ML20217C358

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Application for Amends to Licenses NPF-11 & NPF-18,adding Ventilation Filter Testing Program
ML20217C358
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 09/26/1997
From: Subalusky W
COMMONWEALTH EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217C365 List:
References
NUDOCS 9710010366
Download: ML20217C358 (29)
v • d • e


Text

. _

o mmoncanh ni~,n o miuny lealle Generaung Nation '

2 Nil North 2Ist Road M.irseilles 113 1341 9757 Tel Hl$ 35761 September 26,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Wathington, D.C. 20555

Subject:

Application for Amendment of Facility Operating Licenses NPF-11 and NPF-18, Appendix A, Technical Specifications,

' Addition of a Ventilation Filter Testing Program LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50 373 and 50-374 Pursuant to Title 10, Code of Federal Regulations, Part 50, Section 90 /

(10 CFR 50.90), Commonwealth Edison Company (Comed) proposes to (

revise Appendix A, Technical Specifications (TSs), of Facility Operating Licenses NPF-11 and NPF-18, LaSalle County Nuclear Power Station

, - (LaSalle), Units 1 and 2, respectively. Comed proposes to make the following revisions to the LaSalle, Units 1 and 2, TSs:

i

1. Drvwell and Suporession Chamber Purae Syster!1 i

. TS 3.6.1.8 and associated Bases will be revised to prchibit the simultaneous opening of the drywell and suppression chamber purge

/

system isolation valves;

2. Ventilation Filter Testina Proaram D/  ;

The requirements of Standby Gas Treatment System (SBGTS)

Technical Specification Surveillance Requirements (TS SRs) 4.0.5.3.b, 4.6.5.3.c, 4.6.5.3.d.1, 4.6.5.3.d.3, 4.6.5.3.e, and 4.6.5.3.f will be rolocated to TS 6.2.F.8, Ventilation Filter Testing Program, k"kS$N OEo ay3 lillllll!#llOl.lll%Ill,llilllllll A Unicom Company

U.S. Nuclear Regulatory Commission Page 2 September 26,1997 The requirements of Control Room and Auxiliary Electric Equipment Room (AEER) Emergency Filtration System TS SRs 4.7.2.b,4.7.2 c, 4.7.2.d.1,4.7.2.d.3,4.7.2.e,4.7.2.f, and associated footnotes will be relocated to TS 6.2.F.8, Ventilation Filter Testing Program, and TS 6.2.F.8 will be added to describe the Ventilation Filter Testing Program;

3. Other Control Room and Auxiliarv Electric Eouloment Room Emeroency Filtration System Chanoes TS SR 4.7.2.a will be revised to require flow through the cotiuol room and AEER recirculation filters; TS SR 4.7.2.d.2 will be revised to require the control room and AEER recirculation filters to be online while the surveillance is being performed and that both the control room and AEERs are to be maintained at a positive pressure; TS 3.7.2 Bases will be revised to specifically identify the control room and AEER recirculation filters being required for system operability; and
4. Editorial Chanoes TS 6.2.F 7 will be reformatted to be consistent with the remainder of TS 6.2.F. No technical changes will be made.

This proposed amendment request is subdivided en follows:

1. Attachment A gives a description and safety analysis of the proposed changes in this amendment.
2. Attachment B includes the marked-up TSs pages for LaSalle, Units 1 and 2, with the requested changes indicated.
3. Attachment C describes Comed's evaluation performed in accordance with 10 CFR 50.92 (c), which confirms that no significant hazards consideration is involved.
4. Attachment D provides an Environmental Assessment in accordance with 10 CFR 51.21.
5. Attachment E provides Calculation L-001166, Revision 1, " Post LOCA Control Room, Auxiliary Electric Equipment Room, and Offsite Doses," dated September 12,1997.

1 y U.S. Nucle:r Regul: tory Commission Page 3: _.

, 1 September 26,1997

6. . ~-Attachment F provides Calculation L 001119, Revision 1, 'VCNE Mixed Air Relative Humidity Calculation," dated September 12,-

-1997.This proposed amendment has been reviewed and approved by

' Onsite and Offsite Review in accordance with Comed procedures.

Comed requests approval of this license amendment request prior to startup of LaSalle, Unit 1, from its current forced outage, L1F35, currently scheduled for December 9,1997. The amendment should be made effective upon issuance for both units. Comed will implement the amendment prior to startup of LaSalle, Units 1 and 2, from their current outages.

