ML20205F826

Forwards List of Proposed Revs,Additions & Clarifications to Exceptions Taken to Reg Guides 1.52 & 1.140 in Facility Fsar.Changes Will Be Included in Future FSAR Amend

ML20205F826
Person / Time
Site:	Braidwood
Issue date:	03/25/1987
From:	Hunsader S COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.052, RTR-REGGD-01.140, RTR-REGGD-1.052, RTR-REGGD-1.140 2883K, NUDOCS 8703310304
Download: ML20205F826 (14)

Text

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'" 3 )One Commonwealth Edison First National Plaza Chicago, II:nois Address Reply to: Post OffcJ Box 767 Chicago, Illinois 60690 0767 March 25, 1987 Mr. Harold R. Denton U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, DC. 20555

Subject:

Braidwood Units 1 and 2 Proposed Exceptions to FSAR Appendix A Regulatory Guides 1.52 and 1.140 NRC Docket Nos. 50-456/50-457

Dear Mr. Denton:

Attached is a listing of proposed revisions, additions, and clarifications to the exceptions taken to Reg. Guides 1.52 and 1.140 in FSAR, Appendix A for Braidwood Station along with detailed justifications to support our submittal. Some of the proposed items are new topics and require NRR review while others have already been reviewed by NRR. Those cases previously reviewed by NRR are so noted in the listing.

These are being submitted for early NRC review and as advanced notification that they will be included in a future FSAR amendment.

l Please address any questions concerning this matter to this office.

[ %A l S. C. Hunsader Nuclear Licensing Administrator

/klj cc: J. Stevens NRC Resident Inspector-Braidwood 2883K k

P O i goo l l ,

l

Brcidwood JanuIry 29, 1987".

Exception to Reg. Guide 1.52 Page 1 y s

Revisions, Additions or Justifications for 1.52 Exceptions included in Clarifications to Exceptions Exception and Clerifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 .

c.2.a Entrained water droplets are not None considered credible due to significant quantitles of ductwork with elbows. Water droplets, if present, will Impinge on ducts and drop out of vertical duct risers as the air enters exhaust plenums.

Fbwever, the auxiliary building exhaust system does contain profilters which can serve as demisters.

Revision:

c.2.f The auxillary building non-accessible area The auxiliary building non-accessible area Updating system flows to reflect exhaust FIIter system consists of three exhaust Filter system consists of three built-up system current design.

built-up Filter trains (one standby) with Filter trains (one standby) with a rated a capacity of 66,000 cfm each. For capacity of 63,000 cfm each. The system design maintenance purposes each train is divided exhaust flow is 62,730 For maintenance into three banks with each bank sized for purposes each train is divided into three bank seven filters wide and three high. w!th each bank sized for seven filters wide and three high.

The auxiliary building accessible area Revision: Updating system flows to reflect exhaust Filter system has a capacity of The auxiliary building accessible area exhaust 8Y8 ** # U"*0' *$'9"'

162,300 cfm. This system consists of four Filter system has a rated capacity of 189,000 built-up Filter trains (one standby), and cfm. The system design exhaust flow is 125,990.

each train is divided into three banks. This system consists of four built-up Filter Each bank is sized for seven filters wide trains (one standby), and each train is divided and three filters high*

Into three banks. Each bank is sized for seven filters wide and three filters high.

Clarification:

c.2.f None Clarifying the fact tha't control room The Control Room Recirculation Filter unit is recirculation Filter is > 30,000 CFM.

designed for 49,500 cfm. Filter ef ficiency will be tested at this capacity. The Filter Train 4 consists of two banks with grating between the Filter banks. Each Filter bank is three filters high and eight wide. ,

ATTACHMENT 1 Page 1 of 13

Br;Idunod fanuary 29,198[,

Exception ta Reg. Guide 1.52 Pago 2 ,.

