ML20024F720

Proposed Tech Specs Incorporating App J Requirements Re Containment Leakage Testing Program

ML20024F720
Person / Time
Site:	Fort Calhoun
Issue date:	09/02/1983
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20024F718	List: ML20024F717 ML20024F720
References
NUDOCS 8309090609
Download: ML20024F720 (14)

Text

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

\ 'I <

~

3.0 ' SURVEILLANCE' REQUIREMENTS 3.2 Equipmentiand Sampling Tests Applicability Applies to plant;eculpment and conditions related to safety.

Objective To specify the minimum' frequency and type of surveillance to be applied to critical plant equipment and conditions.

Specifications .

Equipment and sampling tests shall be conducted as specified in Tables 3-4 and 3-5.' The specified intervals may be adjust-ed to accommodate normal test schedules except that the inter-val shall not exceed 1.25 times ^the specified interval.

Basis The equipment testing and system sampling frequencies speci-fled in Tables 3-4 and 3-5 are considered adequate, based upon experience, to maintain the. status of the equipment and systems so as to assure safe operation. Thus, those systems where changes might occur relatively rapidly are sampled fre-quently and those static systems not subject to changes are sampled less frequently.

The control room air filtering system consists of high ef-ficiency part'iculate air (HEPA) filters and the charcoal ad-sorbers. HEPA filters are installed before the charcoal ad-sorbers to pr' event clogging of the iodine adsorbers. The charcoal adsorbers are. installed to reduce the potential in-take of iodine to the control room. The in-place test results will confirm system. integrity and performance. The laboratory

-carbon sample test results should indicate methyl iodide re-moval efficiency of at least 90 percent for expected accident conditions.- Pressure. drop across the combined HEPA filters

~and charcoal adsorbers of less than G inches of water will indicate that the filters and adsorbers are not clogged by

excessive amounts of foreign matter.

The spent fuel pool area filtering unit is designed to filter l the building atmosphere to the auxiliary building vent during refueling operations. The charcoal adsorbers are installed to reduce-the, potential release of radioiodine to the environ-ment. In-place testing.is performed to confirm the integrity of the filtering unit. The charcoal adsorbers are periodical-ly sampled to insure capability for the removal of radioactive iodine.

. Amendment No. . p[, 67 3 ATTACHMENT A 8309090609 830902

,,  ; DR ADOCK 05000285 PDR

q. -

- .a >

e, . '

3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (Continued)

The Safety Injection (SI) pump room air filtering unit con- l sists of charcoal adsorbers which are installed in normally bypassed ducts. This unit is designed to reduce the potential l release of radioiodine in SI pump rooms during the recircu-lation period following a DBA. The in-place and laboratory testing of charcoal adsorbers will assure unit integrity and I performance.

Operation of the filtering units for 15 minutes overy month will demonstrate operability.

If significant painting, fire or chemical release occurs such that the HEPA filters or charcoal adsorbers could become con-taminated from the fumes, chemicals or foreign materials, testing will be performed to confirm system performance.

Demonstration of the automatic and/or manual initiation capa-bility will assure the system's availability.

References USAR, Section 9.10 a

t i

h Amendment No. pd, 67 3-17a

\ a

TABLE 3-5 MINIMUM FREQUENCIES FOR EOUIPMENT TESTS USARSectionl Test Frequency Reference

1. Control Element Drop times of all full-length CEA's Each refueling operation 7.5.3 Assemblies

2. Control Element Partial movement of all CEA's Every two weeks 7 Assemblies (Minimum of 6 in)

3. Pressurizer Safety Set point Once each refueling outage 7 Valves

4. Main Steam Safety Set point Each refueling outage 4 Valves t

u, 5 . Refueling System Functioning Prior to refueling outage 9.5.6 L Interlocks a

6. Raw Water System Functioning Each refueling outage 9.8 Valve Actuation

7. Fire Protection Functioning Monthly 9.11 Pumps & Power Supply

8. Reactor Coolant Evaluate Daily

• 4 System Leakage

9. Diesel Fuel Supply Fuel Inventory Daily 8.4

', 10a. Charcoal and HEPA 1. In-Place Testing ** 9.10

. Filters for Control Charcoal adsorbers and HEPA Each refueling shutdown Room filter banks shall be leak not to exceed 18 months j tested and shall show >99% or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />

Freon (R-ll or R-112) and of system operation or

! DOP removal, respectively. after ea'ch complete or

! partial replacement of l

• Whenever the system is at or above operating temperature and pressure.

