ML20245D764

Proposed Tech Specs,Revising Control Room Emergency Makeup Air & Filtration Subsystem

ML20245D764
Person / Time
Site:	Seabrook
Issue date:	04/28/1989
From:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML20245D759	List: ML20245D756 ML20245D764
References
NUDOCS 8905010154
Download: ML20245D764 (11)

Text

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I Enclosure 1 to NYN-89046 Proposed Technical Specification Changes l

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PLANT SYSTEMS IL

& wro ? A Gl An mTR AT/on' $U85 YS TM 3/4.7.i CONTROL ROOM EMERGENCY P, CLEM UP SYST ".

LIMITING CONDITTON FOR OPERATION gi.,sm A;r ans nItraGon SAsptens

3. 7.)$ Two independent Control Rotm Emergency ^'- Clerup Sy:t=: shall be OPERABLE. .

APPLICABILITY: All MODES.

ACTION:

MODES 1, 2, 3 and 4:

pfqake,p Ae and F,Itrets. Suksystem ,

With one Control Room Emergency ^#- C1:=up Sy:t:: inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTOOWN within the

'following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

MODES 5 and 6: .

nak,op A;r aad filtratka Subsptem

a. With one Control Room Emergency ^ *- Cl:=up Sy:::: inoperable, l restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE Control -

Room Emergency .^ir C1=c. p Sjnu. in the recircuhti!r. mode. M*'di'*"M"/g" nnkaupp;,ud RIsratkn SAsysted gmy.v Ai, ara ratcat,aasasystems

b. With both Control Room Emergency y1:=up Sy:t=: inoperable, on-or with the OPERABLE-Control Room Emergency a'- Ch=up Sy:t:CMdes Air anJ F R d ion Alf rafio./rceirou lab. required to be in the ? :#rcuhtier mode by ACTION a. , not capable ""'1'

of being powered by an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS _

t gnakeup Air and (lLestkn Soseptem 4.7.\ Each Control Room Emergency ^'- Clerup Sy:t= shall be demonstrated l OPERA 8LE:

Z~NSER T A

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b te per:tur: E h:: th= cr equ:1 t: [SC] c;

b. At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 10 continuous hours with the heaters operating; i

l 16 W-STS 3/4 7- M

PLANT SYSTEMS X SURVEILLANCE REQUIREMENTS (C.ontinued)

c. At least once per 18 months or.(1) after any structural maintenance on the HEPA fiita or charcoal adsorber housings, or (2) following -

painting, firt . hemical release in any" ventilation zone communicating w 'ne system by:

qCatcat i.n

1) Verifying that the ch:nup system satisfies the in place -

penetration and bypass leakage testing acceptance criteria of 0I less than E*S% and uses the test procedure guidance in Regula-tory Position C.5.a C.g.c, and C.5.d of Regulatory Guide 1.52, Revisions- 2, March 1978, and the system flow rate is

//o o cfm t 10%;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accor-dance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2,. March 1978*, meets the laboratory testing criteria.

of Regulatory Posigion C.6.a of Regulatory Guide 1.52, Revi-sion 2, March 1978, for a methyl iodide penetration of less than [/oo]%; and

3) Verifying a system flow rate of Noe cfm 1 10% during system l operation when tested in accordance with ANSI N510-1975./96o

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a repre-sentative carbon sample obtained in accordance with Regulatory ,

Position C.6.b of Regulatory Guide 1.52, Revision.2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 19787 for a methyl iodide penetration of less than [213%;

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e. At least once per 18 months by:

.TNS ER 7 B' .

1) Verifying that the pressure-drop-eeress-thewbined HEPA- l

-#41ter: 2nd ch:rcoal :d::rt:r b:nk: i: 1;;s than [C] inche:

l Water ','auge w " 41: Op:r: ting th: :y t:: :t : 'lew r:ta cf no.. x_ r. .. .

2) Ver fying that en a Centdament Rhase " A" h0! tion 2nd uigh i I 6:ke 0:ncity te:t :ign:1, th: :y:t;; ut matically switches l 4tc 3 - recirculation rede ef_operatten

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) Verifying that the system maintains the control room at a positive pressure of greater than or equal to 1/87inchWater Gauge at less than or equal to a pressurization flow of doo I' cfm relative to adjacent areas during system operation; and

't) Verifying that' the heaters dissipate 3. 6 1 o.M. kW when l tested in accordance with ANSI N510-1975; and

5) Verifying that en : "igh Chierin:/ Text: Cas test ;ign:1, l the syster autocratically, reitcher Stc : re freulatier : d  !

of Operatier ith #1:u througn the HE?A fi : and char es!  !

adserber bank: within [15] sacends.

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SURVEILLANCE REQUIREMENTS (Continued)

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f. After each complete (or partial replacement of a HEPA filter bank, by verifying that the ::lc=up system satisfies the in place penetration and bypass leakage testing acceptance criteria of less than Ea#PM accordance with ANSI N510- for a 00P test aerosol while operating the system at a flow rate of //oo cfm i 10%; and .

