ML20215H911

Advises That Lack of Precise Agreement Between Tech Spec Change Originally Proposed in Hulman 870317 Memo to Donohew & Final Version of Change Now Being Processed.Technical Issue Re Filter Bank Remains Unchanged

ML20215H911
Person / Time
Site:	Pilgrim
Issue date:	04/28/1987
From:	Nerses V Office of Nuclear Reactor Regulation
To:	Thadani A Office of Nuclear Reactor Regulation
Shared Package
ML20215G262	List: ML20215G259 ML20215H911 ML20215H958
References
TAC-64475, NUDOCS 8705070145
Download: ML20215H911 (2)

Text

_

f( ' p, UNITED STATES NUCLEAR REGULATORY COMMISSION

{

% "j WASHINGTON, D. C. 20555

\...../

MEMORANDUM FOR: Ashok Thadani Assistant Director for Systems Office of Nuclear Reactor Regulation FROM: Victor Nerses Actino Pro.iect Director Project Directorate I-3, NRR

SUBJECT:

CONTROL ROOM AIR FILTER TEST, TECH SPEC CHANGE (TAC NO. 64475)

There is a lack of precise agreement between the Tech Spec change originally proposed, reviewed and reported in the 3/17/87 memo from Hulman to Donohew, and the final version of the change now being processed. The difference is that, because of interim correction of a typographical error, the current maximum allowable differential pressure across the Control Room Air Filter Bank is 8 in. H 07 rather than 3 in. H,0 as it was when the Tech Spec change was originally requested. However, the yhlue for which approval is being sought remains the same; 6 in. H90. We have concluded that the technical issue of whether 6 in. H9 0 across the filter bank is satisfactory remains unchanged, and therefore the introductory language in the 3/17/87 memo from Hulman to Donohew referring to 3 in. H2 O is not relevant to the technical conclusion.

Consequently, unless advised differently by you, we intend to use the 3/17/87, Hulman to Donohew, memo as the Safety Evaluation document of record in support of changing the allowable differential pressure across the filter bank to 6 in.

Hg 0 at 1000 cfm +10% or the calculated equivalent.

The background consists of five pieces of correspondence, synopsized as follows; copies are enclosed.

(1) In its 1/10/87 letter BEC0 87-007, RECO proposed a change which would increase allowable test success pressure across the Control Room HEPA Filter System (CRHEAF) from 3 in. H O to 6 in. H 70 based on a fan head-flow curve rather than on 1000 cfm.2 The curve would have 6 in. H70 and 1000 cfm as a data point. BECO also pointed out that the differential pressure of 3 in. H,0 was probably a typo and should have been 8 in. H 90.

This request was forwarded to the Plant Systems Branch for review under TAC 64475.

(2) BEC0 found they could not meet the 3 in. H90 criterion and requested emergency relief from Tech Spec requirements to allow fuel off-load to proceed. This request was made in their 1/27/87 letter number BECO v 87-015. V (3) NRC responded on 1/29/87 with a correction to amendment 42 which recognized the typo and changed 3 in. pH 0 to 8 in. H 0' 2

0705070145 870428 PDR ADOCK 05000293 P PDR

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4 Il Ashok Thadani (4) On 2/25/87 BECO 87-036 acknowledged the correction and requested continued review and approval of the original Tech Spec- change request.

(5) On 3/17/87 the Plant Systems Branch responded to the original request, and in describing the action referred to increasing the allowable-differential pressure from 3 in. H O to 6 in. H 0.

2 2 Victor Nerses, Acting Project Director Project Directorate I-3 Division of Reactor Projects I-II

Enclosures:

As stated DISTRIBUTION NO NRC PDR Local PDR BBoger VNerses PShuttleworth PDI-3 r/f 1

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OFFICIAL RECORD COPY

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• 10CFR50.90 BOSTON EDISDN COMPANY 800 BovLaTON STREET 50 BTON, MASS ACMUS ETTs c219 9 J. EDWARD MQWARD

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January 19, 1987 BECo 87-007 Proposed Change 87-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Proposed Technical Specification Change to Section 4.7.B.2.a

Dear Sir,

Pursuant to 10CFR50.90, Boston Edison hereby proposes the attached modification to Appendix A of Operating License No. DPR-35. This modification revises the acceptance criteria for flow and filter train differential pressure for the Control Room High Efficiency Air Filter System (CRHEAF). The proposal is made to reduce overly restrictive criteria, the strict interpretation of which prevents the system from being considered operable.

