ML20006D178
| ML20006D178 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/01/1990 |
| From: | OMAHA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20006D176 | List: |
| References | |
| NUDOCS 9002120188 | |
| Download: ML20006D178 (26) | |
Text
{{#Wiki_filter:. .
.E ' + x ..
4 t h i 1: 4 4 t 1 1 ATTACHMENT A ! I r i P k 1
)
9002120188 900201ADOCK PDC 0500028,5 PDR p
NENT 2.0 :.DtIT"tG CORDITIONS FOR CPERATION ! 2.12 Qatrel Room Systems ! Applicability Applies to the centrol room air cenditi:ning and filtering systems. l Ob.ieetive I To limit the environmental conditions in the control room, under normal and post DBA conditions. Specificetions (1) If the control room air temperature reaches 1200F, immediate action shall be taken to reduce this temperature. If the temperature cannot be reduced to belev 1200F in four hours, the reactor vill be placed in a het shutdown condition. (2) A thernameter must be in the control room at all times. (3) All areas of the plant which have safety related instrumentation vill be observed during hot functional testing to determine local temperatures and monitored during operation if normal plant ventilation is not available. (h) From and after the date that the centrol room air treatment system is made or found to be incperable for any reason, reactor cperation is per=issable only during the succeeding seven days unless such circuit is sooner made operable. If these conditicas cannot be =et, the reactor shall be placed in cold shutdown conditi:n vithin 2h hours. , 3 asis i The reacter protective system and the engineered safeguards system were designed for and the instru=entation was tested at 1200F. l Therefore, if the temperature of the centrol room exceeds 1200F, the reacter vill be shutdevn and the conditions corrected to preclude failure of ecmponents in an untested enviren=ent. If the centrol room air treat =ent system is found to be inoperable , there is no Nediate threat to the contr:1 reem and reactor opera-tien may centinue for a limited period cf time while repairs are being
=ade. If the system cannet be repaired within seven (7) days, the l reacter is shutdevn and brought to cold shutdevn within 24 hours.
1 I l l 2-59 Amend ent No. 15
MC)CS.Ih 2.0 LIMITING CONDITIONS FOR OPERATION 2.12 Control Room Systems ADolicability Applies to the control room air conditioning and filtering systems. Obiective To limit the environmental conditions in the control room, under normal and post DBA conditions.
,Soecifications (1) If the control room air temperature reaches 120'F, immediate action shall be taken to reduce this temperature. If the temperature cannot be reduced to below 120'F in four hours, the reactor will be placed in a hot shutdown condition.
(2) A thermometer must be in the control room at all times. (3) All areas of the plant which have safety related instrumentation will be observed during hot functional testing to determine local temperatures and monitored during operation if normal plant ventilation is not available. (4) With one control room air filtration system inoperable, restore the inoperable system to operable status within 7 days or be in at least cold shutdown condition within the following 24 hours. 9.A111 The reactor protective system and the engineered safeguards system were designed for and the instrumentation was tested at 120*F. Therefore, if l the temperature of the control room exceeds 120'F, the reactor will be shut down and the conditions corrected to preclude failure uf components in an untested environment. If the control room air treatment system is found to be inoperable, there is no immediate threat to the control room and reactor operation may continue for a limited period of time while repairs are being made. If the system cannotberepairedwithinseven(7) days,thereactorisshut down and brought to cold shutdown within 24 hours. 2-59
._ _ _ _ -. _ .J
$Q(T \@
, "J3LE 2-7 FIRE DETECTION ?.ONES Eone No. Locatien 1 Auxiliary Building, nevations 971 and 989 West 2 Auxiliary Building, n evation 989 East 3 Auxiliary Building, nevation 989, Lover nectrical Penetration Room (Room 20) k Auxiliary Building, nevation 989, Air Compressor Room (Room 19)
, 5 Auxiliary Building, nevation 1007, Corridor 26, Rooms 58, 59, and 60 6 Auxiliary Building, nevations 1007 and lou, Uncontroned
;^ 7 Auxiliary Building, Elevation 1013, Upper Electrical Penetration Room (Room 57) 8 Auxiliary Building, Elevations 989 and 1007. Boric Acid Tank Area, Drunaning Area, New Fuel Area 9 Auxiliary Building, nevation 1036, Control Room Complex, Control Room Hau vays 10 '
Containment, Elevation 1013 RC Pump Cavities 11 Containment, Elevation 99h 12 Containment Elevation 1045 13 Auxiliary Building, Elevation 1025 (Rooms 69 and 71). , 14 Turbine Building, Elevation 990 l 15 Turbine Building, Elevation 1011 16 Turbine Building, Ilevation 1Q36 17 Containment Fans VA-3B and VA-7D 18 Containment Fans VA-3A and VA-7C 19 Containment Fans VA-2A and VA-2B 20 Control Room Panels CB-1/2/3 Return Air 21 Contain=ent UDWC Fans VA-12A and VA-123 22 Contain=ent Purge Discharge Fans VA-32A and VA-32B 23 DG-2 Room Exhaust Fan, VA-523 , 24 Contninment Purge Supply Fans VA-2kA and VA-2LB ' 25 Control Room and Hallway Ventilation Ducts 26 Auxiliary Building (Controlled) Supply Fans, VA-35A and VA-35B 27 Auxiliary Building (Controned) Exhaust Fans, VA LOA, VA LOB, and VA LOC l 28 Auxiliary Building (Uncontroned) Supply Fans, VA kSA and VA-kSB 29 Auxiliary Building (Uncontroned) Exhaust Fan, VA k1 30 Auxiliary Building Elevator Shaft Fan, VA-51 l 31 Control Room Air Conditioning Fans, VA k6A and VA k6B 32 DG-1 Room Exhaust Fan, VA-52A 33- Auxiliary Building, nevation 1036 (Room 81) 3h Plant Sprinkler Flev 35 Auxiliary Building, DG-2 (Room 6k) i 36 Auxilia.ry Building, DG-1 (Room 63) 37 Intake Structure Including Rav Water Pu=p Room 38 Auxiliary Building Open Stairven 39 Auxiliary Building open Hatchway l Amend =ent :lo. 33, 60 2-90