Revisions, Additions or Justifications for 1.52 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 .

c.2.f Filter trains are not designed to be None removable from the building as an intact unit. The size of the train precludes shipment off-site and there are no facIIIties for onsite disposal of the intact unit. The Filter elements are removable and can be disposed of through the solid radwaste system.

c.2.g All ESF Filter systems have local control Delete Exception This exception was taken with regards panel airflow Indication. In addition, to tIO5 flow Indication on MCP since the flow rate in each of the stacks is other means are available to recorded at the local control panel . The determine f low. However, since a airflow rate through the control room design change was made to provide emergency makeup air Filter units and the 1I05 flow on MCP this exception is no auxiliary building and fuel handling longer required.

building exhaust charcoal booster fans is continuously sensed.

The dif ferential pressure across all of Delete Exception the ESF Filter unit fans is Indicated on local control panels. High and low differential pressure, and fan trip annunciation is provided on the main control panet. The setpoints for low and high dif ferential pressure alarms will be such that flows at;tIOS of design flow, will be alarmed at the main control panel in the form of low or high dif ferential pressure.

The dif ferential pressurts across all HEPA filters are Indicated on i scal control Delete Exception panels. In addition, the pJessure drop across HEPA filters upsyream of charcoal filters is recorded in the main control room. High dif ferential presss re across all HEPA filters is annunciated on the main control panel and on local control panel s. Upset conditions will toerefore be identified to the control room operator allowing him to take appropriate action. .

Page 2 of 13

Brcidwood Januiry 29,198f, I

Exceptiom to Reg. Guide 1.52 #aga 3 ,

i Revisions, Additions or Justifications for i I.52 Exceptions included in Clarifications to Exceptions Exception and Clari fications Article knend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 .

4 l

c.2.g The auxiliary building exhaust flow rate Delete Exception (Cont'd) and fuel handling building exhaust flow rare is continuously sensed by the exhaust I

stack airflow measuring equipment and recorded in a local control panel and by the plant computer. ,

c.2.1 Filter Housings Filter Housings t

All of the auxiliary building and fuel None handling building exhaust system Filter housings are designed in accordance with ANSI N509-76 The housings are at negative pressure with respect to their q surroundings and are located in auxiliary j building general area which is a low

airborne radiation environment. Any in-leakage from the general area will not adversely af f ect Appendix I releases.

Hence, the housings will not be leak

, tested to the ANSI N509 requirements.

However, Filter mounting leak tests will be perf ormed in accordance with ANSI N510-l 80 The control room emergency makeup air None -

l I

system Filter housings are designed in accordance with ANSI N509-76. The Filter housings are at negative pressure with l respect to their surroundings, and are located within the control room boundary which is a habitable environment the same as the control room. Any in-leakage will be f rom the control room environment and, therefore, will not adversely affect the

] quality of that environment; hence, the housings will not be leak tested to ANSI N509 requirements. However, Filter mounting frame tests will be performed in accordance with ANSI N510-80 I

Page 3 of 13

Brnidunod Jan uary 29, 1987' Exception ta Reg. Guide 1.52 Aags 4 '

Revisions, Additions or Justifications f or -

1.52 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 ,

c.2.1 Addition:

Field Weld Painting Field Weld Painting To avoid rust from forming on the None mounting frame surf ace in the time Field welds may be painted prior to mounting between the weld and performance of f rame leak test

• the leak test field welds may have been painted prior to the mounting frame leak test being performed. The painting of these welds will not significantly af fect the leak test results as the leakage through pin holes in welds is not significant.

Therefore, it is not necessary to remove paint from field welds prior to the mounting frame leak test being perf ormed.

c .2.1 Ductwork Ductwor k None AII auxiliary building and fuel handling building exhaust system ductwork upstream -

of the Filter units is under negative pressure with respect to its surroundings and is located in the same areas of the buildings served by the exhaust systems.

Any inleakage will be filtered prior to discharge to the atmosphere, hence, this ductwork will not be tested to ANSI N509 requirements, mwever, prior to the final system turnover, the non-accessible exhaust system of the auxiliary building HVAC system and the f uel handling building exhaust system will be operated and the ductuork will be visually and audibly '

checked for leaks. Leaks will be sealed.

