during i system operation when tested in accordance with ANSI N510-1980.

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 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 1 less than 0.175%;

d. At least once each REFUELING INTERVAL by: l [

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than. 6.8 l inches Water Gauge while operating the system at a flow  ;

rate of 30,000 cfm 110%, l

2) Verifying that the system starts on a Safety Injection f test signal, and

3) Verifying that the heaters dissipate 180 118 kW when .

tested in accordance with ANSI N510-1980. t

e. After each complete or partial replacement of a HEPA filter i bank, by verifying that the cleanup system satisfies the  ;

in-place penetration and bypass leakage testing acceptance i criteria of less than 0.05% in accordance with ANSI N510-1980 l for a DOP test aerosol while operating the system at a i flow rate of 30,000 cfm 110%; and i 1

f. After each complete or partial replacement of _a charcoal l adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass _ leakage testing acceptance criteria of less than 0.05% in accordance -with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 30,000 cfm 10%.

• ANSI N510-180 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

NILLSTONE - UNIT 3 3/4 7-21 Amendment No. J. 77, 0371 I

REFUELING OPERATIONS l 3/4.9.12 FUEL BUILDING EXHAUST FILTER SYSTEN >

LIMITING COMITION FOR OPERATION ~

3.9.12 Two independent Fuel Building Exhaust' Filter Systems shall be OPERABLE. At least one Fuel Building Exhaust Filter System shall be in operation whenever any evolution involving movement of fuel within' the storage pool or crane operations with _ loads over the storage pool is in progress.

L APPLICABILITY: Whenever irradiated fuel with less than 60 days decay is in the storage pool.

ACTION:

a. With one Fuel Building Exhaust Filter System inoperable, fuel movement within the storage pool or crane operation with loads over the storage pool may proceed provided the OPERABLE Fuel Building Exhaust Filter System is capable of being powered from an OPERABLE ,

emergency power source and is in operation and discharging through at least one train of HEPA filters and charcoal adsorbers.

b. With no Fuel Building Exhaust Filter System OPERABLE, suspend all  :

operations involving movement of fuel within the storage pool or-crane operation with loads over the storage pool until at least one Fuel Building Exhaust Filter System is restored to OPERABLE status. ,

c. The provisions of Specifications 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.12 The above required Fuel Building Exhaust Filter Systems shall be demonstrated OPERABLE:

a. Within 31 days prior to moving fuel within or loads over the storage pool when irradiated fuel with less than 60 days decay is present by initiating, from the control room, flow through the HEPA filters and i charcoal adsorbers, and verifying a system flow rate of 20,700 cfm l 110%'and that the system operates for at least 10 continuous hours  !

with the heaters operating;

b. At least once each REFUELING INTERVAL or (1) after any structural l maintenance en the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

MILLSTONE - UNIT 3 3/4 9-13 Amendment No. J # , Jp).

0373 l

i l

l REFUELING OPERATIONS SURVEILLANCE REQUIREMENTS-(Continued) ,

i

1) Verifying that the cleanup system satisfies the in-place penetration and bypass leakage 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.S.d of Regulatory .

Guide 1.52, Revision 2 March 1978,* and the system flow i rate is 20,700 cfm 110%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample i 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%; and

3) Verifying a system flow rate of 20,700 cfm 110% during i system operation when tested in accordance with ANSI 1 N510-1980.  ;

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 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%;

d. At least once each REFUELING INTERVAL by:

-l

1) Verifying that the pressure drop across the combined HEPA .

filters and charcoal adsorber banks is less than 6.8 inches

• Water Gauge while operating the system at a flow rate of 20,700 cfm 110%.

r MILLSTONE - UNIT 3 3/4 9-14 Amendment No. J.

0373

p - <- c.+ - z. x=, 14 r

REFUELING 0PERATIONS SURVEILLANCE REQUIREMENTS (Continued) i

2) Verifying that the system maintains the-spent fuel storage pool l area at a negative pressure of greater than or equal to 1/4 inch Water Gauge relative to the outside atmosphere during system operation, and ,

3) Verifying that the heaters dissipate 150 115 kW when tested in ,

accordance with ANSI N510-1980.

e. After each complete or partial replacement of a HEPA filter bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in l accordance with ANSI N510-1980 for a DOP test aerosol while operating .

the system at a flow rate of 20,700 cfm 110%; and l f. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cleanup system satisfies the in-place penetration and bypass leakage testing acceptance criteria of less t than 0.05% in accordance with ANSI N510-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 20,700 cfm 110%.

4.9.12.2 The Fuel Building Exhaust Filter System shall be verified to be operating within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the initiation of and at least once per i 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during either fuel movement within the fuel storage pool or crane '

operations with loads over the fuel storage pool whenever irradiated fuel with less than 60 days decay is in the storage pool. ,

l l

i l

• ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2, March 1978.

NILLSTONE - UNIT 3 3/4 9-15 Amendment No.

0373 l

- .. ~ . - -

l P

CONTAllglENT SYSTEMS BASES 3/4.6.6.1 SUPPLEMENTARY LEAK COLLECTION AND RELEASE SYSTEM (Continued)

Surveillance Reauirements A

Cumulative operation of the SLCRS with' 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 31-day frequency was developed in consideration of the known reliability of fan motors and con-trols. This test is performed on a STAGGERED TEST BASIS once per 31-days.

l

b. c. e. and f These surveillances verify that the required SLCRS filter testing is l performed in accordance with Regulatory Guide 1.52, Revision 2. ANSI N510-1980 shall be used in place of ANSI N510-1975 referenced in Regulatory Guide 1.52, Revision 2. The surveillances include testing HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).

d The automatic startup ensures that each SLCRS train responds properly.

The REFUELING INTERVAL frequency is based on the need to perform this l surveillance under the conditions that apply during a plant outage and the l l

potential for an unplanned transient if the surveillance was performed with  ;

the reactor at power. The surveillance verifies that the SLCRS starts on a SIS test signal. It also includes the automatic functions to isolate the )

other ventilation systems that are not part of the safety-related postaccident  :

operating configuration and to start up and to align the ventilation systems l that flow through the secondary containment to the accident condition. -l

• The main steam valve building ventilation system isolates.

• Auxiliary building ventilation (normal) system isolates.

• Charging pump / reactor plant component cooling water pump area cooling subsystem aligns and discharges to the auxiliary building filters and a filter fan starts.

• Hydrogen recombiner ventilation system aligns to the postaccident configuration.

• The engineered safety features building ventilation system aligns to the postaccident configuration.

l MILLSTONE - UNIT 3 8 3/4 6-6 Amendment No. 57, l 0374

15 lo Docket No.'50-423 B15263 4

1 j' Attachment 3 Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications

24-month Fuel Cycle - Surveillance Extensions

] Description of-the Proposed Technical 4

Specification Changes Plant Systems A

4 s

1 1

July 1995

l I

l U.S. Nuclear Regulatory Commission B15263/ Attachment 3/Page 1 July 17, 1995 Millstone Nuclear Power Station, Unit No. 3 Description of the Proposed Technical specification Changes Introduction On June 7, 1995, Millstone Unit No. 3 began operating on a 24-month fuel cycle instead of the previous 18-month cycle. To take advantage of this longer fuel cycle, NNECO is proposing to modify the frequency of a number of the surveillance requirements existing in the Millstone Unit No. 3 Technical Specifications. The proposed changes are described below:

Descrintion of the ProDosed ChanGel

1. Sections 4.6.6.1.b and 4.6.6.1.d. Suoolementary Leak Collection and Release System. Surveillance Reauirements and Bases Section 3/4.6.6.1 The proposed changes to the Millstone Unit No. 3 Technical Specification Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d will extend the frequency from once per 18 months to at least once each refueling interval (i.e., nominal 24 months). The proposed changes are being made in accordance with the guidance contained in GL 91-04. The Bases Section 3/4.6.6.1 has been revised to reflect the above changes.