Comed is notifying the State of Illinois of this application for amendment by transmitting a copy of this_ letter and its attachments to the designated state official.

If there are any questions or comments concoming this letter, please refer them to Perry Bamcs, Ragulatory Supervisor, at (815) 357-6761,

~

extension 2383. I Respectfully, (w __

W. T. Subalusky Site Vice President- y

.LaSalle County Station Enclosure cc: 'A. B. Beach, NRC Region lil Administrator

' M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle F. Niziolek, Office of Nuclear Facility Safety -IDNS

l STATE OF ILLINOIS )

Docket Noe. 50 373 50 374 IN THE MA7ER OF )

COMMONWEALTH EDISON COMPANY )_

LASALLE COUNTY STATION - UNITS 1 & 2 )

AFFIDAVIT I affirm that the cantent of this transmittal is true and correct to the best of my knowledge, information and belief,

'l'% %

N/illiam T. SubaIUsky A "~

Site Vice President LaSalle County Statio Subscribed and swom ) - t.efore me, a Notary Public in and for the State above named,' this 4/o L day of de of, Jws , IN7 . My Commission expires on lb - / . c/c c B .

OmCW. SEAL

, f L4 n b- e o AoLL M NOTARY su lLtygg Notarj' Putilic

( wcomssaEnEstoim

i i

l i' I I

i ATTACHMENT A LASALLE COUNTY NUCLEAR POWER STATION i

UNITS 1 AND 2 .

i DESCRIPTION AND SAFETY ANALYSIS i FOR PROPOSED CHANGES TO i

! FACILITY OPERATING LICENSES

NPF-11 AND NPF-18

! APPENDIX A TECHNICAL SPECIFICATIONS i

d VENTILATION FILTER TESTING PROGRAM i

i f

i 4

s 2-7-

l

I ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Description of the Proposed Change Commonwealth Edison Company (Comed) proposes to make the ,

following revisions to the LaSalle County Nuclear Power Station (LaSalle),

Units 1 and 2, Technical Specifications (TSs):

1. Drvwell and Suppression Chamber Purae System TS 3.6.1.8 and associated Bases will be revised to prohibit the simultaneous opening of the drywell and suppres,sion chamber purge system isolation valves; h4
2. Ventilation Filter Testina Proaram The requirements of Standby Gas Treatment System (SBGTS)

Technical Specification Surveillance Requirements (TS SRs) 4.6.5.3.b, 4.6.5.3.c, 4.6.5.3.d.1, 4.6.5.3.d.3, 4.6.5.3.e, and 4.6.5.3.f will be relocated to TS 6.2.F.8, Ventilation Filter Testing Program, The requirements of Control Room and Auxiliary Electric Equipment Room (AEER) Emergency Filtration System TS SRs 4.7.2.b,4.7.2.c, 4.7.2.d.1, 4.7.2.d.3,4.7.2.e,4.7.2.f, and associated footnotes will be relocated to TS 6.2.F.8, Ventilation Filter Testing Program, and TS 6.2.F.8 will be added to describe the Ventilation Filter Testing Program;

3. Other Control Room and Auxiliary Electric Eaulpment Room Emeroency Filtration System Chanaes TS SR 4.7.2.a will be revised to require flow through the control room and AEER recirculation filters; TS SR 4.7.2.d.2 will be revised to require the control room and AEER recirculation filters to be online v.hlle the surveillance is being performed and that both the control room and AEERs are to be maintained at a positive pressure; A-1

_ . . _ . . , a

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

.TS 3.7.2 Bases will be revised to specifically identify the control room and AEER recirculation filters being required for system operability; and

4. Editorial Channes TS 6.2.F.7 will be reformatted to be consistent with the remainder of TS 6.2.F. No technical changes will be made.

DescrlDtion of the Current Operating License / Technical Specification Reauirements

1. Drvwell and Suppression Chamber Purae System "3.6.1.8 The drywell and suppression c.hamber purge system may be in operation with the drywell and/or suppression chamber purge supply and exhaust butterfly isolation valves open for inerting, de-Inerting and pressure control. Purging through the Standby Gas Treatment System shall be restricted to less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days.

" APPLICABILITY: OPERATIONAL CONDITIONS 1,2 and 3.