• • Tests shall be performed in accordance with applicable section(s) of ANSI N510-1980. l Amendmen t No. JAI, 24

TABLE 3-5 -

(Continued)

USAR Section l Test Frequency Reference 10a. (Continued) the charcoal adsorber/HEPA filter banks, or after any major structural mainte-nance on the system housing and following significant painting, fire or chemical releases in a ventilation zone communicating with the system.

2. Laboratory Testing *

a. Replacement charcoal Each replacement of charcoal shall meet the require- adsorbers.

I '

ments of Table 5-1 of y ANSI N509-1980 for a 4 300C and 95% RH methyl g iodide test.

b. Activated charcoal ad- Each refueling shutdown sorbers shall be replaced not to exceed 18 months or tested. The test re- or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> sults shall show [90% of system operation or methyl iodide removal following significant when tested in accordance painting, fire or chemical with Method A of ASTM- release in any ventilation ,

D3803-79. Verification zone communicating with shall be obtained within the system.

31 days after removal that a laboratory analysis of a representative carbon

- sample meets the above criteria.

3. Overall System Operation ,

a. Each circuit shall be 15 minut,es every month. l operated.

• Testa shall be performed in accordance with applicable section(s) of ANSI N510-1980.

• Amendment No. ,VI, 24 J

f TABLE 3-5 .

(continued)

• USARSectionl Reference Test Frequency 10a. (Continued) b. The pressure drop acroas At least once per plant the combined ilEPA filters operating cycle.

& charcoal adsorber banks shall be demonstrated to be less than 6 inches of wa te r a t system design flow rate.

c. Fan shall be shown to At least once per plant operate within i10% de- operating cycle.

sign flow.

4. Automatic and manual initi- At least once per plant ation of the system shall be operating cycle.

demonstrated. g 10b. Charcoal Adsorbers 1. In-Place Testing

• Each refueling shutdown 6.2 for Spent Fuel Charcoal adsorbers shall be not to exceed 18 months 9.10 Storage Pool Area leak tested and shall show or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> t,99% Freon (R-ll or R-ll2) of system operation, or removal. after each complete or par-tial replacemen.t of the charcoal adsorber bank, or after any major structur-al maintenance on the system housing and follow-ing sig n'i f ica n t painting, fire or chemical release in a ventilation zone com-municating with the systea.

2. Laboratory Testing

a. Replacement charcoal Each replacement of charcoal shall meet the require- adsorbers.'

ments of Table 5-1 of ANSI N509-1980 for a 300C and 95% RH elemental io-dine test.

• Tests shall be performed in accordance with applicable section(s) of ANSI N510-1980.

t ,- t ~. . , , it 94. g,

f TABLE 3-5 .

(Continued) -

USAR Section l Test Frequency Reference 10b. (Continued) b. The carbon sample test- Each refueling shutdown resul ts shall show > 90% not to exceed 18 months elemental iodine reEoval or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> when tested in accordance of system operation, or with Method D of ASTM- following significant D3803-79 and with a face painting, fire or chemi-velocity of 72 fpm i10%. cal release in any venti-Verification shall be ob- lation zone communicating tained within 31 days with the system.

after removal that a laboratory analysis of a representative carbon sample meets the above criteria.

[ 3. Overall System Operation l pf a. Operation of each circuit 15 minutes every month, shall be demonstrated.

b. Volume flow rate through At least once per plant charcoal filter shall be operating cycle.

shown to be be tween 9000 and 12,000 cfm.

4. Manual initiation of the At least once per plant system shall be demonstrated. cperating cycle. l 10c. Charcoal Adsorbers 1. In-Place Testing

• Each refueling shutdown 9.10 for S.I. Pump Room Charcoal adsorbers shall be not to exceed 18 months 6.2 leak tested and shall show or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />

>99% Preon (R-ll or R-ll2) of system operation or removal. after each complete or par-tial replacement of the charcoal adsorber bank, or after any major structural GTests shall be performed in accordance with applicable section(s) of ANSI N510-1980. l 4

Amendment No.dJ , J4, 52 t'

I TABLE 3-5 '

(Continued)

USARSection!