2. Section 4.7.7. Control Room Emeroency Ventilation System.

Surveillance Reauirements Surveillance Requirements 4.7.7.c and 4.7.7.e verify the operability of each control room emergency air filtration system at least once per 18 months. NNECO proposes to extend the frequency of Surveillance Requirements 4.7.7.c and 4.7.7.e from at least once per 18 months to at least once'each refueling interval (i.e., nominal 24 months).

The proposed change is consistent with the recommendations of GL 91-04. No changes to Bases Section 3/4.7.7 are proposed because the Bases Section is not impacted by the proposed change.

3. Section 4.7.8. Control Room Envelope Pressurization System. Surveillance Reauirements *

, Surveillance Requirement 4.7.8.c verifies the operability of each control room envelope pressurization system at least once per 18 months. NNECO proposes to extend the frequency of Surveillance Requirement 4.7.8.c from at ~

least once per 18 months to once each refueling interval (i.e., nominal 24 months). The proposed change is consistent with the recommendations of GL 91-04. No

1

.: i ;

U.S. Nuclear Regulatory Commission  ;

B15263/ Attachment 3/Page 2 i July 17, 1995 changes to Bases Section 3/4.7.8 are proposed because the Bases Section is not impacted by the proposed change.

4.- Section 4.7.9, Auxiliary Bull'dina' Filter System.

Surveillance Reauirements Surveillance Requirements 4.7.9.b and 4.7.9.d verify the operability of each auxiliary filter . system once per.

18 months. NNECO proposes to extend the frequency . of l Surveillance Requirements 4.7.9.b and 4.7.9.d from at least once per 18 months to once each refueling interval- 1 (i.e., nominal 24 months). The proposed change is j consistent with the recommendations of GL 91-04. No J changes to Bases Section 3/4.7.9 are proposed because.the 1 Bases Section is not impacted by the proposed change. ,

5. Section 4.9.12. Fuel Buildina Exhaust Filter System.  ;

Surveillance Recuirements ]

Surveillance Requirements 4.9.12.b and 4.9.12.d verify the  !

operability of each fuel' building exhaust filter system  :

once per. 18 months. NNECO proposes to extend the 1 frequency of Surveillance Requirement 4.9.12.b and  ;

4.9.12.d from once per 18 months to once each refueling l interval (i.e., nominal 24 months). The proposed change is consistent with the recommendations of GL 91-04. No changes to Bases Section 3/4.9.12 are proposed because the -

Bases Section is not impacted by the proposed. change. ,

In addition, Surveillance Requirement ' 4.9.12.2 has been revised to make it consistent - with the . Applicability. .

Section of Specification 3.9.12 by adding the words "whenever irradiated fuel with less than 60 days decay is  ;

in the storage pool." ,

l 4

1 l

l

j 4

l Docket No. 50-423 B15263

.I 1

I 1

'I

'l Attachment 4 j i

Millstone Nuclear Power Station, Unit No. 3 I Proposed Revision to-TechnicalLSpecifications 24-Month Refuel Cycle 3

Safety Assessment and Significant Hazards Consideration

- for Changes to:

Control Room Emergency Ventilation System and Control Room Envelope Pressurization System Auxiliary Building Filter System Supplementary Leak Collection and Release System '

Fuel Building Exhaust Filter System r

4 i

.J i

l July 1995 l l

l

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 1 July 17, 1995 Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications 24-Month Refuel Cycle Safety Assessment and Significant Hazards Consideration Safety Assessment and Significant Hazards Consideration for Changes to control Room Emergency Ventilation System, Control Room Envelope Prr.msurisation System, Auxiliary Building Filter System, Su r plementary Leak Collection and Release System, and Fuel Building Exhaust Filter System .

RArAground On June 7,1995, Millstone Unit No. 3 began operating on a 24-month fuel cycle instead of the previous 18-month cycles. To be consistent with this longer fuel cycle, NNECO is proposing to modify the frequency of a number of the surveillance requirements existing in the Millstone Unit No. 3 Technical Specifications. The safety assessment and significant hazards consideration discussion for the proposed changes to Sections 4.7.7.c, 4.7.7.e, 4.7.8.c, 4.7.9.b, 4.7.9.d, 4.9.12.b, 4.9.12.d, 4.6.6.1.b, 4.6.6.1.d, and Bases Section 3/4.6.6.1 are described below. In the future, NNECG will be proposing additional changes to the Millstone Unit No. 3 Technical Specifications to prepare for the conversion to the 24-month fuel cycle. Each of thase submittals will contain evaluations that are independent and which stand alone.

A. Control Roon Emercency Ventilation System and Control Room EnveloDe Pressurisation System Safety Assessment The function of the control room envelope pressurization system is to provide breathable air to the control room pressure envelope and to pressurize the envelope area for the first hour following the isolation of the control room envelope due to an accident that causes release of radiation or toxic gases. The control room emergency air filtration nystem is put into operation approximately one hour after the isolation of the pressure envelope as the bottled air supply is exhausted. The function of the control room congency air filtration system is to continue to maintain pressMizatic,n of the pressure envelope after the bottled air system is no longer able to do so. It is also designed to limit the amount of radioactivity  ;

introduced into the envelope and filter radioactivity already l in the control room. The control room emergency air filtration and envelope pressurization systems are located in the control building.

z U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 2 July 17, 1995 Surveillance Requirement 4.7.7.c demonstrates the operability of the control room emergency air filtration system by:

(1) verifying that it satisfies in-place penetration and bypass leakage testing acceptance criteria, (2) verifying, within 31 days of removal, that a laboratory analysis of a representative carbon sample meets its acceptance criteria, and (3) verifying a system flow rate of 1120 cfm i 20% during system operation. Surveillance Requirement 4.7.7.c contains additional requirements to perform the applicable verifications after any structural maintenance on the HEPA filter or charcoal adsorber housings, or following painting, fire, or chemical release in any ventilation zone communicating with the system.

These requirements are not being modified.

Surveillance Requirement 4.7.7.e demonstrates the operability of the control room's emergency air filtration system by:

(1) verifying the pressure drop across the combined HEPA filters and charcoal adsorber bank at operating system flow rate, (2) verifying that the system is capable of maintaining the control room at a positive pressure of greater than or equal to 1/8 inch water gauge at less than or equal to the pressurization flow, and (3) verifying that the heaters dissipate specified kW when tested.

Surveillance Requirement 4.7.8.c demonstrates the operability of the control room envelope pressurization system by:

(1) verifying that the control room envelope is isolated in response to a control building isolation (CBI) test signal, (2) verifying that after a 60-second time delay following a CBI test signal, the control room envelope pressurizes to greater than or equal to 1/8 inch water gauge relative to outside atmosphere, and (3) verifying that the positive pressure is maintained for greater than or equal to 60 minutes.

The above surveillances are required to be performed at least once per 18 months. NNECO is proposing to extend the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c from at least once per 18 months to at least once each refueling interval (i.e., nominal 24 months).

The proposed changes to Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, systems, or component functions, and do not modify the manner in which the plant is operated. As such, the proposed changes to the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e,

} and 4.7.8.c will not degrade the ability of the control room emergency filtration and control room envelope pressurization systems to perform their function.

l U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 3 July 17, 1995 Also, the automatic actuation logic and actuation relays responsible for isolating the control room envelope are required to be tested by Surveillance Requirement 4.3.2.1 of the Millstone Unit No. 3 Technical Specifications.

Surveillance Requirement 4.3.2.1 requires monthly actuation logic tests and master relay tests and quarterly slave relay tests for the CBI actuation logics and actuation relays to be t conducted.

Equipment performance over the last four operating cycles was ,

evaluated to determine the impact of extending the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c.

This evaluation included a review of surveillance results, preventive maintenance records, and the frequency and type of corrective maintenance. The components covered under Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4. 7. 8. c are shown in Table 2 and covered by Surveillance Procedures SP3614.F.2 and SP3614.F.3, and Maintenance Procedure SP3712H.

The summary of the surveillance test scope and results are provided below:

1. Control Room Filter Charcoal Analysis:

There were nine surveillances performed on Train 'A' and thirteen on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

2. Control Room Filter System Flow Rates:

There were ten surveillances performed on Train 'A' and eleven on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

3. Control Room Filter Bank Pressure Drop:

There were seven surveillances performed on Train 'A' and eight on Train 'B." In all the cases, the surveillance acceptance criterion was met.