All control room emergency makeup air system ductwork is located within the control room boundary which is a habitable -

environment. Any ductwork leakage will not adversely affect the habitability of the environment, hence, this ductwork will not be tested to ANSI N509 requirements.

Page 4 of 13

Br:Idwood January 29, 1987 Exception ts Reg. Guide 1.52 Pag 9 5 ,

Revisions, Additions or Justifications for 1.52 Exceptions included in Clarifications to Exceptions Exception and Clari fications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amand. 47 .

c.2.1 However, prfor to final system turnover, (Cont'd) the control room emergency makeup air system will be operated and visual and audible leaks in ductwork will be sealed.

The design airflow quantities for each system will be verified during testing, adjusting and balancing of the systems.

Deviations of more than +105 of the design flow quantities will be evaluated and any disposition will be documented.

Addition:

c.2.1 Flow Measurement Flow Measurement Use of a calibrated orifice to None A Calibrated orifice is used in Ileu of a gas measure air flow where an accurate flow totalizer for determining leakage, air flow reading is required, is an accepted industry practice (ref. SMACNA

" Testing, Balancing, and Adjusting of Environmental Systems", NEEE ' Procedural Standards for Testing Adjusting Balanc-Ing of Environmental Systems' NEEE

" Procedural Standards for Testing Adjusting Balancing of Environmental Systems; and ACGlH, 17th Edition,

Industrial Ventilation). As a call-brated of fice is as accurate as the i'

totalizing gas volume meter required by ANSI N510-1080, its use for measuring duct leakage is acceptable.

c.3.n None Addition: Refer to letter of July,2, 1986 from Miosi (CECO) to Denton (NRC) which Ductwork is designed, constructed, and tested in was accepted by PRR in SSER #2 dated accordance with the Intent of Section 5.10 of 10/86 ANSI N509-1976 The longitudinal seams, however, wIII be either seal we1ded or mechanical lock type (Pittsburgh lock with '

sealant). Silicone sealant is used as a permanent sealant for HVAC ductwork.

Page 5 of 13

o .

Br:Idwood J,an uir y 29, 1987 Exception to Reg. Guide 1.52 Pege 6 .

Revisions, Additions or Justifications for 1.52 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend 47 to FSAR in Amend. 47 to FSAR Since Amend. 47

• c.3.n None Add ition : Fan peak pressure (shut off) can only potentially occur in systems that Fan peak pressure test will not be performed. have isolation device's, such as For systems that have isolation devices, the firedampers, in the main flow f ans are provided with high dif ferential paths. High dif ferential pressure pressure trips or high/ low flow trips, trips and high/ low flow trips preclude fan from operating outside its normal range, c.3.p None Add ition :

The VA dampers will be tested to 15 Bubble tight isolation and shutof f dampers are bypass as required by Tech. Spec.

provided only for control room Intakes. Two parallel Olade isolation dampers in series are provided in VA System Non-Accessible Filter system charcoal Filter bypass.

c.4.b The space provided between components is 3 feet from the front (or rear) of the components to the nearest obstacle (Filter f rame or other Filter component) . This allows 3 feet of access between components.

c.5.b l'-flow distribution tests will be performed to ensure that the airflow through any individual Filter element does not exceed 120% of the element's rated capacity.

c.5.b None Clarification: The system design flow Is based on dirty Filter condition. This is to i Filtration Unit Airflow Capacity Tests will be clarity the Intent of N509-76 to perfonned at the system design pressure range perform stability / capability test corresponding to clean and dirty Filter pressure only at 1.25 x dirty Fliter i

fosses. Tests will be performed at I.25x dirty cond i tions. Fliter pressure Filter conditions to verif y system stability conditions are simulated for all i only. Filter pressure losses for airflow capacity tests will be simulated, without airflow tests to prevent change l

and/or depletion prior to air filters inplace.

distribution tests.