" ACTION:

"With a drywell and/or suppression chamber purge systens supply and/or exhaust butterfly isolation valve open for other than inerting, de-inerting or pressure control, close the butterfly valve (s) within one hour or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

A-2

j i

i

. ATTACHMENT A DESCRIPTION OF. SAFETY ANALYSIS OF THE PROPOSED CHANGES E.

i  ; 2. Ventilation Filter Testina Pronram - I and 1

l j 3. Other Control Room and Auxillary Electric Eaulomont Room j Emeroency Filtration System Channes

- The current TS SRs associated with TS 3/4.6.5.3, Standby Gas Treatment System, are as follows:

"4.6.5.3 Each standby gas treatment subsystem shall be demonstrated OPERABLE:

a. "At least once per 31 days by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the subsystem operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters OPERABLE.
b. "At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the subsystem by:
1. " Verifying that the subsystem satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.S a, C.5.c and C.S.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 4000 cfm i10%.

A-3

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED.

CHANGES

2. " Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.
3. " Verifying a subsystem flow rate of 4000 cfm 10% during system operation when tested in accordance with ANSI N510-1975.

I

c. "After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber l operation by verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of j Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.
d. "At least once per 18 months by:
1. " Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than or equal to 8 inches Water Gauge while operating the filter train at a flow rate of 4000 cfm i 10%.
2. " Verifying that the filter train starts and isolation dampers open on each of the following test signals:
a. " Reactor Building exhaust plenum radiation - high,
b. "Drywell pressure - high, A-4 u

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

c. " Reactor vessel water level -low low, level 2, and d.- " Fuel pool vent exhaust radiation -

high.

3. " Verifying that the heatore dissipate 23 i 2.0 kw when tested in accordance with ANSI N510-1975. This readMg shall include the appropriate correction for variations from 480 volts at the bus,
e. "After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i 10%.
f. "After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or equal to 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i10%."

The current TS SRs associated with TS 3I4.7.2, Control Room and Auxiliary Electric Equipment Room Emergency Filtration System, are as follows:

"4.7.2 Each control room and auxiliary electric equipment room emergency _ filtration system train shall be demonstrated OPERABLE:

A-5

ATTACHMENT A DESCRlPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES l

a. "At least once per 31 days on a STAGGERED TEST BASIS by initiating, from the control room,

'; flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters OPERABLE.

b. "At least once per 18 months'* or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following i painting, fire or chemical release in any  !

ventilation zone communicating with the train by: l

1. " Verifying that the train satisfies the in-j place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a. C.S.c and C.S.d of

! Regulatory Guide 1.52, Revision 2, March 1978, and the train flow rate is 4000 cfm 1 10%.

l

2. " Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C,6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Rogulatory Guide 1.52, Revision 2, March 1978.
3. " Verifying a train flow rate of 4000 cfm 110% during subsystem operation when tested in ac::ordance with ANSI N510-1975.

A-6

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSEL CHANGES

c. "After every.720" hours of charcoal adsorber operation by verifying within 31 days after-removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978,

, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978.

d. "At least once per 18 months by:
1. " Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 8 inches Water Gauge while operating the train at a flow rate of 4000 cfm i10%.
2. " Verifying that on each of the below pressurization mode actuation test signals, the emergency train automatically switches to the pressurization mode of operation and the control room is maintained at a positive pressure of 1/8 inch W.G. relative to the adjacent areas during emergency train operation at a flow rate less than or equal to 4000 cfm:

a) "Outside air smoke detection, and b) " Air intake radiation monitors.

3. " Verifying that the heaters dissipate 2012.0 Kw when tested in accordance with ANSI N510-1975. This reading shall include the appropriate correction for variations from 480 volts at the bus.

A-7

)

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

e. "After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i 10%.
f. "After each complete or partial replacement of a charcoal adsorber bank *" by verifyir.g that the charcoal adsorbers remove 99% of a halogenated hydrocarbon refrigerant test gas when they are tested in place in accordance with ANSI N510-1975 while operating the system at a flow rate of 4000 cfm i 10%.
    1. "This surveillance shall include the recirculating charcoal filter, " odor eater," in the normal control room supply filter train using ANSI N510-1975 as a guide to verify > 70% efficiency in removing freon test gas.

"Except that recirculating charcoal filter samples shall be removed and analyzed at least once per 18 months."

4. Editorial Channes TS 6.2.F.7 is numbered and formatted inconsistent with the remainder of TS 6.2.F.

A-8 J

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Rapes for the Current Reauirements

1. Drvwell and Suppression Chamber Purae System in evaluating steam bypass of the suppression chamber, LaSalle assumed a maximum allowable leakage area of 0.03 square feet.