s , F s - N(C.W4E.h
, TABLE 2-7 FIRE DETECTION 7ONES Zone No. Location 1 Auxiliary Building, Elevations 971 and 989 West 2 Auxiliary Building, Elevation 989 East 3 Auxiliary Building, Elevation 989, Lower Electrical Penetration Room (Room 20) 4 AuxiliaryBuilding, Elevation 989,AirCompressorRoom(Room 19) 5 Auxiliary Building, Elevation 1007, Corridor 26, Rooms 58, 59 and 60 6 Auxiliary Building, Elevations 1007 and 1011, Uncontrolled 7 Auxiliary Building, Elevation 1013, Upper Electrical Penetration Room (Room 57) 8 Auxiliary Building, Elevations 989 and 1007, Boric Acid Tank Area, Drumming Area, New Fuel Area 9 Auxiliary Building, Elevation 1036, Control Room Complex, Control ,
Room Hallways - 10 Containment, Elevation 1013, RC Pump Cavities 11 Containment, Elevation 994 12 Containment, Elevation 1045 j 13 Auxiliary Building, Elevation 1025 (Rooms 69 and 71) 14 Turbine Building, Elevation 990 15 Turbine Building, Elevation 1011 16 Turbine Building, Elevation 1036 17 Containment Fans VA-3B and VA-7D 18 Containment Fans VA-3A and VA-7C , 19 Containment fans VA-2A and VA-28 20- Control Room Panels CB-1/2/3 Return Ait 21 Containment NDWC Fans VA-12A and VA-128 22 Containment Purge Discharge Fans VA-32A and VA-32B 23 DG-2 Room Exhaust Fan, VA-52B 24 Containment Purge Supply fans VA-24A and VA-24B 25 Control Room and Hallway ventilation Ducts 26 AuxiliaryBuilding(Controlled)Sup)lyFans,VA-35AandVA-35B Auxiliary Building (Controlled)Ex1austFans,VA-40A,VA-40B,and 27 VA-40C 28 Auxiliary Building (Uncontrolled) Susply Fans, VA-45A and VA-45B 29 Auxiliary Building (Uncontrolled) Ex1aust Fan, VA-41 30 Auxiliary Building Elevator Shaft Fan, VA-51 31 Control Room Air Conditioning Fans, VA-46A and VA-46B 32 DG-1 Room Exhaust Fan, VA-52A 33 AuxiliaryBuilding, Elevation 1036(Room 81) 34 Plant Sprinkler Flow 35 AuxiliaryBuilding,DG-2(Room 64) 36 Auxiliary Building, DG-1 (Roo'n 63) 37 Intake Structure Including Raw Water Pump Room Auxiliary Building Open Stairwell 38 39 Auxiliary Building Open Hatchway 40 ControlRoomOutsideAirFilterVA-64A(Room 81) 41 Control Room Outside Air Filter VA-64B (Room 81) , 2-90 I
( sw l g ., 9 @A.3 h, Y i- 3.0 SURVEILLAfiCE RE0VIRE!!Et:TS 3.2 Eduipment anc Samolino Tests Applicability
- Applies te plant equipment and cenditions related to safety.
Ob.iective To specify the minimum frequency ano 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. Basis The equipment testing and system sampling frequencies specified in I T ables 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 frequently and those static systems not subject to changes are sampled less frequently. The control room air treatment system consists of high efficiency particulate air filters (HEPA) and the charcoal adsorbers. HEPA filters are installed before the charcoal adsorbers to prevent clogging of the iodine adsorbers. The charcoal adsorbers are ; installed to reduce the potential intake of iodine to the centrol ' room. . The in-place test results will confirm system integrity and performance. The laboratory carben sample tests results should , indicate methyl iodide removal efficiency of at least 90 percent for expected accident ccnditions. The spent fuel storage-decontamination areas air treatment system is designed to filter the building atmosphere to the auxiliary building vent during refueling cperations. The charcoal adsorbers are installed to reduce the potential release of radioicdine to the environment. In-place testing is performed to confirm the integrity of the filter system. The charcoal aosorbers are periedically sampled t to insure capability for the removal of radioactive iodine. . 3-17 Amendment tio. 15, 67, 122 l l l
hkCkLVU2a 3.0 SURVEILLANCE REOUIREMENTS l 3.2 Ecuioment and Samolino Tests ' l ADDlicabilitV ) 1 Applies to plant equipment and conditions related to safety. I Objective To specify the minimum frequency and type of surveillance to be applied i to critical plant equipment and conditions. i Soecifications 1 Equipment and sampling tests shall be conducted as specified in Tables 3-4 and 3-5. EA1.11 i The equipment testing and system sampling frequencies specified in Tables ; 3-4 and 3-5 are considered adecuate, based upon experience, to maintain ' the status of the equipment anc systems so as to assure safe operation. Thus, those systems where changes might occur relatively rapidly are sampled frequently and those static systems not subject to changes are sampled less frequently. - The control room air treatment system consists of redundant high . efficiency particulate airfilters(HEPA)and charcoal adsorbers. HEPA filters are installed before and after the charcoal adsorbers. The charcoal adsorbers are installed to reduce the potential intake of iodine to the control room. The in-place test results will confirm system integrity and performance. The laboratory carbon sample test results i should indicate methyl iodide removal efficiency of at least 99.825
- percent for expected accident conditions.