4. Control Room Emergency Ventilation HEPA Filter Test:

There were six surveillances performed on Train 'A' and six on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

5. Control Room Charcoal Adsorber Test:

There were ten surveillances performed on Train 'A' and nine on Train 'B.' In all the cases, the surveillance criterion was met.

J

q l

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 4  ;

July 17, 1995

6. Control Room Emergency Ventilation Pressurization: ,

There were seven surveillances performed on Train 'A' and i eight on Train 'B.' In three cases, the surveillance criterion did not meet the acceptance criterion.

Specifically, the control room pressure did not go above the 0.125 inch of water gauge acceptance criterion. After the investigation and making some adjustments to the control room manual recirculation damper, the tests were conducted on the same or following day and all the retests were acceptable. To prevent recurrence, written changes were made to Ops Form 3314F-9 and 3314F-10 to specify that the recirculation dampers are throttled appropriately to meet the control room pressurization technical specification requirements. At present, NNECO is continuing to investigate alternatives to the current testing methodology, including installation of a flow orifice. It is noted that all other tests met the acceptance criterion.

7. Control Room Envelope Pressurization Test:

There were thirteen surveillances performed on Train 'A' and ten on Train 'B.' Train 'A' had six failed surveillances (last test failure occurred on May 5, 1993),

and Train 'B' had three failed surveillances (last test failure occurred on February 23, 1993). These failures were attributed to problems with the oscillating chilled water valves 3HVK*TY41A(B) . Corrective actions were taken to prevent recurrence and the retests were performed in April /May 1993 which met the appropriate acceptance l criterion. Since then, additional tests have been l performed and, in those cases, the surveillance acceptance i criterion was met. All the failed surveillances l represented physical plant system conditions or lack of understanding of the allowable differential pressura fluctuation margin. Each issue was identified and i corrected by either component and loop adjustment, )

component replacement, procedural changes or i clarifications. In April 1994, a technical clarification was added to the Technical Requirements Manual (3TRM-3.7.8) explaining acceptable pressure fluctuation conditions which result in the differential pressure momentarily dropping below the 0.125 inch water gauge.

Prior understanding of this differential pressure fluctuation allowable criteria would have resulted in acceptable surveillances in the majority (5 of 9) of the failed tests. In addition, due to the extremely high frequency of use, the east control room door was starting to degrade and was replaced during RFOS. The following l pressurization tests were successful and showed marked )

1 i

i

.-~ - - - . . . . - . - . - - . . . - - . . .

s

.i

'U.S.-:Nucl' ear Regulatory Commission B15263/ Attachment 4/Page 5' )

July 17, 1995 improvement in the pressurization margin. Prior  ;

replacement of this door could have resulted in. acceptable i surveillances in an additional two'or three of the failed i tests.- The door replacement was an improvement to the  !

control room pressurization boundary, which is part of the ';

ongoing system preventive maintenance program to inspect

all control' room boundary doors on a quarterly basis.

8. Control Room Emergency Ventilation Filter Assembly Heaters: l There were six surveillances performed on Train 'A' and ]

six on Train 'B.' In all cases, the surveillance  !

acceptance criterion was met.

Based on the above surveillance results, the corrective changes -

made to the system and boundary, and better understanding of 1 allowable differential pressure fluctuation allowable criteria,  !

the reliability of the control room emergency air filtration  !

a nt control room envelope pressurization systems is considered l acc.aptable. .l The majority of corrective maintenance involved with charcoal .

filter inspections, charcoal removal of analysis, and leaking i air - valves and tanks. The majority of charcoal filter. '

E insr,ections and charcoal removal tasks were done following a -

filter having greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation time. Tests  ;

and experience have shown that activated carbon has a useful  :

life of between 3-5 years. in a . standby system. The leaking i valve corrective maintenance- tasks were either valve  ;

adjustments, disassembly and refurbishing Deating~ or i repacking). Due to recurring leaks with relief valves q 3HVC*RV125 A1, A2, B1, and B2, all valves have been replaced. 1 Leaking air tanks were inspected and plugs removed, cleaned and '

replaced with no known recurrence. The above maintenance tasks could be performed with the plant on-line. Based on the above, it is concluded that there is no indication that the proposed- ,

increase in the surveillance interval could cause deterioration i in the control room emergency air filtration and envelope l pressurization systems.  !

The only preventive maintenance that is scheduled on . an ~[

18-month frequency is to verify the capacity of heaters  !

3HVC*FLT1A and B. There is no indication that the~ proposed.  !

extension could cause deterioration in the control room  !

emergency air filtration system condition or performance.  !

In addition, Surveillance Requirements 4.7.7.b and 4'7.8.b .

provide additional assurance that the control room emergency l air filtration and control room envelope pressurization systems -l are operable, q f

k-U.S. Nuclear Regulatory Commission-B15263/ Attachment 4/Page 6 i July 17, 1995 On the basis of the above evaluation, there is reasonable assurance that the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c can be extended from at least once per 18 months to once each refueling interval (i.e.,

nominal 24 months) .

A Probabilistic Risk Assessment (PRA) review of the proposed i extension in the surveillance frequency concluded that the l l

increase in public risk is negligible. j 1

Sicnificant Hazards Consideration  !

NNECO has reviewed the proposed changes in accordance with

} 10CFR50.92 and has concluded that the changes do not involve

(. a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC l because the changes would not: l

1. Involve a significant increase in the probability or 3 consequences of an accidence previously evaluated.

The proposed changes to Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c extend the frequency for demonstrating the operability of the control room emergency air filtration and control room envelope pressurization systems. The proposal would extend the i frequency from at least once per 18 months to at least )

once each refueling interval (i.e., nominal 24 months).

The proposed changes to Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c do not alter the intent or method by which the surveillances are conducted, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. In addition, the acceptance criterion for each surveillance is unchanged. As such, the proposed changes in the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c will not degrade the ability of the control room emergency air filtration and control room envelope pressurization systems to perform their safety function.

In addition, Surveillance Requirements 4.7.7.b and 4.7.8.b provide additional assurance that these systems will be operable.

An evaluation of past surveillances, preventive l maintenance records, and the frequency and the type of j corrective maintenance concluded that decreasing the l

frequency will have little impact on safety. Since the l

, proposed changes only affect the surveillance frequency, I

the proposed changes cannot affect the probability of any

~

w; L ,

U.S.-Nuclear Regulatory Commission

'B15263/ Attachment <4/Page 7 July 17, 1995 previously analyzed accident. While the proposed changes can lengthen the interval between surveillances,.the

' increase in the interval has been ' evaluated, - and .it is concluded that there is no significant impact on the reliability or availability of.the control room emergency air filtration and control' room envelope pressurization systems, and consequently, there is no impact on the consequences of any analyzed' accident.

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

The proposed changes to Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c do not modify the design or operation of any plant system. The proposed changes do not alter the intent or method by which the surveillance is conducted .other than increasing .the interval from 18 months to 24 months (nominal) . The proposed changes do not introduce a new failure mode. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously analyzed.

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

Changing the frequency of Surveillance Requirements 4.7.7.c, 4.7.7.e, and 4.7.8.c from at least once per 18 months to at least once each refueling interval does not change the basis for frequency. . The proposed changes.

do not alter the intent or method by 'which. the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. Further, the previous history of reliability of the. control room

, emergency air filtration and control room envelope pressurization systems provides assurance that the changes will not affect the reliability of these systems. Thus, the proposed changes have no impact on the margin of safety.

B. Auxiliary Buildina Filter System Safety Assessment

! The auxiliary building filter system (ABFS) is a two train safety-related system. The function of the ABFS is to ensure 4

that radioactive material that leaks from the primary

containment into the secondary containment following a design basis accident (DBA) is filtered out and adsorbed prior to any release to the environment. To accomplish this, the ABFS works

~

in conjunction with the supplementary leak collection and

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 8 July 17, 1995 release system (SLCRS). The ABFS is also designed to process exhaust from nonsafety-related fans for filtration of other reactor plant areas where high radioactivity in those areas is detected. The SLCRS and the ABFS fans and filtration units are located in the auxiliary building. The ABFS is designed to operate together with the SLCRS to achieve and maintain a specified negative pressure in all areas within the secondary containment boundary under most meteorological conditions.