The only credible leakage path was assumed to be suppression chamber vacuum breaker valve seat leakage. The drywell and suppression chamber purge isolation valves were assumed to be closed.

2. Ventilation Filter Testina Pronram i

and

, 3. Other Control Room and Auxiliary Electric Eauloment Room Emerg_ency Filtration System Chanaes The TS SRs associated with filter testing of the SBGTS and Control Room and AEER Emergency Filtration System are based upon the requirements of the current revision of NUREG-0123," Standard Technical Specifications for General Electric Boiling Water Reactors (BWRl5)" at the time LaSalle, Units 1 and 2, were initially licensed.

These requirements reflected the industry standards at that time.

4. Editorial Channes TS 6.2.F.7 numbering and formatting is consistent with the Comed's application for LaSalle, Units 1 and 2, Technical Specification Amendments 110 and 95, respectively, Letter dated November 14, l 1995, TAC numbers M94063 and M94064, and issued by NRR letter dated March 11,1996.

A-9

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Description of the Need for Amendina the Operating License / Technical Specifications L 1. Drvwell and Suopression Chamber Purae System During a review of the LaSalle improved Technical Specifications (ITS) a question was raised regarding whether or not the SBGTS would become overpressurized if the drywell or suppression chamber purge supply and exhaust isolation valves were open for inerting, de-inerting or pressure control at the time a LOCA was initiated. It was also determined that the simultaneous opening of the drywell and suppression chamber purge supply and exhaust isolation valves currently allowed by LaSalle, Units 1 and 2, Technical Specifications would create a bypass path between the drywell and suppression chamber in excess of that assumed in the plant's design bases. These issues were documented in Licensee Event Report (LER) 50 373/97-005-00 dated March 24,1997. LER 50-373/97-005-01 was issued on June 19,1997, in part to commit to submit this proposed change to the LaSalle, Units 1 and 2, Technical Specifications to make the Technical Specliications consistent with the plant's design bases.

2. Ventilation Filter Testina Proaram During a System Functional Performance Review of th6 Control-Room and Auxiliary Electric Equipment Room Emergency Filtration System, it was determined that the surveillance procedures used to demonstrate operability were not in verbatim compliance with the associated TS SRs. It was also determined that a similar condition existed for SBGTS. This issue was documented in LER 50-373/97-004-00 dated March 17,1997. It was determined that the LaSalle filter testing should be updated to the current industry standard, which rer.iaires a TS change.

A-10

i ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

3. ' Other Control Room and Auxiliary Electric Eauloment Room Emeroency Filtration System Channes During a TS and design bases review of the AEERs it was determined that the AEERs are required to be habitable during design basis, events and that habitability could not be demonstrated. This issue was originally documented in LER 50-373/96-012-00 dated November 8,1996, and subsequently updated

, in LER 50-373/96-012-01 dated March 25,1997. Appropriate TS SRs

! need to be revised in order to demonstrate AEER habitability, l

4. Editorial Channes TS 6.2.F.7 needs to be reformatted for consistency with the remainder of TS 6.2.F.

Description of the Amended Operatina License / Technical Specification Recuirements

1. Drvwell and Suppression CAamber Purae System TS 3.6.1.8 Limiting Condition for Operation (LCO) will be revised to prohibit the simultaneous opening of the drywell and suppression chamber purge system butterfly isolation valves. The new LCO will read as follows:

"3.6.1.8 The drywell and suppression chamber purge system may be in operation with the drywell or suppression chamber purge supply and exhaust butterfly isolation valves open for inerting, de-inerting and pressure control. Purging through the Standby Gas Treatment System shall be restricted to less than or equal to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per 365 days."

A-11

. __ -a

1 1

ATTACHMENT A DESCRIPTION OF SAFETY' ANAL.YSIS OF THE PRC POSED

CHANGES i

TS 3.6.1.8 Action will be revised to be consistent with the new LCO.