The spent fuel storage-decontamination areas air treatment system is designed to filter the building atmosphere to the auxiliary building vent ' during refuel-ing operations. The charcoal adsorbers are installed to reduce the potential release of radioiodine to the environment, In-place ' testing is performed to confirm the integrity of the filter system. The charcoal adsorbers are periodically sampled to insure capability for the removal of radioactive iodine. 3-17
[* g . N .' , m .- !1 ( - 1MD ?'., h k. %\
- 3. 0 .:URVE111ANCE REQUIRECTS 5.? "quierent wi Op.pline Tests (Continued)
Sc Ja 'ety In.)ection (01) pump room air treatment system consists of charet,41 ausurbers which are installed in normally bypassed ducts. This system is designed to reduce the potential release of radiciodine ' in SI pump rooms durine, the recirculation period following a DBA. The in-place and laboratory testing of charcoal adsorbers will assure
- Oystem intecrity and perfonamnee.
Pressure tirop across the combined KEPA filters and charcoal adsorbers, for each of the air treatment systems, of less than 6 inches of water vill indierite that the filters and adsorbers are not clogged by e i.m .:a lvo tamuin Lu esr roccie.n nutter. uperation of the system for 10 hourn avery month vill demonstrate operability and remove excessive "eslut.ut e but H op or f.he tulsesrbero. I r cisoil fletoit p*sitntjtut, rire or chemieul release veeurs such that the HEPA filters or charecal adsorbers could become contaminated from the rumen, chemicil or foreJ#'.n matericic, testin,t vill be performed to confirm system performance. Demonstration of the automatic and/or manual initiation capability vill tacure the cyctem'a rivailability. References U3AR , Section 9 10 4 Amendment :!o. 15, 67 3-17a i
s - CkEQ l 1 3.0 SURVEII.LANCEREOUIREMENTS j 3.2 EauiementandSamolinoTests(continued) l The Safety Injection (SI) pump room air treatment system consists of charcoal adsorbers which are installed in normally bypassed ducts. This system is designed to reduce the potential release of radioiodine in SI pump rooms during the recirculation period following a DBA. The in-place i and laboratory testing of charcoal adsorbers will assure system integrity and performance. Pressure drops across the combined HEPA filters and charcoal adsorbers, of less than 9 inches of water for the control room filters (VA-64A & , VA-64B) 'and of less than 6 inches of water for each of the other air treatment systems will indicate that the filters and adsorbers are not clogged by amounts of foreign matter that would interfere with performance to established levels. 0)eration of each system for 10 hours every month will demonstrate opera)ility and remove excessive moisture ' buildup in the adsorbers. If significant fire or chemical release occurs such that the HEPA filters orpainting,l charcoa adsorbers could become contaminated from the fumes, chemicals or forei materials, testing will be performed to confirm system performance. gn i Demonstration of the automatic and/or manual initiation capability will ' assure the system's availability. References USAR, Section 9.10 l t f 3-17a 9
TMM 3 , MINItRSI FREQUENCIES FOR EQUIPMulT TESTS , FSAR Section Test Frequency Re ference -
- 1. Control Element Drop times of all full-length CEA's Each refueling operation 7.5.3 Assemblies l
- 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 is . Main Steam Safety Set point Each refueling outage le Valves 5 liefueling System Functioning Prior to refueling outage 9.5.6 l In terlocks
- 6. Itaw Water System Functioning Each refueling outage 9.8 Valve Actuation l 7 Fire Protection Functioning Monthly 9 11 Pumps & Power Supply
.pl
- 8. lienctor Coolant Evaluate Daily' la System Leakage -
9 Diesel Fasel Supply Fuel Inventory Daily 6.84 [f s 10a. Charcoal und liEPA 1. In-Place Testing ** 9 10 Filters for Control Charcoal adsorbers and HEPA Itocm filter banks chall be leak Each refueling shutdown not to exceed 18 months or after every 720 hours of system [ a tested and shall show $9% operation or after each couplete or partial Freon (R-11 or R-112) and replacement of the charcoal adsorber/NEPA cold DOP particulates re- filter banks, or after any major structural moval, respectively. maintenance on the system housing and follow-ing significant painting, fire or chemical releases in a ventilation zone communicating with the system.
- Whenever the system is at or above operating temperature and pressure, c* Tests shall be performed in accordance with applicable section(s) of ANSI M510 's975 Amendment No. 2h
TNEE 3-5 ' V MINIlui rm me KR BOUIPfGrr 'ITSTS , Test E equency 17AR Sectim nefemn
- 1. Control Elenent Drop times of all full- Each refueling operation 7.5.3 Assemblies length CEA's -
- 2. Control Elenent Partial moveient of all Every tsao weeks 7 Assmblies CEAs (Miniman of 6 in)
- 3. Pressurizer Safety Set Point Orxm endt refueling outage 7 Valves
- 4. Main Steann Safety Set Point Each refueling outage 4 Valves S. Refueling Systen Functioning Prior to refoeling outage 9.5.6 Interlocks m 6. Raw Water Systen Functioning Each refueling outage 9.8 y 4
u Valve Actuaticn o .