Test Frequency Reference 10c. (Continued) maintenance on the system housing and following signi-ficant painting, fire or chemical release in any ventilation zone com*anicating with the system.

2. Laboratory Testing

a. Replacement charcoal Each replacement of charcoal shall meet the require- adsorbers.

ments of Table 5-1 of ANSI N509-1980 for a 300C and 95% RH elemental io-dine test.

w b. The carbon sample test Each refueling shutdown da results shall show no not to exceed 18 months

@ 1ess than 97% elemental or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> iodine removal when test- of system operation or ed in accordance with following significant Method D of ASTM-D3803- painting, fire or chemi-79 and with a face velo- cal release in any venti-city of 72 fpm i10%. lation zone communicating Verification shall be ob- with the system.

tained within 31 days after removal that a laboratory analysis of a representative carbon sample meets the above criteria.

3. Overall System Operation

a. Operation of each circuit 15 minutes every month. l shall be demonstrated. -

b. Volume flow rate shall be At least'once per plant shown to be 4300 cfm 120%. operating cycle.

l.'

Amendment No. k , N , 60 e

7 TABLE 3-5 -

(Continued)

USARSectionl Test Frequency Reference

4. Automatic and/or manual ini- At least once per plant tiation of the system shall operating cycle.

be demonstrated.

11. Containment Cool- 1. Demonstrate damper action. 1 year, 2 years, 5 years, 9.10 ing and Iodine Re- and every 5 years there-moval Fuseable 2. Test a spare fuseable link. after i

Linked Dampers

12. Fuel Elements Visually inspect fuel elements re- During each refueling 3 moved from the reactor. outage

13. Diesel Geqerator Calibrate During each refueling 8.4.3 Under-Voltage Re- outage y lays E$

o 14. Motor Operated Verify the contactor pickup value During each refueling Safety Injection at 185% of 460 v. outage Loop Valve Motor Starters (HCV-311, 314, 317, 320, 327, 329, 331, 333, 312, 315, 318, 321)

15. Pressurizer Heaters Verify control circuits operation During each refueling for post-accident heater use. outage L - _ _ _ _ _ _ _ _ -

3.0 SURVEILLANCE REQUIREMENTS 3.6 Safety Injection anc containment Cooling Systems Tests (Continued)

(3) Pumps

a. The safety injection pumps, shutdown cooling pumps, and containment spray pumps shall be started at intervals not to exceed three months.

Alternate manual starting between control room consolo and the local panel shall be practiced during refueling outages.

b. Acceptable levels of performance shall be that the pumps start, reach their rated heads at mini-mum recirculation flow, and operate for at least fifteen minutes.

(4) Valves

a. The SIRW storage tank outlet valves and contain-ment sump isolation valves shall be stroked during the pump test.

b. The SI tank check valves shall be checked for operability during each refueling shutdown.

(5) Containment Recirculating Air Cooling and Filtering System

a. Emergency mode damper, automatic valve, fan, fuse-able link, automatic damper, and raw wat.er backup valve operation will be checked for operability during each refueling outage.

b. Each fan and remotely operated damper required to function during accident conditions will be exer-cised at intervals not to exceed three months.

c. Each air filtering circuit will be operated at g least 15 minutes every month.

d. A visual examination of the HEPA and charcoal filters will be made during each refueling out-age, prior to each in-place DOP test or charcoal adsorber leak test and following partial or full replacement of HEPA filters or charcoal ad-sorbers, in accordance with Section 5 of ANSI N510-1980 to insure that leak paths do not exist.

e. Measurement of pressure drop across the combined HEPA and charcoal adsorber banks shall be per-formed at least once per plant operating cycle to verify a pressure drop of less than 6 inches of water at system deaign flow.

Ame nd men t No . ,}5', 24 3-55 e . - _ _ _ .