The revised Action will read as follows: ,

"With any drywell or suppression chamber purge system

! supply or exhaust butterfly isolation valve oper. for other than

! inerting, de-inerting or pressure control, close the butterfly

! valve (s) within one hour or be in at least HOT SHUTDOWN l within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

l_ TS 3.6.1.8 Bases will be revised to describe the potential bypass _

, path that would be created if the drywell and suppression chamber i isolation valves were opened simultaneously. The revised Bases j will read as follows:

i j The drywell and suppression chamber purge supply and exhaust isolation valves are required to be closed during plant operation except as required for inerting, de-inerting and pressure control. During operations involving inerting,-

h( de-inerting and pressure control, only the drywell or

suppression chamber purge supply and exhaust isolation j valves may be open to prevent the creation of a bypass path between the drywell and suppression chamber. - Creation of a bypass path between the drywell and the suppression chamber air space through the vent and purga lines would allow steam and gases from a LOCA to bypass the downcomers to the suppression pool in excoss of design-bypass leakage. These valves have been demonstrated capable of closing during a LOCA or steamline break accident from the full open position."
2. Ventilation Filter Testina Proaram TS SRs 4.6.5.3.a and 4.6.5.3.d.2 will remain unchanged.

A-12

I 7

i ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED l CHANGES ,

i-

, TS SR 4.6.5.3 b wl'l be revised to read as follows:

l b. " Perform required standby gas treatment filter testing i in accordance with, and at th) frequency specified by, the Ventilation Filter Testing Program."

1

[ TS SRs 4.6.6.3.c, 4.6.5.3.d.1, 4.6.5.3.d.3, 4.6.5.3.e, and 4.6.5.3.t -.'ill be j revised to indicate " Deleted."

4 TS SR 4.7.2.d.2 will remain unchanged.

l l TS SR 4.7.2.b will be revised to read as follows:

b. " Perform required control room and auxiliary electric equipment roam filter testing in accordance with, and at the frequency specified by, the Ventilation Filter.

-Testing Program."

TS SRs 4.7.2.c, 4.7.2.d.1, 4.7.2.d.3, 4.7.2.e, and 4.7.2.f will be revised to indicate " Deleted."

A new TS 6.2.F.8, Ventilation Filter Testing Program, will be added to the Administrative Controls Section of TS. It will read as follows:

8. " Ventilation Filter Testing Proaram (VFTP)

"A program shall be established to implement the following required testing of Engineered Safety Feature (EsF) filter ventilation systems at the frequencies specified in Regulatory Guide 1.52, Revision 2, dated March 1978, and conducted in general conformance with ASME N510-1989' "The provisions of Specifications 4.01 and 4.0.3 are applicable to the VFTP test frequencies.

A-13

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

a. " Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate-

- air (HEPA) filters shows a penetration and system bypass < 0.05 % when tested in general conformance with Regulatory Guide 1.52, Revision 2, and ASME N5101989, at the system flowrate specified below:

ESF Ventilation Flowit..e (cfm)

System SBGT System a 3600 and s 4400 CREF System a 3600 and s 4400

b. " Demonstrate for each of the ESF system filter units that an inplace test of the charcoal adsorber shows a penetration and system bypass less than the value specified below, when tested in general conformance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989, at the system flowrate specified below:

ESF Ventilation Penetration and Flowrate (cfm)

System System Bypass SBGT System 0.05 % > 3600 and s 4400 CREF System 0.05 % a 3600 nnd s 4400 CRRF System 2.0 % 218000 and s 28900 AEERRF System 2.0 % 214000 and s 19900 A-14 I- . . . . .- .

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

c. " Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal-adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl lodido penetration less than the value specified below when tested at a temperature of 30*C, a relative humidity of 70 % and a face velocity as specified below in general conformance with ASME D3803-1989. ,

l

! ESF Ventilation Penetration Face l System Velocity (fpm)

SBGT System 0.5 % 40 CREF System 2.5 % 40 CRRF System 15.0 % 80 AEERRF System 15.0 % 80

d. " Demonstrate for each of the ESF systems that the pressure drop across the combined moisture separator, heater, profilter, HEPA filters and the charcoal adsorbers is less than the value specified below when tested at the system flowrate specified below:

ESF Ventilation Delta P Flowrate (cfm)

System (inches wg)

SBGT System 8 a 3600 and s 4400 CREF System 8 2 3600 and s 4400 '

A-15 v -_ ___

ATTACHMENT A

)ESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES

e. " Demonstrate that the heaters for each of the ESF systems dissipate the electrical power specified below when tested in general conformance with ASME N5101989. These readings shall include appropriate corrections for variations from 480 Volts at the bus.