During normal plant operations, the ABFS does not normally operate. In the event of a DBA, it and the SLCRS start on receipt of a safety injection signal (SIS). The safety assessment of surveillance extension for the SLCRS is described later in this submittal.

The operability of the ABFS is verified by Surveillance Requirements 4. 7. 9. a through 4.7. 9. f. Surveillance Requirement 4.7.9.a requires that the ABFS be demonstrated operable 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, verifying the flow rate, and operating the system for a minimum period of time. Surveillance Requirements 4.7.9.b, c, e, and f require testing to verify HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal.

Surveillance Requirement 4.7.9.d verifies: (1) the pressure drop across the combined HEPA filters and charcoal adsorber banks, (2) that the ABFS starts on an SIS test signal, and (3) the heater dissipate 180 i 18 kW.

Currently, Surveillance Requirements 4.7.9.b and 4.7.9.d are required to be performed at least once per 18 months. NNECO is proposing to change this frequency to at least once each refueling interval (i.e., nominal 24 months) . Changing the frequency of Surveillance Requirement 4.7.9.b and 4.7.9.d from at least once per 18 months to at least once each refueling interval does not change the basis for the frequency.

Surveillance Requirement 4.7.9.b contains additional requirements to perform the applicable verifications after any structural maintenance on the HEPA filter or charcoal adsorber housings, or following painting, fire, or chemical release in any ventilation zone communicating with the system. These requirements are not being modified.

Also, the automatic actuation logic and relays responsible for starting the ABFS are required to be tested by Surveillance Requirement 4.3.2.1 of the Millstone Unit No. 3 Technical Specifications. Surveillance Requirement 4.3.2.1 requires j monthly actuation logic tests and master relay tests, and quarterly slave relay tests for the safety injection automatic actuation logics and actuation relays to be conducted.

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 9 July 17, 1995 Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of Surveillance Requirements 4.7.9.b and 4.7.9.d. This evaluation included a review of surveillance results, preventive maintenance records, and the frequency and type of corrective maintenance. Table 2 provides a list of the equipment tested by Surveillance Requirements 4.7.9.b and  ;

4.7.9.d and are covered by Surveillance Procedures SP3614A.2, SP3646A.17, and SP3646A.18, and Maintenance Procedure SP3712I.

The summary of the surveillance test scope and results are provided below:

i

1. Laboratory Analysis of Auxiliary Building Charcoal Sample:

There were seven surveillances performed on Train 'A' and six on Train 'B.' In all the cases, the surveillance I acceptance criterion was met.

2. Auxiliary Building Filter System Flow Rate:

There were eight surveillances performed on Train 'A' and eight on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

3. Auxiliary Building Filter Bank Pressure Drop:

There were seven surveillances performed on Train 'A' and six on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

4. Auxiliary Building Charcoal Adsorber Penetrant and Bypass Leakage Test:

There were six surveillances performed on Train 'A' and seven on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

5. Auxiliary Building HEPA Filter Bank Leakage Test:

There were six surveillances performed on Train 'A' and ten on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

6. ABFS System Fan Start on SIS Signal With the Loss of Power:

There were seven surveillances performed on Train 'A' and six on Train 'B.' All Train A and B surveillance acceptance criteria, with the exception of one on each train, were met. The Train A failure was due to a power circuit that supplies power to an auxiliary circuit that

V ,

j

)

- U.S. Nuclear Regulatory Commission l

B15263/ Attachment 4/Page 10 i July 17, 1995 was not energized. A subsequent test was performedJwith no failures. The Train B failure.was due to a procedural ,

inadequacy..~The procedure ~ change was completed and Train j B was successfully ratested.  ;

s

7. Auxiliary Building Filter Assembly Heaters: ,

i There were seven surveillances performed on Train.'A'.and  ;

six on Train ' B. In all the cases, the surveillance  :

acceptance criterion was met. l corrective maintenance records for the auxiliary building filter system equipment within the scope of this review have ,

also been ' reviewed. The corrective maintenance on the ,

equipment involved a variety of tasks, the majority of which l were involved with charcoal filter inspections and charcoal .j removal for analysis, air and motor operating damper j adjustments, hydrometer oil leak repairs, flow switch  !

modifications and adjustments, and pressure controller and instrument relay modifications and adjustments. The majority l of the charcoal filter inspection and charcoal removal for- l analysis tasks were done after a filter c'ompleted greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of run time. Taking into account the number of l surveillances performed, inservice testings, and enhancements-made~ to the auxiliary building ventilation -system in-  ;

conjunction with the SLCRS, the reliability, of the ABFS is l considered acceptable. Modifications made to the auxiliary ,

building ventilation system are evaluated below.-

The corrective maintenance performed does not indicate any generic ABFS problems. The highest number of actions involved the HEPA and charcoal filters. The corrective maintenance ,

tasks reviewed could be performed with the plant on line. '

I The preventive maintenance for the ABFS that is performed on an 18-month interval is limited to verifying the capacity of l the heaters in the filter housing units (3HVR*FLT1A&B). These heaters have passed their maintenance checks. Therefore, there is no indication that . extending the surveillance frequency would cause deterioration of these heaters, other preventive maintenance tasks are performed at intervals greater' than 18 months. For these tasks, the frequency can either be shortened, or the task can be performed at power.

Proper automatic operation of the ABFS exhaust fan'and its variable inlet vane was not properly established in the initial startup testing. On September 29, 1992, the 'B' train of the SLCRS was declared inoperable, after an in-depth review of timing sequence of the 'B' train ABFS fan coupled with a '

determination that the ABFS fans were required to assist the SLCRS. On September 29, 1992, a test was performed on the

l U.S. Nuclear Regulatory Commission

! B15263/ Attachment 4/Page 11 July 17, 1995 SLCRS Train 'A' using actual accident timing sequences. The results showed that Train 'A' SLCRS did not achieve a 0.25 negative pressure within 50 seconds inside the secondary containment SLCRS. On October 31, 1992, a successful SLCRS i negative pressure drawdown test was performed followed by plant startup on November 4, 1992.  !

During the 1993 (Cycle 4) refueling outage, more extensive testing showed that the ABFS/SLCRS would not drawdown the secondary containment within 60 seconds. During the outage, the 18-month surveillance testing of the ABFS Train 'A' fan identified a delay in the start caused by an inherent design characteristic of the flow switch in the circuit. Design changes were made to the ABFS to allow specific equipment to start as soon as possible after a loss-of-power event coincident with an accident signal. Also, safety-related unit heaters were installed in the auxiliary building and winter /

summer system damper position and switchover dates were established. On October 24, 1993, a SLCRS/ABFS negative pressure drawdown was performed. These test results showed a negative pressure of 0.5 inches in water gauge at 120 seconds for both the A and B trains. In a letter dated November 4, 1993, NNECO proposed a license amendment to revise the technical specifications to state that the SLCRS must produce a negative pressure of greater than or equal to 0.4 inches

, water gauge as measured at the 24'6" elevation of the auxiliary l building within 120 seconds after a start signal. This i amendment was approved by the NRC followed by plant startup on November 7, 1993.