/190 j)livat ion

g. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the cl ur.up system satisfies the in place enetration and bypass leakage testing acceptance criteria of less 05,_p th W[*]% in accordance with ANSI N510-)9M for a halogenated hydrocarbon refrigerant test gas while(operating the system "

at a flow rate of //0o cfm 10%. (frao w\\a tiEPA\\

0x05% valu ap\p ica\(e b filter oryhaal\ Ddso\ N rger' (fic1gncy h9n of99%isagume(d,or\1%whensHEP filter or cha s cal of 5% r les is\assuged i'q th NRCktaffs's sd ety\eva\adsogber se the'effic(enc lbatioq. N value ass \imed or'thecharcoalasorbe'qeff"cien(cyifthe\valugfortheHEPA g N slte'r i is' tiff ent \ rom the 'charc'oal adsorb r ef icie cy f the NRC tafs shfety eval (batio )

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Va ic e wi 1 b determirledb the llowing quat on: \

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andM,Filthe ciency asisumed inkthe SER fbr methyl \odik removal (%),\

afe'ty fa'ctor o a ' ount, for' char' coal egradatio'r( bet'aeen \ k \

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kesth k\(5 For\ s \stems s s

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-W-STS 3/4 7-17A

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INSERTS FOR TECHNICAL SPECIFICATION 3/4.7.6 As

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the Control Room is maintained below the limiting equipment qualification temperature in the Control Room area.

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1. Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks, for filter CBA-F-38, is less than 2.8 inches Water Gauge while operating the system at a flow rate of 1100 cfm 1 02:

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and verifying that the pressure drop across the combined HEPA filters '

charcoal adsorber banks, for filter CBA-F-8038, is less than 6.3 inches Water Guage while operating the cystem at a flow rate of 1100 cfm i 101.

2. Verifying that upon generation of an 'S' test signal, the following automatic system functions occurs

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close;

b. The control room exhaust subsystem isolation damper (s) close, and the exhaust fan trips off;

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and charcoal adsorber banks;

3. Verifying that upon generation of Remote Intake High Radiation test signal, the following automatic system functions occurs

a. The normal makeup air fan (s) trip off and the normal makeup air isolation damper (s) close; j

b. The control room exhaust subsystem isolation damper (s) close, and the exhaust fan trips off;

c. The control room emergency makeup air and filtration subsystem actuates with flows through the HEPA filters and chatroal adsorber banks; C:

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

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F Enclosure 2 to NYN-89046 Revised Bases

1 PLANT SYSTEMS BASES 3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION The limitation on steam generator pressure and temperature ensures that the pressure-induced stresses in the steam generators do not exceed the maximum allowable fracture toughness stress limits. The limitations of 70*F and 200 psig are based on a steam generator RT f 60*F and are sufficient to NDT prevent brittle fracture 3/4.7.3 PRIMARY COMPONENT COOLING WATER SYSTEM The OPERABILITY of the Primary Component Cooling Water System ensures that sufficient cooling capacity is available for continued operation of safety-related equipment during normal and accident conditions. The redundant cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the safety analyses.

3/4.7.4 SERVICE WATER SYSTEM The Service Water System consists of two independent loops, each of which a n operate with either a service water pump train or a cooling tower pump train. The OPERABILITY of the Service Water System ensures that sufficient cooling capacity is available for continued operation of safety-related equip-ment during normal and accident conditions. The redundant cooling capacity of this system, assuming a single failure, is consistent with the at,sumptions used in the safety analyses, which also assumes loss of either the cooling tower i or ocean c oling.

3_/4.7.5 ULTIMATE HEAT SINK f The limitations on service water pumphouse level, and the OPERABILITY requirements for the mechanical draft cooling tower and the portable tower makeup pump system, ensure that sufficient cooling capacity is available to either: (1) provide normal cooldown of the facility or (2) mitigate the effects of accident conditions within acceptable limits. This cooling capabil-ity is provided by the Atlantic Ocean except during loss of ocean tunnel water t

flow, when the cooling capability is provided by the mechanical draft cooling tower with tower makeup using portable pumps.

The limitations on minimum water level and the requirements for mechanical I draft cooling tower OPERABILITY are based on previding a 30-day cooling water l

supply to safety-related equi;; ment without exceeding its design basis tempera-ture and is consister,t with the recommendations of Regulatory Guide 1.27, j " Ultimate Hr.at Sint for Nuclear Plants," March 1974.

1 rd/Grycy NerEcP n/r Aus fztreprzw SogS/579/

3/4.7.6 CONTRO L ROOM "" " """" ' "" ^" '""""

gr,e Ape:yy The OPERABILITY of the Control Room ._,t M m r A J M ~ & S b u d ""!

" tM Sgtc ensures that:

l 1 (1) the allowable temperature for continuous-duty rating for the equipment and SEABROOK - UNIT 1 B 3/4 7-3

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PLANT SYSTEMS BASES grw&wc/ mrrup on? sMo intonck soasys7W  !