ESF Ventilation Wattage (kw)

System

  • l SBGT System a 21 and s 25 CREF System a 18 and s 22
3. Other Control Room and Auxiliary Electric Eauloment Room Emeroency Filtration System Channes TS SR 4.7.2.a will be revised to require flow through the control room and AEER recirculation filters. The revised TS SR will read as follows:
a. "At least once per 31 days on a STAGGERED TEST BASIS:
1. By initiating, from the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the heaters OPERABLE, and
2. Manually initiating flow through the control room and auxiliary electric equipment room recirculation filters for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />."

A-16 l

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES TS SR 4.7.2.d.2 will be revised to require the control room and AEER recirculation filters to be online while the surveillance is being performed and that the both the control room and AEERs to be maintained at a positive pressure. The revised TS SR will read as follows:

2. " Verifying that on each of the below pressurization trode actuation test signals, the emergency train automatically switches to the pressurization mode of operation. Manually initiate flow through the control room and auxiliary electric equipment room recirculation filters and then verify that the control room and auxiliary electric equipment rooms are maintained at a positive pressure of greater than or equal to 1/8 inch W.G. relative to the adjacent areas during emergency train operation at a flow rate less than or equal to 4000 cfm:

a) "Outside air smoke detection, and b) " Air intake radiation monitors."

TS 3.7.2 Bases will be revised to specifically identify the control room and AEER recirculation filters being required for system operability. The revised Bases will read as follows:

"The OPERABILITY of the control room and auxiliary electric equipment room emergency filtration system, which includes the control room and auxiliary electric equipment room recirculation filters, ensures that the rooms will remain habitable for operations personnel during and following all design basis accident conditions. The OPERABILITY of this system in conjunction with room design provisions is based on limiting the radiation exposure to personnel occupying the rooms to 5 rem or less whole body, or its equivalent. This.

limitation is consistent with the requirements of General Design Criteria 19 of Appendix "A",10 CFR Part 50.

Cumulative operation of the system with the heaters A-17

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES OPERABLE for 10 houm over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filtsrs."

4. Edliorial Channel The paragraph numbering and indentation of TS 6.2.F.7 will be revised for consistency with the remainder of TS 6.2.F.

Bases for the Amended Operating License / Technical Roecification Reauest

1. Drvwell and Suppression Chamber Purae System The proposed revisions to TS 3.6.1.8 LCO, Action and Bases are

! required to make the TSs consistent with the assumptions used l when evaluating steam bypass of th) suppression chamber; i specifically, a ma.v.imum allowable leakage area of 0.03 square feet with the only credible leakage path was assumed to be suppression chamber vacuum breaker valve seat leakage.

2. y_antilation Filter Testina Proaram The proposed revisions to TS SRs 4.6.5.3.b,4.6.5.3.c,4.6.5.3.d.1, 4.6.5.3.d 3, 4.6.5.3.e, 4.6.5.3.f, 4.7.2.b, 4.7.2.c, 4.7.2.d.1, 4.7.2.d.3, '

4.7.2.e,4.7.2.f, associated footnotes, and a new TS 6.2.F.8 are consistent with the requirements contained in NUREG-1434, Revision 1, " Standard Technical Specifications, General Electric Plants, BWR/6," dated April 1995 and represent the current industry standards with respect to ventilation filter testing. Adoption of the NUREG-1434 format provides sufficient regulatory controls over the ventilation filter testing to be performed. The bases for the new TS 6.2.F.8, " Ventilation Filter Testing Program," are discussed below.

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l ATTACHMENT A i DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED l

CHANGES l

i 4

The Standby Gas Treatment (SBGT) filter unit has the following i

components: moisture separator, electric heater, profilter, upstream HEPA filter, type Ill (deep bed) charcoal filter and downstream HEPA. The filter unit has a rated flow of 4000 cfm at a design filter unit pressure drop of 0.5" water gauge. The heater is sized to maintain the relative humidity of the air stream to less than or squal '

to 70%. The charcoal filter has a 8 inch bed depth, and a charcoal

! orrespon s to a face veloc of 20 e per in e(p j Laboratory testing of the charcoal samples will be done at a face velocity of 40 fpm to be consistent with Regulatory Guide 1.52,

! Revision 2.

i

- The Control Room and Auxiliary Electric Equipment Room i Emergency (CREF) filter unit has the following components

moisture separator, electric heater, profilter, upstream HEPA filter, l type lli (deep bed) charcoal filter and downstream HEPA. The filter unit has a rated flow of 4000 cfm at a design filter unit drop of 8.5" water gauge. The heater is sized to maintain the relative humidity