A PRA review of the proposed extension in the surveillance frequency concluded that the increase in public risk is negligible.

sienificant Hazards Consideratiori NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and concluded that the changes do not involve an SHC. The basis for this conclusion is that the three criteria of 10CFR50.92 (c) are not compromised. The proposed changes do not involve an SHC because the changes would not:r

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

1 The proposed changes to Surveillance Requirements 4.7.9.b l and 4.7.9.d of the Millstone Unit No. 3 Technical l Specifications extend the frequency for conducting several I verifications of the operability of the ABFS. Changing '

l the frequency of Surveillance Requirements 4.7.9.b and 4.7.9.d from at least once per 18 months to at least once 1

__________ - _ - _______________________________ ____________- ______-___ a

i

)

l U.S. Nuclear' Regulatory Commission *

]

B15263/ Attachment 4/Page.12' July-17,a1995 l

^

ench refueling interval does not change the basis for-the ,

frequency. Surveillance . Requirement 4.7.9.b contains

, additional requirements to perform' the applicable  !

verifications after any' structural maintenance on the HEPA filter or charcoal adsorber housings, or following '

painting, fire, or chemical release in any ventilation l zone communicating with the system. These requirements: -l will not be modified. l The proposed changes do not alter the intent or method by- ,

which the surveillances are conducted, do not involve any'  :

physical changes to the plant, do not alter the way.any. '1 structure, system, or - component functions, and do J not '

modify the manner in which the plant is operated. .As i such, the proposed changes in the frequency of l Surveillance Requirements ' 4.7.9.b and 4.7.9.d will' not ~  !

degrade the ability of the ABFS from performing. its safety  ;

function.

Also, the automatic actuation logic and relays responsible i for starting the ABFS are required to be tested by-  !"

Surveillance Requirement 4.3.2.1 of the Millstone Unit No. 3 Technical Specifications.

Equipment performance over the last four operating cycles.

was evaluated to determine the-impact of extending the ~;

frequency of Surveillance Requirements 4.7.9.b and 4.7.9.d. This evaluation included a review of' surveillance results, preventive maintenance records, and. l the frequency and type of ' corrective maintenance. The l results of the tests conducted during the last four cycles demonstrates that the reliability of the ABFS is ,

acceptable.

Based on the above, the proposed changes to Surveillance

~'

Requirements 4.7. 9.b and 4.7.9.d of the Millstone Unit No. 3 Technical Specifications does not involve a 1 significant increase in the probability or consequences of  !

an accident previously analyzed.  :

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

The proposed changes to Surveillance Requirements 4.7.9.b .i and 4.7.9.d does nct modify the design or operation of any  !

plant system. The proposed changes do' not alter the'  !

intent or method by which the surveillance is conducted other than increasing the interval from 18 months to (

24 months (nominal). The proposed changes do not 'j introduce a new failure mode. Therefore, the proposea  ;

a l

I

, , < .i y l J1 . , i,

- U.S. Nuclear Regulatory Commission

B15263/ Attachment 4/Page 13

, . July 17, 1995 changes do not create the possibility of a new or-different kind.of accident from'any previously analyzed.

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

Changing- the frequency of -Surveillance Requirements 4.7.9.b and 4.7.9.d from at least once per 18 months to at'

-least once each refueling interval does not change the basis for frequency. The proposed changes do not alter

. the way any structure, system, or component functions and_

do not modify the manner in which the plant is operated.

Further, the-previous history of reliability of the ABFS provides assurance that the changes will not affect the reliability of these ABFS components. Thus, the proposed changes have no impact on_the margin of safety.

C. Supplementary Leak collection and Release System (SLCRS) safety 1ssessment The function of the SLCRS is to ensure that radioactive material' that leaks from'the primary containment into the secondary containment following a design basis accident (DBA) is filtered out and adsorbed prior to any release to the

- environment. To accomplish this, the SLCRS works 1 in conjunction with the auxiliary building filter ' system _(ABFS) to maintain a negative pressure within the secondary containment. The SLCRS collects a portion of' the primary containment leakage from the buildings contiguous to the containment, which house the various containment penetrations and the engineered safety -features ' equipment. circulating radioactive fluids. This volume is then filtered and released to the atmosphere through the Millstone Unit No. 1 stock.

The SLCRS is comprised of two exhaust fans (each supplied from a separate. emergency bus), two filter banks (each consisting of a moisture separator, electric heater, prefilter, upstream HEPA filter, a charcoal adsorber, and a downstream HEPA filter), ductwork, and dampers. The SLCRS was designed to perform its intended safety function even with a single failure of an active component.

During normal operations, the SLCRS does not normally operate.

In the event of a DBA, it and the ABFS start on a receipt of a safety injection signal.

The operability of the SLCRS is verified by Surveillance Requirements 4.6.6.1.a through f. Surveillance Requirement 4.6.6.1.a requires, that the SLCRS;be demonstrated operable at least once per 31 days on a staggered test basis, by initiating, from the control room, flow through the HEPA

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 14 July 17, 1995 filters and charcoal adsorbers, verifying the flow rate, and operating the system for a minimum period of time.

Surveillance Requirements 4.6.6.1.b, c, e, and f require testing to verify HEPA filter performance, charcoal adsorber efficiency, system flow rate, and the physical properties of the activated charcoal. Surveillance Requirement 4.6.6.1.d verifies 1) the pressure drop across the combined HEPA filters and charcoal adsorber banks, 2) that the SLCRS starts on a safety injection test signal, 3) the production of a negative pressure of greater than or equal to 0.4 inch water gauge in the auxiliary building within 120 seconds after a start signal, and 4) the heaters dissipate 50 i 5 kW. .

l.

Currently, Surveillance Requirements 4.6.6.1.b and d are required to be performed at least once per 18 months. NNECO is proposing to change this frequency to at least once each refueling interval (i.e., nominal 24 months). Changing the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d from at least once per 18 months to at least once each refueling interval does not change the basis for the frequency.

Surveillance Requirement 4.6.1.1.b contains additional requirements to perform the applicable verifications after any structural maintenance on the HEPA filter or charcoal adsorber housings, or following painting, fire, or chemical release in any ventilation zone communicating with the system. These ,

I requirements are not being modified.

Also, the automatic actuation logic and relays responsible for ,

i starting the SLCRS are required to be tested by Surveillance Requirement 4.3.2.1 of the Millstone Unit No. 3 Technical Specifications. Surveillance Requirement 4.3.2.1 requires monthly actuation logic tests and master relay tests and quarterly slave relay tests for the safety injection automatic actuation logics and actuation relays be conducted.

Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of Surveillance Requirements 4. 6. 6.1.b and 4.6.6.1.d. This evaluation included a review of surveillance results, preventive maintenance records, and the frequency and type of corrective maintenance. Table 1 provides a listing of the equipment tested by Surveillance Requirements 4. 6. 6.1.b and 4.6.6.1.d.

For the surveillances conducted to satisfy Surveillance Requirements 4.6.6.1.b and d, the SLCRS have passid ~each of the surveillances except two. On July 23, 1990, he\B ' train of the SLCRS failed two surveillances. One of these 4ai-lures was due ,

to running the surveillance with 3HVR*DMPR13B locked and wired I open, while the other failure was attributed to having the main steam valve building dampers 3HVV* MOD 51A, B, C, and D open I

l

i U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 15 July 17, 1995 1

during test. A follow-up surveillance test on the same day was performed with acceptable results. Recent successful SLCRS negative pressure surveillances were performed on train 'B' after completing boundary work on March 6, 1995, and on train

'A' and 'B' nearing the completion of RFOS on May 30, 1995.

In addition, each system train of SLCRS and ABVS and its equipment is proven operable based on a required staggered monthly surveillance. The surveillance verifies fan start, flow through HEPA filters and charcoal adsorbers, system flow rate and heater operation. Based on these results, the i reliability of the SLCRS is considered to be high.

Taking into account the number of surveillances performed, inservice testings and enhancements made to the auxiliary building ventilation system in conjunction with the SLCRS, there is a high level of confidence that the SLCRS will be operational to provide its safety-related function and t ie reliability of the SLCRS is considered acceptable.

Modifications made to the auxiliary building ventilation system are evaluated in the safety assessment of surveillance extension for the auxiliary building filter system (i.e.,

Specification 3.7.9).

In Amendment No. 87,m the acceptance criteria for Surveillance Requirement 4.6.6.1.d.3 was revised. In October 1993, a series of tests were conducted which confirmed that the SCLRS in conjunction with the ABFS would be able to drawdown the secondary containment to a negative pressure greater than or equal to 0.4 inches water gauge within 120 seconds following a safety injection signal.