3/4.7.6 CONTROL ROOM ^"." """"L".T:C" S5TPi (Continued) instrumentation cooled by this system .is not exceeded; and (2) the control room will remain habitable for operations personnel during and following credible sasd7 C accident condidbnf.N The OPERABILITY of this system in conjunction with con-trol room design provisions is based on limiting the radiation exposure to per-sonnel occupying the control room to 5 rems or less whole body, or its equiva-t lent. This limitation is consistent with the requirements of General Design

' Criterion 19 of Appendix A, 10 CFR Part 50. p g p y 3/4.7.7' SNUBBERS All snubbers are required OPERABLE to ensure that the structural integrity of the Reactor Coolant System and all other safety-related systems is main-tained during and following a seismic or other . event initiating dynamic loads.

Snubbers are classified and grouped oy design and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features of the 2-kip,10-kip and 100-kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by Company "B" for the purposes of this Technical Specification would be of a different type, as would hydraulic snubbers from either manufacturer.

A list of individual snubbers with detailed information of snubber location and size and of system affected shall be available at the plant in accordance j

with Section 50.71(c) of 10 CFR Part 50. The accessibility of each snubber p shall he determined and approved by the Station Operation Review Committee (50RC). The determination shall be based upon the existing radiation levels and the expected time to perform a visual inspection in each snubber location as well as other factors associated with accessibility during plant cperations (e.g., temperature, atmos'phere, location, etc.), and the recommendations of Regulatory Guides 8.8 and 8.10. The addition or deletion of any hydraulic or mechanical snubber shall be made in accordance with Section 50.59 of 10 CFR Part 50.

Surveillance to demonstrate OPERABILITY is by' performance of the require-ments of an approved inservice inspection program.

Permanent or other exemptions from'the surveillance program for individual snubbers may be granted by the Commission if a justifiable basis for exemption is presented and, if applicable, snubber life destructive testing was performed to qualify the snubbers for the applicable design conditions at either the com-pletion of their fabrication or at a subsequent date. Snubbers so exempted shall be listed in the list of individual snubbers indicating the extent of the exemptions.

1 1 The service life of a snubber is established via manufacturer input and

.infonnation through consideration of the snubber service conditions and associated installation and maintenance records (newly installed snubbers, seal SEABROOK ' UNIT 1 B 3/4 7-4

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INSERTS FOR REVISED TECHNICAL SPECIFICATION BASES A

Cumulative operation of the system with the heaters on for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> over a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. Heaters run continuously to maintain the relative humidity below 70%.

B:

ANSI N510-1980 vill be used as a procedural guide for surveillance testing.

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t Enclosure 3 to NUI-89046 Basis.for Proposed Technical Specification Changes h

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Background:

USNRC Inspection Report 50-443/86-54 identified that the Seabrook Station Control Building HVAC (CBA) System was susceptible to a single active failure which would cause the isolation of both trains of the makeup air system. New Hampshire Yankee (NHY), in letters dated February 9, 1987 (NYN-87013) and March 2, 1987 (NYN-88024), provided justification for operation in this configuration up to 5% power and committed to modify the system design prior to full power operation.

Details of the proposed design modifications were provided to the NRC Staff via NHY letters dated Januar y 22, 1988 (NYN-88007) and June 17, 1988 (NYN-88084). The results of the NRC Staff review of this design modification are documented in an NRC letter dated August 24, 1988.

Description of Proposed Changes: i j

As a result of the above referenced design modification, the current Seabrook Station Technical Specification (3/4.7.6) will not reflect the system design nor will it adequately define system operability requirements. The proposed change is based on the Westinghouse Standard Technical Specifications which have been modified to reflect plant specific information.

Safety Evaluation of Proposed Changes:

New Hampshire Yankee has reviewed the proposed changes utilizing the criteria specified in 10 CFR 50.92 and has determined that the proposed changes would not

1. Involve a significant increase in the probability or consequences of an accident previously evaluated. This specification is being modified to ensure Control Room habitability during all operational modes. With the Control Room habitable as defined by 10 CFR 50 Appendix A, GDC 19 and Section 6.4 of the Standard Review Plan (SRP),

proper conduct of operations will not be hindered by the Control Room enviromnent. With Control Room habitability ensured, proper mitigation of design basis accidents can be performed by the Control Room '

personnel as currently described in the FSAR. Proper mitigation of the accident (s) ensures that radiological releases to the environment remain within limits established by existing design basis analyses. ,

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2. Create the possibility of a new or different kind of accident from any previously evaluated. Because these revised Technical Specifications ensure that Control Room habitability as defined in pertinent regulatory criteria is maintained, proper conduct of operations will J not be hindered by the Control Room environment. Therefore, no type f of accident could De caused directly or indirectly by this change. l I

3. It _/e a significant reduction in a margin of safety. The proposed changes reflect the revised system design which ensures that Control Room operation deses would be within the GDC-19 acceptance criteria and that the system will provide protection in accordance with SRP Section 6.4, 6.5.1, and 9.4.1.

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