- of the air stream less than or equal to 70%. The charcoal filter has i a 2 inch bed depth and a charcoal residence time of 0.25 seconds, j

which corresponds to a face velocity of 40 fpm at 4000 cfm.

t The Control Room Recirculation (CRRF) filter unit has the following i

components: profilter and type lli (dsep bed) charcoal filter. The

profilter always has flow through it when the train is running, while d

the charcoal filter is normally bypassed. The filter unit has a rated flow of 26,340 cfm. The relative humidity of the air s' ream is l maintained less than or equal to 70% by the HVAC cooling coil

, which removes moisture, room heat and fan heat, as demonstrated

! in Calculation L-001119, Revision 1, "VCNE Mixed Air Relative j Humidity,"- dated September 12,1997 (Attachment F). The charcoal filter haF a 2 inch bed depth and a charcoal residence time of 0.125 l seconds, which corresponds to a face velocity of 80 fpm at 26,340 i cfm.

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1 i

i

ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED -

CHANGES The Auxiliary Electric Equipment Room Recirculation (AEERRF) filter unit has the foiiowing components: profilter and a type ill (deep bed) charcoal filter. The profilter always has flow through it when the train le running, while the charcoal filter is normally bypassed. The filter unit was sized for a rated flow of 31,300 cfm. >

Modifications to the system have reduced the current design flow to 18,300 cfm. The relative humidity of the air stream is maintained less than or equal to 70% by the HVAC cooling coil whicl, removes rooisture, room heat and fan heat, also demonstrated in Calculation L-001119. The charcoal filter has a 2 inch bed depth and a charcoal residence time of 0.125 seconds, which corresponds to a face velocity of 80 fpm at 31,300 cfm.

The tables that follow provide a summary of the filter testing acceptance criteria proposed in the VFTP.

Inplace Filter Testing l

Filter Unit HEPA Charcoal penetration penetration & system bypass SBGTS < 0.05 % < 0.05 %

CREF < 0.05 % < 0.05 %

CRRF N/A < 2.0 %

AEERRF N/A < 2.0 %

The inplace HEPA and Chaicoal filter testing acceptance criteria, proposed for the SBGTS and CREF filter units, are taken directly from Regulatory Guide 1.52, Revision 2, " Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," dated March 1978.

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ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES The acceptance criteria used for the CRRF and AEERRF inpiace charcoal adsorber penetration is different than that identified in Regulatory Guido 1.52, Revision 2. The reason for this is that the CRRF and AEEttRF have an internal inlet and outlet damper for the

. charcoal filtr.r that isolate the charcoal filter during normal operation. A third internal damper provides a bypar,s path around the charr,oal filter. When the charcoal filter is manually initiated, the bypass damper closes and the inlet and outlet dampers open.

Sinc 9 the design leakage through the bypass damper is about 0.7 %

of tated flow and tha actual leakage values are less than 1.5 %, a renetration and system bypass acceptance criteria of 2.0 % was chosen.

Calculation L-001166, Revision 1, " Post LOCA Control Room,

! Auxillary Electric Equipment Room, and Offslie Doses," dated September 12,1S97 (Attachment E), e.ssumes a charcoal penetration and system bypass of 5.0%, for the CRRF and AEERRF filter units, which provides a factor of safety cf 2.6 between the design basis and the testing acceptance criter!a.

The acceptance criteria used far the CRRF and the AEERRF inplace charcoal filter penetrat!on and system bypass are also the same as a similarly designed recirculation filter unit at Byron Nuclear Power Station (Byron), Units 1 and 2, and Braidwood Nuclear Power L Station (Braidwood), Units 1 and 2. The requirements at Ey ron and Braidwood are contained in Byron, Units 1 and 2, and Braidwood, Units 1 and 2, TS 3.7.E, " Control Room Ventilation System." These requirements have been previously approved by the Staff and in-effect at Byron, Unli 1, since October 31,1984.