- 7. Fire Protecticri Ebnctioning Monthly 9.11 'u,.:
Punps & Power O Supply {M
- 8. Reactor Coolant Evaluate Daily
- 4 P Systen Isakage 7
- 9. Diesel Fuel Supply Fuel Inventory nnily 8.4 10a. Charcoal and HEPA 1. In-Place Testirn** 9.10 Filters for Qiarcoal aduvtl.=.ts and HEPA Each refueling shuMrmai not to eseceed 18 Control Rom filter banks shall be leak arriths or after every 720 hours of systan tested and show > 99.95% operation or after endt complete or partial l Frecri (R-11 or R-112) and replacement of the crustuml adsorber/HEPA (x)ld 00P particulates filter banks, or after any sejar structural
! renoval, igdvely. maintenance on the systen housing and following significant painting, fire or chemical releases in a ventilation zone cv====ilcating with the systen.
- Mas =:ver the systen is at or above operating t==.mai and pressure.
** Tests shall be perfnnawi in au.ma-sw with applicable section(s) of ANSI M510-1990. l t
-TABIA . 1 (Continued)
FSAR SeetIon Test Frequency De fe rence-10a. (Continued) 2. Laboratory Testing **
- a. Initial batch tests of acti- Prior to initial loading in filter unit, vated charcoal shall show 3 0% radioactive methyl lodide removal when tested under conditions of 195% .
relative humidity, >1250F, 0.05 to 0.15 mg/m3 inlet methyl iodide concentration and at a face velocity of within +20% or system de-sign.
- b. Activated charcoal cells Each refueling shutdown not to exceed 18 lg shall be replaced or months or after every 720 hours of system tested. The test results operation and following significant paint-w shall show 3 0% methyl ing, fire or chemical release in a venti-j, lodide removal when test- lation zone communicating with the system.
y ed under conditions of 9 5% relative humidity,
>1250F aid within +20%
of system design face velocity. -
*f 3 Overall system operation
- a. Each circuit shall be oper- Ten hours every month.
g ated.
'gj l',
- b. The pressure drop across At least once per plant operating cycle. f
the combined IIEPA filters , and charcoal adsorber banks shall be demonstrated to be less than 6 inches of water , f[l at system design flow rate. I
- c. Fan shall be shown to oper- At least once per plant operating cycle.
ate within +10% design flow. le . Automatic and menual initiation At least once per plant operating cycle. of the system shall be demon- , strated. CGTests shall be performed in accordance with applicable section(s) of ANSI N510-1975. Amendment No. , 216
1 NEE 3-5 (Cmtinued) Test Frecauency ISAR - - hetion Reference 10a. .(oontinued) 2. Iidua^uav Testina** Prior to initial loading in filter unit.
- a. Initial batch tests of activated charcoal shall show 99.825% radimetive methyl '
iodide reuxal when tested urder conditions of 2 70% . relative htsnidigy, 2176*F (80*C) 1.5 to 2.0 m3/ ar' inlet methyl iodide conomtration at a face velocity of 401 1.6 FPM (12.2 10.5 m/ min) and at a bed depth of 4 inches (101.6 nen).
- b. Activated charcoal cells Eadt refueling shutdown not to enoeed 18 shall be replaced or tested. nonths or after every 720 hours of systen -{y j
1he test results shall show operatim and following significant painting, y 2 99.825% methyl iodida fire or chemical release in a vettilation renoval when tested under zone ocanunimting with the systen. p-Y g conditims of > 70% relative hinnidity, 2176 F (80 C), at a Y
= O) face velocity of 4011.6 FPH (12.2 + 0.5 m/ min) and at a beni p depth of 4 inches (101.6 asa). h
- 3. Overall Systen Operation
- a. Each circuit shall be Ten hours every amth operated.
- b. 'Ihe pressure drop across At least mee per plant operating cycle.
the otat>ined HEPA filters and chru.um1 ah le banks shall be & sus ^ua^wd to be less than 9 inches of water at systen design flow rate.
- c. Fan shall be shown to At least once per plant operating cycle.
operate within i 10% design flow.
- 4. Autaastic and menual At least once per plant operating cycle.
initiation of the systen 5 shall be dsumstrated.
** Tests shall be perfrmmari in acardance with applicable section(s) of JesSI M510-1980. l a
TA Bs ._ -5 (Continued) FSAR Uectio$ Test Frequency Reference 10b. Charcoal Adsorbers 1. In-Place Testing ** Each refueling shutdown not to exceed 18 6.2 for Spent Fuel Charcoal adsorbers shall be months or after every 720 hours of system 9.10 Storage Pool Area leak tested and shall show operation, or after each complete or par-
>99% Freon (R-11 or R-112) tial replacement of the charcoal adsorber .
removal. bank, or after any major structural mainte-nance on the system housing and following signi ficant painting, fire or chemical re-lease in a ventilation zone communicating with the system.
- 2. I.aboratory Testing
- a. Initial batch tests of all Prior to initial loading in the filter unit.
charcoal udsorbers shall show >99% elemental iodine
. . , removal when tested under
. d3 conditions of >95% H.ll.,
@ 1125oF, 5 to 10 mg/m3 inlet elemental iodine concentra- /
tion and at the face velocity 'i' . within +20% of system design. >
. {#
- b. The carbon sample test re- Each refueling shutdown not to exceed 18 sults shall show >90% ele- months or after every 720 hours of system f f,j mental iodine removal, under operation, and following significant paint- t condi tions of >95% R.H. , ing, fire or chemical release in any venti- jf
>1250F, 5 to 10 mg/m3 in- lation zone communicating with the system.
let elemental concentration
- and within 20% of design face velocity.