J

3.0 SURVEILLANCE REQUIREMENTS 3.6 safety Injection and containment Cooling Systems Tests (Continued)

f. Fans shall be shown to operate at a flow rate of 90,000 cfm 110% during each refueling outage.

g. In-place testing of charcoal adsorbers and HCPA filter banks shall be performed following any major system modification or repair to the filter system, . excluding partial or full replacement of filter bank. Charcoal adsorbers and HEPA filter banks shall show >99% halogenated hydrocarbon and DOP removal, respectively.

h. Replacement charcoal shall meet the requirements of Table 5-1 of ANSI N509-1980 for a 1300C and 95% RH methyl iodide test,

i. A sample shall be removed for laboratory testing at each refueling outage not to exceed 18 months; or at the next shutdown following 4300 hours0.0498 days <br />1.194 hours <br />0.00711 weeks <br />0.00164 months <br /> of charcoal filtering unit operation; or following significant painting, fire, or chemical release in any ventilation zone communicating with the filtration system. The sample tests shall show

> 8 5 % me t hyl iodide removal when tested in ac-

_cordance with Method C of ASTM-D3803-79. Verifi-cation shall be obtained within 31 days that a laboratory analysis of a representative carbon sample meets the above criteria.

Basis The safety injection system and the containment cooling system are principal plant safeguards that are not operated during normal reactor operation.

Complete systems tests cannot be performed when the reactor is operating because a safety injection signal causes containment isolation and a containment spray system test requires the system to be temporarily disabled. The method of assuring operability of these systems is, therefore, to combine systems tests to be performed during refueling shutdowns in addition to more frequent component tests which can be performed during reactor operation.

The refueling shutdown tests demonstrate proper automatic oper-ation of the safety injection and containment spray systems.

A test signal is applied to initiate automatic action and veri-fication made that the components receive the safety injection actuation signals in the proper sequence. The test demon-strates the operation of the valves, pump circuit breakers, and automatic circuitry.(1)(2)

Amendmen t No. )dI, 24 3-56

o .

3.0 SURVEILLANCE REQUIREMENTS 3.6 Safety Injection and Containment Cooling Systems Tests (Continued)

During reactor operation, the instrumentation which is depend-ed on to initiate safety injection and containment spray is generally checked daily and the initiating circuits are tested monthly. In addition, the active components (pumps and valves) are to be tested every three months to check the oper-ation of the starting circuits and to verify that the pumps are in satisfactory running order. The test interval of three months is based on the judgement that more frequent testing would not significantly increase the reliability (i.e., the probability that the component would operate when required),

yet more frequent tests would result in increased wear over a long period of time. Verification that the spray piping and nozzles are open will be made initially by a smoke test or other suitably sensitive method, and at least every five years thereafter. Since the material is all stainless steel, normal-ly in a dry condition, with no plugging mechanism available, the retest every five years is considered to be more than adequate.

Other systems that are also important to the emergency cooling function are the SI tanks, the component cooling system, the raw water system and the containment air coolers. The SI tanks are a passive safeguard. In accordance with the speci-fications, the water volume and pressure in the SI tanks are checked periodically. The other systems mentioned operate when the reactor is in operation and are continuously monitor-ed for satisfactory performance.

The in-containment air filtering system is designed to filter I the containment building a tmosphere during accident condi-tions. Both in-containment air filtering systems are designed l to automatically start upon accident signals. Should one system fail to start, the redundant system is designed to start automatically. Each of the two systems has 100 percent capacity.(3)

High efficiency particulate air (HEPA) filters are installed before the charcoal adsorbers to prevent clogging of the io-dine adsorbers. The charcoal adsorbers are installed to re-duce the potential release of radioiodine to the environment.

The laboratory carbon sample test results should indicate a radioactive methyl iodide removal efficiency of at least 85 percent. If the efficiency of the charcoal adsorbers is as 1 specified, the resulting doses will be less than the 10 CPR Part 100 guidelines for,the accidents analyzed.

Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 6 inches of water will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.

Amendmen t No. 15 3-57 2

3.0 SURVEILLANCE REQUIREMENTS 3.6 safety Injection and containment Cooling Systems Tests (Continued)

If significant painting, fire or chemical release occurs in a ventilation zone communicating with the system that could lead to the degradation of charcoal adsorbers or HEPA filters, test-ing will be performed to assure system integrity and per-formance.