Page 6 of 13

Brcidwood Januar y 29, 1987*

Exception to Reg. Guide 1.52 6g3 7 *

~.

Revisions, Additions or Justifications for -

1.52 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 ,

c.5.b Add ition :

The VA System Accessible, Non-Accessible and The maximum flow capacity is Fuel Handling Building filters air capacity predicated on the filter rated tests will be performed to verify that maximum capacity + 105 to assure charcoal flow is not greater than + 105 of filter rated residence time. Final flow is capacity dependent on final test and balance which is uncertain but less than rated capacity. Low flow limit is not significant to filtration capability, c . 5.c None Addition: Refer to letter of July 2, 1986 from Miosi (CECO) to Denton (NRC) which Silicone sealant or other temporary patching was accepted by mR in SSER #2 materials will not be used in the ESF Filter housing. Silicone sealant is used, however, as a permanent sealant to HVAC ductwork, c.5.c. None Clarification: The testing DOP detector can obtain a representative sample with a sampling A sampling rato of less than 1 CFM will be rate less than 1 CFM.

employed for testing Fli tc Systems larger than 1000 CFM.

c.6.l(2) Pbne Clar i f ication : Refer to letter of August 21, 1986 from Miosi (CECO) to DeatM , (NRC)

All carbon furnish prior to 1985, as part of the which was accepted by mR in SSER a2.

original specification for atmospheric clean-up filtration units will be tested to the requirements of Table 5-1 of ANSI N509-1976.

All replacement carbon or original carbon furnished in 1985, or later, will be tested to the requirements of Table 5-1 of ANSI N509-1980, with the exception that the laboratory test for methyl lodine penetration at 30 C, 955 relative humidity is less than If.

c.6.a(3) None Clarification: Refer to letter of July 2, 1986 from Laboratory tests will be performed per approved Miosi (Ceco) to Denton (NRC) which I was accepted by mR in SSER #2 1 plant Technical Specifications.

Page 7 of 13

Br:Ifwood Jan uary 29, 1987 Exception to Reg. (kside I.140 P,ago 1 .'

Revisions, Additions or Justifications for -

1.140 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47

• c ol.a The equipment and components (excluding None c.I.b charcoal, Filter pads and separator pads) are designed to withstand a maximum of 40-year Integrated radiation dose and worst-case anticipated continuous service, rather than 40 years of continuous service, c.2.a All of the exhaust Filter systems contain None profilters, HEPA filters, fan and associated i nstrumentation. Charcoal adsorbers are only used when iodine is anticipated to be present, with heaters for over 705 relative humidity air streams.

c.2.b The purge system exhaust Filter train is None designed for 43,900 cfm. Filter ef ficiency wlit be tested at this capacity. The Filter train consists of two banks with a grating between the Filter banks. Each Filter bank is three filters high and seven wide.

Filter Housing Revision:

c.2.f Refer to letter of July 2, 1986 c.3.f All non-ESF Filter housings, exclusive of Delete reference to " post-LOCA purge unit". Miosci (CECO) to Denton (NRC) which the TSC and post-LOCA purge units, are at was accepfed by MtR in SSER #2 negative pressure with respect to their surroundings, and are located in areas which are low airborne radiation environ-monts. Any in-leakage will not adversely offeet Appendix I releases, hence, the housings will not be leek tested to the ANSI N509 requirements. However, all of the Filter mounting frames will be leak tested in accordance with ANSI N510-80 Page 8 of 13

Brtidwood Janu;ry 29, 1987.

• Exception ts Reg. Guide 1.140 Page 2 ,

Revisions, Additions or Justifications for -

1.140 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 e 1

! c.2.f The TSC unit housing Is located in an area Delete Underlined portion "The post-LOCA . . . Refer to letter of July 2, 1986, c.3.f where the airborne radiation level of the requirements". Miosci (CECO) to Denton (NRC) which

) (Cont'd) room air may exceed that of the air within was accepted by NRR in SSER #2 j the housing; however, it is at positive pressure with respect to the surroundings, I

hence, it will not be tested to ANSI-N509

. requirements. The Filter mounting frames

] will be leak tested In accordance with

! ANSI N510-80 The' post-LOCA purge unit housing will be leak tested to ANSI-N509-80 requirements.