~[
'l
- 3. Overall System Operation
- a. Operation of each circuit Ten hours every month.
shall be demonstrated.
- b. Volume flow rate through At least once per plant operating cycle.
charcoal filter shall be shown to be between 9000 and 12,000 cfm.
- h. Manual initiation of the system At least once per plant operating cycle.
shall be demonstrated. C*T:sto shall be performed in accordance with applicable section(s) of ANSI N510-1975 Amendment No. d , h , 52 i
'DGE 3-5 (Contimed)
Test Freauscv FSAR . Sectim Reference 10b. Charcoal Aliuhu 1. In-Place Testing ** Each refueling shutdown not to exceed 6.2 l for Spent Fuel Charcoal admudus shall be 18 months c: after every 720 hours 9.10 i Storage Pool Area leak testai and shall show of systm operation, or after each 2 99% Frean (R-11 or R-112) cruplete or partial replacement of the rutoval. charcoal abuh bank, or after any major structural maintsian on the . systen housing and following significant l painting, fire or chemical release in a j ventilation zone ocusenicating with the , systen.
- 2. Laboratory Testina
- a. Initial batch tests of all Prior to initial loading in the filter unit.
charcoal adsorbers shall show 2 99% elenental iodine raroval when tested under conditicms of 2 95 R.H., 2 125'F, 5 to
-d 10 mg/nr)' inlet elenental iodine cxmoentration and at the h'
~j Y face velocity within i 20% of g systen design.
tr b. '1he carbon sanple test Eac:h refueling shutdown not to exceed 18 (/' results shall show 2 90% months or after every 720 hours of systen elenental iodine renoval, operaticm, and follcwing significant [fl under cxniitions of 2 95% painting, fire or chenical release in any [ey R.H., 2125 F, 5 to 10 m/ad zone crminanicating with the systen. inlet elevental concentration and within 20% of design face velocity. 3 Overall S/stan Operation
- a. Operation of each circuit Ten hours every month shall be doncmstrated.
- b. Volune flow rate through At least cooe per plant operating cycle.
charcoal filter shall be shown to be between 9000 and 12,000 cfa.
- 4. Manual initiation of the At least once per plant operating cycle.
systen shall be desumhated.
** Tests shall be perfonnai in accordance with applicable section(s) of ANSI N510-1990.
tabla 5 . (Continued) FSAR Section - Test Frequency Reference lo c. Charcoal Adsorbers 1. In-Place Testing ** Each refueling shutdown not to exceed 16 9.10 for S.I. Pump Hoom Charcoal adsorbers shall be months or after every 720 hours of system 6.2 , leak tested and shall show operation or after each complete or partial 199% Freon (R-11 or H-ll2) replacement of the charcoal adsorber bank, removal. or after any ma,jor structural maintenance . on the system housing and following signi-ficant painting, fire or chemical release in any ventilation zone communicatin6 with the system.
- 2. I.aboratory Testing
- a. Initial batch tests of all Prior to initial loading in the filter unit.
charcoal adsorbers shall show 1995 elemental fodine removal when tested under 4 condi tions of 195% R.11. , g 11250F, 5 to 10 mg/m3 in- ,/ let elemental iodine con- ~I/ centration and at a face - velocity within +20% of /' system design. ~
- b. The carbon sample test Each refueling shutdown not to exce d 18 [/
3 results for the S.I. Pump months or after every 720 hours of system hoom charcoal filters shall operation and following significant paint-show no less than 90% ele- ing, fire or chemical release in any venti- o[rf mental iodine removal, under conditions of >95% lation zone communicating with the system. [-
"[
H.II. b at >l25%', 5 to 30 mg/m inlet elemental
'l iodine concentration and within +20% or desi6n face velocity.
- 3. Overall System Operation
- a. Operation of each circuit Ten hours every month.
shall be demonstrated,
- b. Volume flow rate shall be At least once per plant operating cycle.
shown to be between 3000 and 6000 cra. CCTests shall be performed in accordance with applicable section(s) of ANSI N510-1975 Amendment No. d, N, 52
~
1MEE 3-5 (Oontinued) Test Frequency FSAR - Wm Refermee 10c. Chatwal Aba.b&s 1. In-Pla Testing ** Eadt refueling shutdown not to exrvat 9.10 for S.I. Punp Roce Charcoal adwsbe.ts shall be 18 naths or after every 720 hours of 6.2 leak tested and shall show systsa operation or after eeds cxmplete 2 99% Freon (R-11 or R-112) or partial replacement of the charcoal runwal. .vh 'e bank, or after any major structural maintenance cm the systen . housing and following significant painting, fire or chemical release in any ventilation zone cxanunicating with the systaa.
- 2. Iaboratory Testing Prior to initial Irwedirq in the filter unit.
- a. Initial batch tests of all charcoal adsorbers shall show 2 99% elenental iodine rmoval when tested under conditims of 2 95% R H.,
3 'y(/ Y 2125'F, 5 to 10 ngha' inlet - N elenental iodine concentration S and at a face velocity within i 20% of systen design.