. Operation of the system for 15 minutes every month will demon-strate operability of the filters and adsorbers system.

Demonstration of the automatic initiation capability will as-sure system availability.

References (1) USAR, Section 6.2 (2) USAR, Section 6.3 (3) USAR, Section 6.4 i

I i

I l

l .

3-57a

.. o-DISCUSSION OF PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS The proposed revisions to the Technical Specifications are made in response to an informal request from the Commission and following several telephone conversations between Mr. E. G. Tourigny and Mr. J.

Hayes of the Commission and Mr. T. L. Patterson and Mr. S. U. Khan of the District. These changes were requested by the NRC in reference to a proposed amendment to the Technical Specifications on 10 CFR Part 50, Appendix J, presently being reviewed by the Commission. The changes can be summarized as follows:

(1) The acceptance criteria for replacement charcoal tests has '

been changed to conform with Table 5-1 of ANSI N509-1980.

(2) The acceptance criterion for the S.I. pump room carbon sample ,

test results has been raised from 90% to 97%. This change is based upon actual operating data.

(3) The volume flow rate for the S.I. pump room, based upon oper-ating data for the past four years, has been changed from "between 3000 and 6000 cfm" to "4300 i 20%".

(4) The frequency of operation of each filtering circuit has been changed from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month to 15 minutes each month.

This change is based upon the fact that none of the plant filtering systems are equipped with heating coils, thereby making the 10-hour test unnecessary.

(5) A specification for in-place testing of containment filtering systems has been added.- It should be noted that requirements for in-place testing following a partial or full replacement of HEPA or charcoal adsorber banks have been excluded.

(6) The District takes exception to one item proposed by the Com-mission. The existing acceptance criterion for the removal of methyl iodide from the in-containment used charcoal is >85% as compared to a newly proposed value of >90%. It needs to be emphasized that the health and safety of the public will not be endangered with the existing charcoal adsorber's efficiency as the resulting doses, with a charcoal efficiency of 85%,

will be well below the 10 CFR Part 100 guidelines for the acci-dents analyzed. The District has been operating the in-con-tainment filtering systems with the present value, approved by the Commission, since 1976. It is believed that the 85% value provides operational flexibility (sufficient durations between required filter changeouts) and minimizes the cost impact on the District. -

(7) The Commission has recommended a 31-day verification of labora-tory testing of the charcoal adsorbers. The District believes that the proposed requirement for obtaining verification ATTACHMENT B

i l

(either written or verbal) within 31 days that a laboratory analysis of a representative charcoal adsorber sample meets the appropriate criteria is responsive to the concerns raised by the commission.

(8) other changes of an administrative nature (i.e., correction of typographical errors, changes to achieve consistency in the applicable sections, and reference corrections).

This amendment application does not involve significant hazards con-siderations. This determination is based on the following facts:

(1) Acceptance criteria (see 1, 2, and 3 above) were made more stringent. This will not increase the probability of an acci-dont previously evaluated, it will not create the possibility of a different accident, and will increase rather than reduce the margin of safety.

(2) Frequency of operation of filtering circuits (see 4 above) changed from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month to 15 minutes per month. This will not increase the probability of an accident previously evaluated; it will not create the possibility of a different accident; and, since the plant filtering systems are not equipped with heating coils (making the 10-hour test unneces-sary), this change will not decrease the margin of safety.

(3) Specifications for in-place testing of containment filtering systems have been added (see 5 above). This will not increase the probability of an accident previously evaluated; it will not create the possibility of a different accident; and, since this increases testing requirements, no reduction in the margin of safety will be realized.

(4) The 85% acceptance criteria was not changed (see 6 above). No change was made; therefore, no significant hazards consider-ation is involved. I (5) A 31-day limit on verification of the results of a laboratory test on charcoal adsorbers has been added. This requirement will not increase the probability of an accident previously evaluated; it will not create the possibility of a different accident; and, since the previous specification had no time limit on verification, this change will increase the margin of safety.

(6) The administrative changes (see 8 above) such as correction of typographical errors, omissions, and changes to achieve con-sistency do not involve significant hazards consideration.

m 1