2f and 3f Ductwork Ductwor k All of the ductwork upstream of the non* None j ESF Filter units is under negative l

pressure with respect to its surround ings. Ductwork upstream of the I

Filter units, except ducteork upstream of l the TSC Filter unit, is located In areas a

of low airborne radioactivity. Any in-

[ leakage will not adversely af fect Appendix j i releases, hence, it will not be tested

] to the ANSI N509 requirements.

l l The ductwork upstream of the TSC Filter j unit is located in the HVAC Equipment i Room. The quality of the equipment room l environment Is the same as that of the 1 outside air which is within the duct. An y leakage will be filtered prior to its release to the TSC environment, hence, j this ductwork will not be tested to the '

ANSI N509 requirement.

The following ducteork will be leak tested to the ANSI N509-80 requirements:

1 Pagpe 9 of 13

Brciducod ~

Jan uar y 29, 1987 Exception to Reg. Guide 1.140 Page 3 .

Revisions, Additions or Justifications for 1.140 Exceptions included in Clarifications to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 2f and 3f 1. Positive pressure ductwork for the None None (Cont'd) laboratory exhaust Filter unit outside the laboratory HVAC Equipment Room.

2. The positive pressure ductwork from the Radmaste Building exhaust Filter unit in the Auxillary Building.

3. The positive pressure ductwork f rom the volume reduction system area ventilation exhaust Filter that is located in the Radwaste Building.

4 The positive pressure ductwork from the Post-LOCA purge Filter unit.

5. AII non-safety-related system ductwork that is required to operate and is under pressure within the Control Room boundary during an abnormal or accident condition.

6 TSC negative pressure duct sr :tions outside the protected space where in-leakage would not normally be fIItered.

All remaining ductwork meets the exception of ANSI N509, or has negligible impact on ALARA practices and therefore, will not be leak tested. Positive pressure Radwaste

• Building exhaust ductwork in the Auxillary Bul1 ding will be tested before the radmaste volume reduction system is put j into operation. '

Page 10 of 13

- - . . - . .- . - -- - - - -- .. - - .. - - .- - - . - . - =. . ---

i Breldwood JInuary 29, 1987 .

Exception to Reg. Gaide 1.140 Phge 4 '

{

Revisions, Additions or Justifications'for 1.140 Exceptions included in Clarifications to Exceptions Exception and Clarifications ,  ;

Article Ament!. 47 to FSAR in knend. 47 to FSAR Since Amend. 47 l

c.2.f Field Weld Painting Addition: To avoid rust from forming on the Field weld Painting mounting frame surface in the time None between the weld and performance of

Field welds may be pqinted pelor to mounting the leak test field welds may have frame leak tests. been painted prior to the mounting frame leak test being performed. The painting of these welds will not significantly affect the leak test results as the leakage through pin l

j holes in welds is not significant.

Therefore, it is not necessary to remove paint from fleid welds prior j to the mounting frame leak test being performed,

]

i

] c .2.f Flow Measurement Addition:

i None Flow Measurement Use of a calibrated orifice to

) measure air f low where an accurate A calibrated orifice is used in lieu of a gas air flow reading is required, is an j

flow totalizer for determining leakage. accepted Industry practice (ref.

i I SMACNA ' Testing, Balancing and

Adjusting of Environmental Systems',

l NEEE ' Procedural Standards for Testing Adjusting Balancing of Environmental Systems' and ACGlH,  ;

17th Edition, Industrial j Ven t i l ation ) . As a calibrated orifice is as accurate as the

totalizing gas volume meter required

(

by ANSI N510-1980, its use for i

measuring duct leakage is acceptable.

c . 3.a The components of the heaters are manu- None factured and assembled as per Section 5.5 '

! of ANSI N509-76, similar to the require-ments of heaters in safety-related Filter j systems, but the traceability of the compo-l nents is not established as It would be in j

i the case of safety-related heaters. Thus, j no complete qualification program is done.