The corrective maintenance performed on the SLCRS equipment included the inspection and repair of dampers and seals, the investigation of low system flow, the removal and analyzing of charcoal, the removal and replacement of HEPA filters, and the investigation of removal of damper fusible links. To improve the operation of the SLCRS, the fan wheel from 3HVR*FN12A/B was replaced with an increased diameter with the same design. The new wheel provides a broader operability range for the fan. r No flow irregularities have been identified since the modification. The corrective maintenance performed does not indicate any generic SLCRS problems. The highest number of actions involved the HEPA and charcoal filters. The corrective maintenance tasks reviewed could be performed with the plant on line.

i (1) V. L. Rooney letter to J. F. Opeka, " Issuance of Amendment (TAC No. M87216)," dated December 8, 1993.

I l

l 1

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 16 July 17, 1995 l l

The preventive maintenance for the SLCRS that is performed on I an 18-month interval is limited to verifying the capacity of the heaters in the filter housing units (3HVR*FLT3A&B). These heaters have passed their maintenance checks. Therefore, there is no indication that extending the surveillance frequency would cause deterioration of these heaters. Other preventive maintenance tasks are performed at intervals greater than 18 months. For these tasks, the frequency can either be shortened, or the task can be performed at power.

A PRA review of the proposed extension in the surveillance frequency concluded that the increase in public risk is negligible.

Sionificant Hazards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and concluded that the changes do not involve an SHC. The basis for this conclusion is that the three criteria of 10CFR50.92 (c) are not compromised. The proposed changes do not involve an SHC because the changes would not:

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

The proposed changes to Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d of the Millstone Unit No. 3 Technical Specifications extend the frequency for conducting several verifications of the operability of the SLCRS. Changing the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d from at least once per 18 months to at least once each refueling interval does not change the basis for the frequency. Surveillance Requirement 4.6.6.1.b contains additional requirements to perform the applicable verifications after any structural maintenance on the HEPA filter or charcoal adsorber housings, or following painting, fire, or chemical release in any ventilation zone communicating with the system.

These requirements will not be modified.

The proposed changes do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. As  ;

such, the proposed changes in the frequency of '

Surveillance Requirements 4. 6. 6.1.b and 4. 6. 6.1.d will not degrade the ability of the SLCRS from performing its safety function.

t j

' U'.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 17 July 17,.1995 Also, the automatic actuation logic and relays responsible for starting the SLCRS are required to be tested by Surveillance Requirement 4.3.2.1 of the Millstone Unit.

No. 3 Technical Specifications.

Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d. This evaluation included a -review of ,

surveillance results, preventive maintenance records, and-the frequency and type of corrective maintenance. The results of the tests conducted during the last four cycles .

demonstrates that the reliability of the SLCRS is  !

acceptable.

Based on the above, the. proposed changes to Surveillance- ,

Requirements 4. 6.6.1.b and 4. 6. 6.1.d of the Millstone Unit No. 3 Technical Specifications does not involve a ,

significant increase in the probability or consequences of an accident previously analyzed.

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

The proposed changes to surveillance Requirements 4.6.6.1.b and 4.6.6.1.d of the Millstone Unit No. 3 Technical Specifications extend the frequency for ,.

conducting several verifications of the operability of the SLCRS. Changing' the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d from at least once '

per 18 months to at least once each refueling interval does not change the basis for the frequency.

The propased changes do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. As such, the proposed changes in the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d will not degrade the ability of the SLCRS from performing its '

safety function. The proposed changes do not introduce a new failure mode.

Based on the above, the proposed changes to surveillance Requirements 4.6.6.1.b and 4.6.6.1.d of the Millstone Unit No. 3 Technical Specifications will not create the possibility of a new or different kind of accident from any previously evaluated.

1

i

\

l ' .{ ,f U.S.= Nuclear' Regulatory Commission B15263/ Attachment 4/Page 18 July;17, 1995-

3. Involve a significant reduction!in'a' margin of safety.

1 The proposed- ' changes to . Surveillance- Requirements "4.6.6.1.b and 4.6.'6.1.d of the Millstone Unit ~ No. 3 Technical Specifications extend the frequency for-conducting several verifications of the operability of. the SLCRS. Changing -the frequency- of- Surveillance Requirements - 4. 6.6.1.b and . 4.6.6.1.d from at . least once per 18 months to at least once'each refueling interval does not change the basis for the frequency.

The proposed changes do not alter the intent.or method by which the surveillances are conducted, do not involve any.

physical changes to the plant,.do not alter the way any structure, system, or component functions, and do not modify the manner in ' which the plant is operated. As-such, the proposed changes in the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d will not degrade the ability 'of the SLCRS from . performing its safety function.

! Also, the automatic actuation logic and relays responsible for starting the SLCRS are required to be tested by Surveillance Requirement 4.3.2.1 of the Millstone Unit No.

3 Technical Specifications.

Equipment performance over the last four operating cycles was evaluated to determine the impact ' of extending the frequency of Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d. This- evaluation included a review of surveillance results, preventive maintenance records, and.

the frequency and type of corrective maintenance. The results'of the tests conducted during the last four cycles demonstrates that the reliability of the SLCRS is

acceptable.

t Based on the above, the proposed changes to Surveillance Requirements 4.6.6.1.b and 4.6.6.1.d of the- Millstone Unit No. 3 Technical Specifications do not- involve a significant reduction in the margin of safety.

D. Fuel Buildincr Exhaust Filter System Safety Assessment The fuel building ventilation system is designed to maintain a suitable environment for equipment operation and to limit potential radioactive release to the atmosphere during normal operation and postulated fuel handling accident conditions.

The system consists of a nonsafety-related air supply system i . . i r . .. .,

U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 19 l' July 17, 1995 and one safety-related and one nonsafety-related exhaust system.

The supply air system includes three nonsafety-related 50 percent capacity heating and ventilation units, nonsafety-related modulating damper, safety-related fuel building isolation damper, and nonsafety-related spent fuel pool area air heater.

The safety-related exhaust system consists of two redundant 100 percent capacity filter assemblies and associated exhaust fans and isolation damper. Prior to Amendment 105, Limiting Condition for Operation (LCO) for the fuel building exhaust filter system required that the two independent systems shall be operable whenever the irradiated fuel is in the storage pool. In addition, the LCO required that at least one fuel building exhaust filter system shall be in operation whenever any evolution involving movement of fuel within the storage pool or crane operations with loads over the storage pool is in progress. This applicability requirement has been revised via License Amendment 105. Specifically, the fuel building exhaust filter system is now required to be operable whenever irradiated fuel with less than 60 days decay is in the storage pool. Therefore, the operation of this system during fuel handling is not required unless the irradiated fuel with less than 60 days decay is in the storage pool.

Surveillance Requirement 4.9.12.b demonstrates the operability of the fuel building exhaust filter system by: (1) verifying that it satisfies in-place penetration and bypass leakage testing acceptance criteria, (2) verifying, within 31 days of removal, that a laboratory analysis of a representative carbon sample meets its acceptance criterion, and (3) verifying a system flow rate of 20,700 cfm 10 percent during system operation.

Surveillance Requirement 4.9.12.d demonstrates the operability of the fuel building exhaust filter system by: (1) verifying '

the pressure drop across the combined HEPA filters and charcoal adsorbers at operating system flow rate, (2) verifying that the j system is capable of maintaining the spent fuel area at a l negative pressure of greater than or equal to 1/4 inch of water gauge (WG) relative to the outside atmosphere during system operation, and (3) verifying that the heaters dissipate specified kW when tested.

The above surveillances are required to be performed at least once per 18 months. NNECO is proposing to extend the frequency of Surveillance Requirements 4.9.12.b and 4.9.12.d from at j least once per 18 months to at least once each refueling '

interval (i.e., nominal 24 months). Surveillance Requirement

I U.S. Nuclear Regulatory Commission B15263/ Attachment 4/Page 20 July 17, 1995 l 4.9.12.b contains additional requirements to perform the applicable' verifications after any structural maintenance on the HEPA filter or charcoal adsorber housings, or the following 1 painting, fire, or chemical release in any ventilation zone communicating with the system. These requirements are not being modified.

The proposed change to Surveillance Requirement 4.9.12.2 merely makes the surveillance consistent with the Applicability Section of Specification 3.9.12. No other changes are proposed. Therefore, the change to Surveillance Requirement 4.9.12.2 has no impact on the plant safety.