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1 ATTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES Performance of Activated Carbon Filter Unit Assigned Laboratory Decontamination penetration @ 30*C Efficiency and 70% relative humidity SBGTS 99 % < 0.5 %

CREF 95 % < 2.5 %

CRRF 70 % < 15.0 %

AEERRF 70 % < 15.0 %

s The assigned decontamination efficiencies are the efficiencies credited in the attached dose calculation. For both SBGT and CREF the efficiencies are consistent with Regulatory Guide 1.52, Revision

2. The charcoal residence time for the CRRF and the AEERRF is half that recommended by Regulatory Guide 1.52, Revision 2. To i

ensure that there will be reasonable charcoal life when testing to the ne.v standard, American Society of Testing and Materials (ASTM) D3803-1989, the decontamination efficiencies were lowered.

There is a factor of safety provided between the laboratory acceptance criteria and the value used in the dose calcu!: tlon to ensure that any degradation of the charcoal still results h6 an efficiency greater than that credited in the dose calcuhtien after one operating cycle. All of the filter units will have a factor of safety of 2 for charcoallaboratory testing. The NRC Staff has recently approved the use of a factor of safety of 2 for charcoal laboratory testing when using ASTM D3803-1989 testing protocol at test conditions of 30'C and 70 % relative humidity for Dresden Nuclear Power Station (Dresden), Units 2 and 3, by letter dated April 25,1997, issuing Techrilcal Specification Amendments 158 and 153 for Dresden, Units 2 and 3, respectively.

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_._.____.__._____.y 1

1 ATTACHMENT A j- DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES f

Calculation L-001166 calculates radiation dose to personnel in the

!- control room and auxiliary electric equipment room, as well as the

!- dose at the EAB and LPZ after a postulated design basis LOCA, in i the calculation several values were used for the source term and-

ventilation system parameters. The values that will make up the
design basis are
the Selmens source term; a four hour delay before starting the recirculation filters; minimum makeup air flow j rate of 1350 cfm for the control room ventilation system and 2250

[ cfm for the auxiliary electric equipment room ventilation system; 4 minimum recirculation flow rate of 18,000 cfm for the control room 4

ventilation system and 14,000 cfm for the auxiliary electric equipment room ventilation system; and duct inleakage of 1200 cfm i for the control room ventilation system and 1600 cfm for the -

auxiliary electric equipment room ventilation system. With these j values the control room dose is 19.5 rem and the auxiliary electric equipment room is 26.8 rom. Prior to declaring the control room
ventilation system or auxiliary electric equipment room ventilation

! system operable, the duct inleakage rates will be c'etermined via tracer gas testing and the inleakage rates will be verified to be less than 1200 cfm for the control room ventilation system and 1600 cfm 1

for the auxiliary electric equipment room ventilation system.

l- 3. Other Control Room and Auxiliary Electric E_guloment Room Emeroency Filtration System Channes

! Calculatica L-001166 demonstrates that the control room and AEER

. recirculation filter units are required to operate in order to maintain

! control room and AEER doses within 10 CFR 50, Appendix A, l General Design Criteria (GDC) 19 limits assuming that operator

action is taken within the first four heurs of accident initiation to l place these recirculation filter units in service.

I The proposed revision to TS SR 4.7.2.a is requ!rud to ensure that i any entrained moisture is periodically removed from the charcoal

!- adsorbers in the control room and AEER recirculation filter units to prevent charcoal degradation.

l A-23 i

o l

i l

i

/.TTACHMENT A DESCRIPTION OF SAFETY ANALYSIS OF THE PROPOSED CHANGES 4

The proposed revision to TS SR 4.7.2.d.2 is required to ensure that
system operability, as defined by periodic surveillance testing, satisfies the plant's design bases. Specifically, the proposed revision will ensure control room and AEER habitability during deeign basis events by maintaining a positive pressure of greater i

than or equal to 1/8 Inch water gauge relative to the adjacent areas

, during control room and AEER emergency filtration system operation in the pressurization mode of operation after manual laitiation of the control room and AEER recirculation filter units.

I j The proposed revision to the TS 3.7.". Bases is to clarify that th, j control room and AEER recirculation filter units are necessary comnanents of an operable control room and AEER emergency

filtration system, consistent with the proposed revisions to TS SRs 4.7.2.a and 4.7.2.d.2.

l

4. Editorial Chances i Tht proposed revisions to TS 6.2.F.7 are required for consistency with the rema!ader of TS 6.2.F.

) Schedule Comed requests approval of this license amendment request prior to

, startup of LaSalle, Unit 1, from its current forced outage, L1F35, currently schedulod for December 9,1S97. The amendment should be made effective upon issuance for both units. Comed willimplement the amendment prior to startup of LaSalle, Units 1 and 2, from their current

outages.

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