I i

j Page 11 of 13

Brciducod Jpnuary 29, 1987 Exception in lleg. Guide 1.140 Pego 5 ',

Revisions, Additions or Justifications for -

I.140 Exceptions included in Clarificatiens to Exceptions Exception and Clarifications Article Amend. 47 to FSAR in Amend. 47 to FSAR Since Amend. 47 c.3.f None Addition:

Fan peak pressure (shut off) can only Fan peak pressure test will not be performed. potentially occur in systems that For systems that have Isolation devices the fans have isolation devices, such as are provided with high dif ferential pressure firedampers, in the main f low paths.

trips or high/ low flow trips. High dif ferential pressure trips preclude f an from operating outside its normal range.

c.3.e None Add itIon :

The TSC intake isolation dampers are Bubble tight dampers are not provided for TSC Isak tested integral with the nega-intake isolation. tive pressure ductwork and intake plenum downstream of the Filter unit to ensure total unfilterad inteakage is within health physics requirements, c .5.D Airflow distribution tests will be None

performed to ensure that the airflow through any individual Filter element does not exceed 120% of the element's rated capacity, c.5.5 None Cl ari f Ication

The system design flow is based on Filtration Unit Airflow Capacity Tests will be dirty Filter condition. This is to performed at the system design pressure range clarify the Intent of N509-76 to corresponding to clean and dirty Filter pressure perform stability / capability test losses. Tests will be performed at I.25x dirty only at 1.25 x dirty Filter Filter conditions to verify system stability cond it ions . Filter pressure onl y. Filter pressure losses for airflow conditions are simulated for all capacity tests will be simulated, without filters inplace.

airflow tests to prevent damage and/or depletion prior to air distribution tests.

Page 12 of 13

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

Brcidsood January 29, 1987 ;

Exception to Reg. Oside 1.140 dag36 };

Revisions, Additions or

• Justifications for ,

I.140 Exceptions Inctoded in Clarifications to Exceptions Exception and Clarifications Article Amend 47 To FSAR in Amend. 47 to FSAR Since Amend. 47 c.5.b Addition:

The Miscellaneous Filter Tank Vents System (VF) The VF system is a closed system air capacity test will be performed to verify which collects equipment and process that maximum flow is not greater than +105 of vents from other process systems and design. The lower flow limit criteria will not filters through VF system filtration be applied.

unit. The flow through the filter unit depends on the venting of the equipment and hence is not predictable. Low flow Is not significant to filtration capability, c.5.c None Add Ition :

Refer to letter of July 2, 1986 from Sillcone sealant or other temporary patching Miosi (CECO) to Denton (NRC) which material will not be used in the ESF Filter was accepted by mR in SSER #2.

housing. Silicone sealant is used, however, as a permanent sealant to HVAC ductwork.

c.5.c None Clarification:

The testing DOP detector can obtain a A sampling rate of less than I CFM will be representative sample with a sampling employed for testing Filter systems larger than rate less than 1 CFM.

1000 CFM.

c.6.a None Clarification:

Refer to letter of August 21,1%6 All carbon furnished prior to 1985, as part of the original specification for atmospheric from Miosi (CECO) to Denton (NRC) clean-up filtration units will be tested to the which was accepted by WR in SSER #2 requirements of Table 5-1 of ANSI N509-1976 All replacement carbon or original carbon furnished in 1985, or later, will be tested to the requirements of Table 5-1 of ANSI N509-1980, ,

with the exception that the laboratory test for methyl Iodine penetration at 30 C, 955 relative humidity is less than 1%.

t c.6.a(3) None Clarlfice Ion:

Refer to letter of July 2, 1986 from Laboratory tests will be performed per the requirements of Table 2 of Regulatory Guide Miosi (CECO) to Denton (NRC) which was accepted by mR in SSER #2.

temperature will be 30 C.

Page 13 of 13

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