- b. The carbon sanple test Each refue'ing shutdown not tc, -w: 18 results for the S.I. Pimp Room nonths or after every 720 hours of systen (A charcoal filters shall show no operation and following significant painting ff less than 90% elenental iodine fire or charnical release in any ventilation remwal, under conditions of zme communicating with the systen.
2 95) R.H. , at 2125'F, 5 to 10 mghr.' inlet elenental iodine ocncentration ard within i 20% of design fcoe velocity.
- 3. Overall System Operatica
- a. Operation of each cizatit Ten hours every amth.
shall be demuusi_wted.
- b. Voltane flow rate shall At least once per plant wai.ing cycle.
be shown to be between 3000 and 6000 cfm.
** Tests shall be perfonned in accordance with applicable sectim(s) of mesi N510-1980.
~l M
A y y - 3.0' SURVE!Lt.ANCE RE001REMENTS
-3'.16 Re'irculation c Heat Removal System inteority Testing Applicability
. Applies to determination cf the integrity of the shutdown ecoling system and associated' components.
Objective To verify that the leakage fron the recirculation heat rmoval system components is within acceptable limits. Specifications (1) a. The portion of the-shutdown cooling system that is outside-the containment shall be tested at 250 psig or-a refueling interval. . b. Piping from valves HCV-383-3 and HCV-383-4 to the discharge isolation valves of the safety injection pumps and containment spray. pumps shall be hydrostatically tested at no less than 100 psig at the testing frequency specified in (1)a. above, c. Visual inspection of the system's components shall be per-formed at the frequency specified in (1)a. above to uncover any significant leakage. The . leakage shall be measured by collection and weighing or by any. other equivalent method. ,l (2) a. The maximum allowable leakage from.the recirculation heat removal s i flanges, ystem's' components (which incluoe valve-stems, and pump seals) shall not exceed one gallon per . minute, under the normal hydrostatic head from the SIRW ! tank. S. Repairs shall be made as requirec to mairtain leakage within the acceptable limits. Basis
'The limiting leakage rates from the shutdown cooling systen are judgment values based primarily on assuring that the components could operate without mechanical failure for a period on the order of 200 days efter a design basis accident. The test pressure (250
" psig) achieved either by normal system operation cr by hydrostctic testing'givesanadequatemarginoverthe(yghestpressurewithin-the system af ter a design basis accident. Similarly, the hydrostatic test pressure for the return lines from the contain-ment to the shutdown cooling system (100 psig) gives an adequatt margin basis accident.
over the highest pressure within the lines after a design 3-64 Amencment No. 97,122 4
. _ _ _ . - - - - - - - - - - - - - - ~ ~ ' ~ ~ ~ ' ' ' ' ~ ~ ~ ~ ~ ~ ~ ' '
@ ~QO 9 0 E h m -
L 3.0 , 50RVf!LLANCE RE0VIREMENTS 3.16 Recirculation Heat Removal System Intenrity Testino ADolicability Applies to determination of the integrity of the shutdown cooling system and associated components. Ob.iect ive To verify that the leakage from the recirculation heat removal system components is within acceptable limits. Specifications (1) a. The portion of the shutdown cooling system that. is i outside the containment shall be tested at 250 psig on a
~
l refueling interval,
- b. . Piping from valves HCV-383-3 and HCV-383-4 to the-
~
discharge isolation valves of the safety injection pumps and containment spray pumps shall be hydrostatically tested at no less than 100 psig at the testing frequency ' specified in (1)a. above,
- c. Visual inspection of the system's components shall be-performed at~ the frequency specified in (1)a. above to i uncover any significant- leakage. .The leakage shall be measured by collection and weighing or by any other equivalent method.
(2) a. The maximum allowable leakage from the recirculating heat removal system's components (which include valve stems, flanges, and pump seals) shall not exceed 1243 cc/hr under the test conditions given in (1)a. and (1)b above,
- b. Repairs shall be made as required to maintain leakage within the acceptable limits. ;
Basis l The limiting leakage rates from the shutdown cooling system are judgment values based primarily on assuring that the components could operate , without mechanical failure for a period on the order of 200 days after a j design basis accident as well as limiting the potential post accident airborne radiciodine concentrations in the control room. The test j aressure (250 psig) achieved either by normal system operation or by j lydrostatic testing gives an adequatemarginoverghighestpressure within the system after a design basis accident . Similarly, the hydrostatic test pressure for the return lines from the containment to the shutdown cooling system (100 psig) gives an adequate margin over the highest pressure within the lines after a design basis accident. l 3-84
,7 1;
W Iei S- hhh N ;
~3.0 ' SURVEILLANCE P.EQUIREMENTS 3.16 Recirculation Heat Removal System Integrity Testing (Continued) i A shutdown cooling system leakage of.cne'gpm will limit off site exposures due to leakage to insignificant levels relative to' those
-calculated for direct leakage f rom the containment in the design-basis accident.: The safety injection system pump rooms are !