The proposed changes to Surveillance Requirements 4.9.12.b and 4.9.12.d do not alter the intent or method by which the surveillances are conducted, do not involve any physical changes to the plant, do not alter the way any structure, system, or component functions, and do not modify the manner in which the plant is operated. As such, the proposed changes to the frequency of Surveillance Requirements 4.9.12.b and

4. 9.12.d will not degrade the ability of the fuel building exhaust filter system to perform its function.

Equipment performance over the last four operating cycles was evaluated to determine the impact of extending the frequency of Surveillance Requirements 4.9.12.b and 4.9.12.d. This evaluation includes a review of surveillance results, preventive maintenance records, and the frequency and type of corrective maintenance. The components covered under Surveillance Requirements 4.9.12.b and 4.9.12.d are shown on Table 2. The summary of the surveillance test scope and results are provided below:

1. In-place Penetration and Bypass Leakage Testing:

There were five surveillances performed on Train 'A' and five on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

2. Fuel Building Exhaust Filter System Charcoal Analysis:

There were five surveillances performed on Train 'A' and five on Train 'B.' In all the cases, the surveillance acceptance criterion was met.

3. Fuel Building Exhaust Filter System Flow Rate:

There were five surveille..ces performed on Train 'A' and five on Train 'B.' In all the cases except one, the surveillance criterion was met. The failure on Train 'B'

j

- ')'

1 1

C

U.S.' Nuclear Regulatory Commission B15263/ Attachment'4/Page 21' July ~17, 1995~

The Train

,was'possibly due to a roll-up. door being open. ll

'B' was ratested.successfully.  ;

4. Fuel Building Exhaust Filter System Bank Pressure Drop: q There were five surveillances performed on Train 'A'.and five on Train 'B.' In all the cases, the surveillance-  ;

criterion was met.

5. Fuel Building Exhaust Filter System:

There were six surveillances performed on Train-'A' and six on Train 'B. ' In all the cases, except for one. i Train 'A' and Train 'B' surveillance, the criterion was ,

i met. The failure of the negative pressure tests-were caused.by an improperly calibrated damper controller. The Train 'A' and 'B' surveillances were performed ,

successfully.  ;

6. Fuel Building Exhaust Filter Assembly Heaters: .

There were seven surveillances performed on Train 'A' and  !

seven on Train 'B.' In all the cases, the surveillance'  !

criterion was met. -

The results of the review of the past. corrective: maintenance.

on the equipment do not suggest .that an extension of the interval between testing would have. . an adverse affect on-safety.

The only preventive maintenance required for the system on an 18 month frequency'is the check of the power dissipation'by the - i electrical heaters. This is covered by Surveillance 1 Requirement 4.9.12.d(3) on an 18 month basis. In addition, the results of the review of the preventive maintenance 'on the i equipment do not - suggest that an extension of the interval i between testing would have an adverse affect on safety.

A PRA review of the proposed extension in the. surveillance frequency concluded that the increase in public risk is ,

negligible. t Sianificant Hazards Consideration f NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that the changes do'not involve

, an SHC. The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed -

changes do not involve an SHC because the changes would not: l i

I i

. . .n. . _ . . _ __ _ . . _ , _ _ __ _ - _ .I

1 i

.l

. U.S. Nuclear Regulatory Commission  ;

_B15263/ Attachment 4/Page 22 ~

July 17, 1995

1. - Involve a significant increase in the probability or -

consequences of an accident previously-~ evaluated.

. The proposed changes to Surveillance' Requirements 4.9.12.b

~

l and 4.9.12.d extend the frequency.for demonstrating the-  !

operability of the fuel building exhaust' filter system. 'l The proposed changes would extend the frequency from at  :

i least once per 18 months to at least once-each refueling' interval (i.e., nominal 24 months). ,

The proposed changes do not alter the' intent or method by ,

^

which the surveillances are conducted, do not alter the way any structure, system, or component functions, and do not modify the manner in which the. plant is operated. In ,

addition, the acceptance. criterion for each surveillance is unchanged. As L such, the proposed ~ changes in the I frequency of Surveillance Requirements 4.9.12.b and I 4.9.12.d will not degrade the ability of the fuel building exhaust filter system to perform its function. ,

The evaluation of past surveillances, preventive-maintenance records, and the frequency and type. of i corrective maintenance _ concluded that decreasing.-the frequency will have-little impact on safety. ~

Since-the  ;

proposed changes only affect the surveillance frequency, '

the proposed changes cannot affect the probability of.any previously analyzed accident. 'While the proposed changer j can- lengthen the intervals between surveillances, the increase in the interval has been evaluated and it is '

concluded that' there is no significant impact on the reliability or availability of the fuel building-exhaust l filter system, and consequently, there is.'no impact on the ,

consequences of any analyzed accident.

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

i The proposed changes to Surveillance Requirements 4.9.12.b l and 4.9.12.d do not modify _the design or operation of any ,

plant system. The proposed changes do not J alter the- i intent or method by which the surveillance is conducted 1 other than increasing the interval from 18 months to.24 months (nominal). The proposed changes do not introduce-a new failure mode.- Therefore, the proposed. changes do not create the possibility of a new or-different kind of accident from any previously analyzed.

3. Involve a significant reduction in a margin of safety. 'l changing the frequency of Surveillance Requirements

. 4.9.12.b and 4.9.12.d from at least once per 18 months to l

i l

U.S. Nuclear.' Regulatory Commission ,

B15263/ Attachment 4/Page.23 .

July 17, 1995 atIleast once each refueling interval does not change the  !

basis.for frequency. The proposed changes do not alter '

the intent or~ method by which the surveillances are conducted, do not involve any physical changes to'the plant, do not alter the way any structure, system, or i component functions, and do not modify the manner in which the plant is operated.- Further, the previous history.of reliability of the fuel building exhaust filter system provides assurance that the changes will not affect the reliability of the system. Thus, the proposed changes 3 have no impact on the margin of the safety.

3 Y

P I

i

'I

?

b i

7 r , -

r-

Paga 1 of 6 TABLE 1 Equipment Covered by Technical Specification Surveillance 4.7.7.c and e, and 4.7.8.c EQUIPMENT DESCRIPTION ACTUATION 3HVC*TKlA, B, C. D, Control Room Pressurization Air Storage CBI E, F, G, H, and J Tank 3HVC*SOV74A control Room Pressurization Air Storage CBI Tanks Discharge Valve 3HVC*SOV74B Control Room Pressurization Air Storage CBI Tanks Discharge Valve 3HVC*PCV68A Control Room Pressurization Air Storage CBI Tanks Discharge Pressure Control Valve 3HVC*PCV68B Control Room Pressurizttion Air Storage CBI Tanks Discharge Pressure Control Valve 3HVC*RV125A1 Control Room Pressurization Air Storage 2,450 psig Tanks Pressure Relief Valve 3HVC*RV125A2 Control Room Pressurization Air Storage 2,450 peig Tanks Pressure Relief Valve 3HVC*RV125B1 Control Room Pressurization Air Storage 2,450 psig Tanks Relief Valve 3HVC*RV125B2 control Room Pressurization Air Storage 2,450 psig Tanks Relief Valve 3HVC*AOD25 Control Room Emergency Ventilation Closes CBI Outside Air Intake Damper Open: Manual 3HVC*AOD26 Control Room Emergency Ventilation Closes CBI Outside Air Intake Damper Open Manual 3HVC*AOD27A&B Control Room Emergency Ventilation Closes CBI Bypass Dampers Opent Manual 3RVC* MOD 33A Control Room Emergency Ventilation Open on Train B Filter Unit A Inlet Damper Low Flow or Manual 3HVC* MOD 33B Control Room Emergency Ventilation Open on Train a Filter Unit B Inlet Damper Low Flow or Manual 3HVC*FLT-1A Control Room Emergency Ventilation During 3HVC*FN1A Train A Filter Operation 3HVC*FLT-2B Control Room Emergency Ventilation During 3HVC*FN1B Train B Filter Operation 3HVC**FLT-1A Train A Control Room Emergency Train A Filter Assembly Heaters Ventilation Filter Assembly Heaters Fan Running and Low Supply Temperature 3HVC*FLT-1B Train B Control Room Emergency Train A Filter Assembly Heaters Ventilation Filter Assembly Heaters Fan Running and Low Supply Temperature