equipped wiC~ individual charcoal filters which are'placed into operation by means of switches in the control room. The radiation .! detectors in the auxiliary. building exhaust duct are used to <
' detect high radiation level. The one spa leak rate is suffi-ciently high to permit prompt detection and to allow for reason-able leakage through the pump seals and valve packings, and yet ;
small enough to be - ;11y handled by the pumps and radioactive waste system. Leak s, to the safety injection system gpp room sumps will be returned to the spent regenerant tanks.( ' Addi-tional makeup water to t.he containment sump inventory'can be. readily accommodated via the charging pumps frem either the SIRW , tank or the concentrated boric acid storage tanks. In case of failure to meet the acceptance criteria for leakage from the shutdown cooling system or the associated components, it 3 may be possible to effect repairs within a short time. If so, it is considered unnecessary and unjustified to shutdown the- reactor. The times allowed for repairs are consistent with' the times developed for other engineered safeguards components. i References (1) USAR, Section 9.3 (2) USAR. Section 6.2 F 3-85 Amendment No. 97 ,
y ., D EN
'3.0 SURVEILLANCE RE0VIREMENTS 3.16 Recirculation Heat Removal System Inteority Testino (Continued)
A shutdown cooling system leakage' of 1243 cc/hr will limit off-site l exposures due to leakage to insignificant levels relative to those-calculated for -direct leakage from the containment in the design basis- : aacident. The. safety injection system pump rooms are equipped with individual charcoal filters which are placed into operation by means of switches in the~ control room. The radiation detectors in the auxiliary building exhaust duct are used to detect'high radiation-level. The 1243 ' cc/hr leak rate is sufficiently -high to allow for reasonable leakage !
-through the pump seals and valve packings, and yet small enough to be readily~ handled by the pumps and' radioactive waste system. Leakage to the safetyinjectjggsystempumproomsump:willbereturnedtothespent. .
regenerant tanks.\ / Additional makeup water to the containment sump inventory can be readily accommodated via the charging pumps from either the SIRW tank or the concentrated boric acid storage tanks. In case of failure to meet the acceptable criteria for leakage from the shutdown cooling system or the associated components, it may be possible' to effect repairs within a short time. If so, it is considered unnecessary and unjustified to shut down the reactor. The times allowed for repairs are consistent with the times developed for other engineered safeguards components. References ; (1) USAR, Section 9.3 (2). USAR, Section 6.2' i 1 3-85 1 l. 1 i
*
- e a -.
D ' s i e .1 4
'g M, f-; ,'hi!(- T I
.. i ,
9 . 5 i
,,O-l i
4 1
'l I
1 I
.1 l
1
'l
( h i e f i ATTACHMENT B . v 9
. h, t
h l b i b 2 I r l
- l. e t'
u I'. f 1 l
- i. -
I: i ,' # l' 1 I l t-
,-.,m,
a ,1 ,
' O-
- Discussion, Justification and No Significant
,. Hazard' Consideration-
'The proposed changes to Technical Specifications Section 2.19, page 2-90; Section 3.2, pages-3-17, 3-17a, 3-20, 3-20a, 3-20b and 3-20c; Section 2.12, page 2-59; Section 3.16, pages 3-84 and 3-85 are required to incorporate modifications that will be made to the Control Room Air Treatment system and i supporting radiological dose calculations. '
The Control Room Air Treatment System must meet the requirements of-10 CFR 50, Appendix A, General Design Criterion 19 (GDC 19), NUREG 0737,-Item 111.0.3.4, Standard Review Plant (SRP) 6.4, and Regulatory Guide (R.G.) 1.52. A control room survey was conducted by the NRC at Fort Calhoun Station in October,-1987. The survey determined that an excessive amount of unfiltered air was being-pulled into the control room envelope. Calculations performed by 0 PPD indicated that these amounts of unfiltered air would result in operators ]- receiving more than the 30 REM thyroid dose limit allowed in a 30 day period post accident. Interim measures were taken to protect the operators while OPPD evaluated the Control Room Air Treatment system. Several modifications were made to the system to reduce air inleakage but it is necessary to replace the existing charcoal filter train to reduce radioactive iodine to acceptable levels, i The existing single, 90% efficient charcoal filter unit is being replaced by I two, full capacity 99% efficient filter trains. Calculations using the ! increased efficiency show that the new filters will reduce exposures to the i operators below the GDC 19 dose limits from the combination of all sources of l airborne radiation. The reduced RHR system leakage is also required as. j discussed below. A change to the Technical Specifications is necessary to ; revise the carbon testing requirements to conform to those given in R.G. 1.52 and ANSI N510-1980 used by the testing laboratories. Since the installation of the new charcoal filter units in room 81 will l introduce an increased fire load in the area, the filters are equipped with 1 fire detection and deluge systems that are designed to alert the operators and extinguish any fires without reliance on existing fire protection equipment in ; the area. Two new fire zones are being added to the Technical Specifications to conform to the modification of the fire system caused by the addition of the new air filter system. =i The current Technical Specification 3.16 allows a maximum leak rate of one i gallon per minute (1 gpm) for the Residual Heat Removal (RHR) system. Yet, if , a design basis-LOCA would occur, the Thyroid dose to control room operators , would exceed GDC-19 limits as further defined by SRP 6.4, even if the proposed ' ventilation filters design basis of 99% efficiency was met. Therefore, to achieve maximum protection to the operating staff and validate the design basis for the control room air filter system modification, a maximum RHR leak rate of 1243 cc/hr must be incorporated into Section 3.16 of the Technical Specifications. The Technical Specification change will close out item 5 of Safety Analysis for Operability (SA0) # 89-02. The section 3.16 change is proposed to assure allowed leakage from the Residual Heat Removal System does not adversely effect control room habitability. Surveillance Requirement 3.16(2)a. now allows a leakage rate of one gallon per minute. This value is to be changed to 1243 cc/hr, based on an analysis by
, Combustion Engineering; this is the maximum expected from the safety injection system at Fort Calhoun.
r i
.4
# In addition, the wording is changed in 3.16(2)a to indicate the 1243 cc/hr
', leakrate-is verified-at the. hydrostatic test pressures described in 3.16(1)a.
and 3.16(1)b.'rather than the normal hydrostatic head from the SIRW tank. A statement is'added to the Basis section of 3.16, page 3-84 to indicate the
' proposed new allowable RHR leakage is required to limit post accident radioiodine levels in the control room. Section 8.16, page 3-85 also makes reference to the 1 gpm leakrate being high enough to be promptly detected. The District proposes to strike this statement as discussed below.