]

l TABLE 1 Page 2 of 6 l Equipment Covered by Technical Specification .-

surveillance 4.7.7.c and e, and 4.7.8.c (cont'd.)

i 59UIPMENT DESCRIPTION ACTUATION l i

3HVC*FNlA Control Room Emergency Ventilation Filter Unit'"A"  ;

Exhaust Fan, Train A Inlet Damper 3HVC* MOD 33A Open ,

3HVC*FN1B Control Room Emergency Ventilation Filter Unit "B" Exhaust Fan, Train B Inlet Damper l 3HVC* MOD 33B Open  ;

3HVC*FS38A Control Room Emergency Ventilation Continuous 4 Train A Supply Flow Switch l 3HVC*FS38B Control Room Emergency Ventilation Continuous Train 3 Supply Flow Switch r

F L

o l

I l

i

Pcgs 3 of 6 TABLE 1 ,

4 Equipment covered by Technical specification j surveillance 4.7.9.b and d '

I EQUIPNENT DESCRIPTION ACTUATION 3HVR*FLTlA Auxiliary Building Filter Train A, Starts on SIS, includes HEPA and Charcoal Filters CDA, LOP 3HVR*FLTlB Auxiliary Building Filter Train B, Starts on SIS, includes HEPA and Charcoal Filters CDA, LOP 3HVR*FNGA Auxiliary Building Filter Exhaust Fan Starts on SIS, j Train A CDA, LOP j i

3HVR*FN6B Auxiliary Building Filter Exhaust Fan Starts on SIS, Train B CDA, LOP 3HVR*AOD20A Auxiliary Building Filter A Inlet Opens on SIS, Isolation Damper CDA, LOP 3HVR*AOD20B Auxiliary Building Filter B Inlet Opens on SIS, Isolation Damper CDA, LOP 3HVR* MOD 140A Auxiliarf Building Filter A Fan Inlet Varies with Damper (VIV) Supply Plenum Press 3HVR* HOD 140B Auxiliary Building Filter B Fan Inlet Varies with Damper (VIV) Supply Plenum Press 3HVR* MOD 28A Auxiliary Building Filter Fan 6A Opens on SIS, Exhaust Isolation Damper CDA, LOP 3HVR* MOD 28B Auxiliary Building Filter Fan 6B Opent on SIS, Exhaust Isolation Damper CDA, LOP 3HVR&PT104A Auxiliary Building Supply Plenum Continuous Pressure Transmitter Train A 3HVR&PTIO4B Auxiliary Building Supply Plenum Continuous Pressure Transmitter Train B 3HVR*AOD44A1 Auxiliary Building Normal Ventilation Close on SIS, Exhaust Isolation Damper CDA, LOP 3HVR*AOD44B1 Auxiliary Building Normal Ventilation Close on SIS, Exhaust Isolation Damper CDA, LOP 3HVR*HTRIA Train A Auxiliary Building Filter Train A Filter (3HVR*FLTlA Assembly Assembly Heaters Fan Running and Heaters) Low Supply ,

Temperature j 3HVR*HTRIB Train B Auxiliary Building Filter Train B Filter (3HVR*FLTlB Assembly Assembly Heaters Fan Running and Heaters) Low Supply Temperature 3HVR*AOD29A/B Containment Ventilation Purge Exhaust Close on SIS, Isolation CDA, LOP 3HVR*AOD33A and 35A Auxiliary Building Train A Heating and Close on SIS Ventilation Supply Isolation Dampers 3HVR*AOD33B and 35B Auxiliary Building Train B Heating and Close on SIS j Ventilaticn Supply Isolation Dampers

TABLE 1 Pcgs 4 of 6 Equipment Covered by Technical Specification Surveillance 4.7.9.b and d (cont'd.)

EQUIPMENT DESCRIPTION ACTUATION l

3HVR*AOD42A/B Auxiliary Building General Area Close on SIS, i Ventilation Exhaust Isolation Dampers CDA, LOP l

3HVR$A9D43A/B Auxiliary Building General Area Close on SIS, Ventilation Exhaust Isolation Dampers CDA, LOP 3HVR*HVU2A/B Auxiliary Building Train A and B Stop on SIS Heating and Ventilation Units 3HVR-FN5 Auxiliary Building General Area Exhaust Stop on SIS, Fan CDA, LOP 3HVR-FN7 Auxiliary Building General Area Exhaust Stop on SIS, Fan CDA, LOP 3HVR*PS182A/B Auxiliary Building Filter Unit Pressure Continuous Switch Train A and B 3HVR*FS27A/B Auxiliary Building Filter Unit Flow Continuous Switch Train A and B 3HVR*TS175Al/B1 Auxiliary Building Filter Assembly Continuous Heater Temperature Switch

Pags 5 of.6 TABLE 1 Equipment Covered by Technical Specification Surveillance 4.6.6.1.b and d EQUIPMENT DESCRIPTION ACTUATION-3HVR*FLT-3A SLCRS Train A Filter SIS 3HRV*FLT-3B SLCRS Train B Filter SIS 3HVR*FLT-3A SLCRS Train A SLCRS Filter Assembly Heaters SIS Filter Assembly Heaters 3HVR*FLT-3B SLCRS Train B SLCRS Filter Assembly Heaters SIS Filter Assembly Heaters 3HVR*FN12A SLCRS Exhaust Fan, Train A SIS 3HVR*FN12B SLCRS Exhaust Fan, Train B SIS 3HVR*AOD95A SLCRS 3HVR*FLT-3A Inlet Isolation SIS Damper 3HVR*AOD958 SLCRS 3HVR*FLT-3B Inlet Isolation SIS Damper 3HVR*FS88A SLCRS Train A Flow Switch On Low Flow Sands Signal to Open 3HVR*AOD95B (Opposite Train Inlet Damper) 3HVR*FS88B SLCRS Train B Flow Switch On Low Flow Sands Signal to Open 3HVR*AOD95A (Opposite Train Inlet Damper)

~ ~

7

}

Pags 6-of.6  !

f i

l l

TABLE 1 l Equipment Covered by Technical specification I surveillance 4.9.12.b(1),(2) & (3) l and 4.9.12.d(l),(2) & (3) l t

l agUIPMENT DESCRIPTION -

?

3HVR*FLT2A 'A' Train Fuel Building Filter Assembly 3HVR*FLT2B 'B' Train Fuel Building Filter Assembly 3HVR*HTR2A 'A' Train Fuel Building Filter Assembly Heater 3HVR*HTR2B 'B' Train Fuel Building Filter Assembly Heater 3HVR*FNIOA 'A' Train Fuel Building Exhaust Fan ,

3HVR*FNIOB 'B' Train Fuel Building Exhaust Fan 5 3HVR* MOD 72A 'A' Train Fuel Building Exhaust Fan Outlet Damper 3HVR* MOD 72B 'B' Train Fuel Building Exhaust Fan Outlet Damper j 11tl'PS209A 'A' Train Fuel Building Exhaust Fan Control Pressure Switch ,

3HV.t-PS209B 'B' Train Fuel Building Exhaust Fan Control Pressure Switch  ;

3HVR*FS73A 'A' Train Fuel Building Exhaust. Fan Flow Switch [

'i 3HVR*FS738- 'B' Train Fuel Building Exhaust Fan Flow' Switch  !

l 3HVR*AOD80A 'A' Train Fuel Building Filter' Inlet Isolation Damper

{

3HVR*AOD80B 'B' Train Fuel Building Filter Inlet Isolation Damper f 3HVR*AOD81A 'A' Train Fuel Building Filter Bypass Damper l 1

3HVR*AOD81B 'B' Train Fuel Building Filter Bypass Damper 3HVR*AOD184 Fuel Building Supply Air Isolation Damper l ,

q l

l i

f o l l  !

l' I

i

- - - . .. .-. .