The district proposes an administrative change _to page 2-59 2.12(4), Control Room Systems,-Control Room Air Treatment. This administrative change clarifies-the control room air treatment operability requirements by replacing the legalese statement with the words from the Standard Technical Specifications. A typographical error is corrected on page 3-84, (1)a., or is changed to on, j No Significant Hazards Consideration This proposed amendment does not involve a significant hazard consideration i because the operation of Fort Calhoun Station in accordance with this amendment would not: !
- 1. Involve a significant increase in the probability or consequences of an ;
accident previously evaluated.
-The charcoal contained in the new filter units will increase the fire loading in Room 81. However, the new fire loading sources will be ,
equipped with new detection, monitoring, and deluge systems. The ! existing filter system is not equipped with fire detection, so this represents an increased level of fire detection capability. Therefore, j the fire detection and suppression capabilities for the plant will not be ! degraded, and the consequences of an accident previously evaluated will-not be increased. Dose calculations show that the new filter system will prevent the operators from exceeding the 10 CFR 50 Appendix A GDC 19 dose limits from the combination of all sources of airborne radioactive iodine in conjunction with the reduced RHR system leakrate. l
- - 'The consequences of an accident previously analyzed will not be increased because the testing requirements given in Table 3-5 are being increased, ;
resulting in a more efficient filter thus lowering the doses in the ! control room. ! Decreasing the allowable RHR system leakage will only decrease the consequences of any accidents previously analyzed simply because of a l reduced release of radioactivity. This change will not increase the probability of any accident previously evaluated since the system ' operation and configuration remain the same and the surveillance test acceptance criteria is more restrictive by lowering the allowable system leakage. The change in test conditions in Section 3.16(2)a. is only editorial in
-nature to more accurately state the conditions under which the leak rate is measured. The statement added to the Basis Section of 3.16 is also editorial in nature to provide additional background information and show relation to control room habitability.
g # F1
- 1 ' t A + : 2.. Create-the-possibility of a new or different kind of accident from any
- c ' accident-previously evaluated..
The addition of two new fire detection zones will not create a new or different kind of accident from any previously evaluated since there will be new monitoring and deluge systems installed for each new area. The new filtration system will consist of redundant 99% efficient units rather than the single 90% efficient configuration that currently g exists. This does not create the possibility of a new or different kind of accident from any previously evaluated.
. Reduction of the allowable RHR system leakage only strengthens the surveillance of the system which in turn will ensure at least the same-
. level of system integrity.which exists under the current allowable leakrate. Furthermore, since no new or different modes of operation are -
proposed, no new or different kinds of accider.ts could be created I considering the continued use of the existing Technical Specifications' administrative controls for operation of the plant.
- 3. Involve a significant reduction in a margin of safety.-
The new monitoring and deluge systems for each unit are designed to alert , the operators and extinguish any fires without reliance on any existing _ fire protection equipment in-the area. Since the units are equipped with , their own monitoring and deluge systems, the margin of safety of any 1 existing system is not reduced. Dose calculations show that the existing single 90% efficient filer unit does not provide enough iodine removal capacity to achieve the design doselimitof.30 REM (SRP6.4)tothethyroid. In addition, a review of ! the design requirements stated in R.G. 1.52 showed the existing i filtration system and associated isolation dampers to not meet the ' redundancy criteria. i
- The new redundant 99% filter trains and associated bubble atight dampers,
-combined with the reduction in allowable RHR system leakage, will provide the required iodine removal to meet the dose limit as-well as all design requirements of R.G. 1.52, (i.e., redundancy, local and remote indication, humidity control, etc.).
O j The proposed reduction of the allowable RHR system leakage from 1 gom to - 1243 cc/hr reduces the postulated radiological consequences to the plant ; staff and the general public. The potential doses are well within the : requirements of 10 CFR 100.11 and GDC 19. l Section 3.16, page 3-85 states that the current one gpm leakrate is sufficiently high to permit prompt detection and to allow for reasonable leakage from the system and yet small enough to be easily handled by the pumps and radioactive waste system. Since the Technical Specifications do not set _a minimum RHR system leakage, credit for a certain level of j leakage to allow prompt detection appears to have no basis. The proposed lower leakrate is also more consistent with the historical "as found" condition of the system. Therefore, reduction of the allowable leakrate will not reduce the margin of safety of the system. Therefore, it can be concluded that the new filtration system and reduction of the allowable RHR System leakage will not reduce the margin of safety.
.a
g: e , -
- g C, :e ,
b [ Y * ! Based on the above. considerations, OPPD doas not believe that this amendment. e -involves 1a signiiLicant hazards consideration as defined by 10CFR50.92'and the proposed cha,nges will-not result in.a condition which'significantly alters the ;
< impact.of!the station on the environment. Thus,.the proposed changes meet'the L. Leligibility criteria for categorical: exclusion set forth in 10CFR51.22(e) (9) .
[ =and pursuant >to 10CFR51 22(b) no environmental. impact.or environmental. p assessment need'to be prepared. i
.I
?
i
'l b
g
,}}