The strict interpretation is also in conflict with vendor design information.

Should you wish further information on this submittal, please contact us.

Very truly yours, PMK/ns '

Attachment' One Original and 37 Copies t Commonwealth of Massachusetts)

County of Suffolk )

1 Then personally appeared before me, J. E. Howard, who, being duly sworn, did j state that he is Vice President - Nuclear Engineering and Quality Assurance l Department of. Boston Edison Company and that he is duly authorized to execute i and file the submittal contained herein in the name and on behalf of Boston l Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.

My commission expires: 8,O_ el/ /988 DATE 7

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N -S0570N' EDISON COMPANY January 19,'1987

!.,, J.S. Nuclear Regulatory Commission-3, Page :

cc: U.S. Nuclear Regulatory Commission.

Region;I

' 631 Park Avenue

-King of Prussia, PA 19406

-Senior NRC Resident Inspector Pilgr.im Nuclear. Power Station Robert M. Hallisey, Director

-Radiation Control Program Mass. Dept. of Public Health 150 Tremont-Street.F-7 '

Boston, MA~ - 02111.

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Proposed Change to Technical Soecifications Prccosed Change Reference is made to Pilgrim Station Operating License No. DPR-35, page 158B.

Section 4.7.B.2.a. This currently states:

At least once every 18 months the pressure drops across each comoined filter train shall be demonstrated to be less than 3 inches of water at 1000 cfm.

This will be changed to provide 6 inches of water pressure drop and a 107.

tolerance to the flow rate, and shall state, in part: "

... less than 6 inches of water at 1000 cfm or the calculated equivalent."

Reason for Change .

The change is proposed to allow flexibility in surveilling the Control Room High Efficiency Air Filtration (CRHEAF) system. The existing 1000 cfm is too restrictive in that no tolerance is specified, therefore strict compliance requires a flow rate of exactly 1000 cfm. This is contrary to common operating practice in that it does not provide for small variations in the system, the atmosphere, or measuring at any particular surveillance.

The "3 inches of water" pressure drop is very restrictive when applied'to the combined filter train, as currently required. A review of vendor design information indicates that 3 inches of differential pressure is the vendor recommended action point for changeout for each HEPA filter. Each filter train consists of a prefilter, two HEPA filters, a charcoal adsorber, and heaters, all of which contribute to differential pressure. When 3 inches is applied to the combined HEPA filters it is overly restrictive vis-a-vis the vendor recommended criteria, i.e., filters should be either tested separately to 3 inches or less, or the differential pressure raised to 6 inches or less for the combined filter train.

Safety Considerations The addition of a " calculated equivalent" to the CRHEAF acceptance criteria is in keeping with the standard engineering and operating practice of providing tolerance in measuring HVAC system flow performance, and allows the procedural use of a performance curve with flow rates bounded by TS 3.7.B.2.d.

The changing of the differential pressure criterion to 6 inches of water is acceptable for the following reasons:

o The summation of vendor recommended action levels for all components in each filter train gives a total differential pressure of approximately 8 inches of water; o The maximum vendor allowed differential pressure across any og HEPA unit is 8 inches of water; o The expected value for the summation of component differential pressures for a filter train with new filter media is approximately 3.75 inches of water; W#

e ,.

Therefore. a value of 6 inches of water across the combined filter train comoonents is conservative because it will prompt action before any single HEPA would 3ch its maximum, and before the vendor recommended level for the combined filter train is reached.

This proposed change has been reviewed by and approved by the Operations Review Committee and reviewed by the Nuclear Safety Review and Audit Committee.

Succorting Information and No Significant Hazards Conditions Analyses The proposed change provides a tolerance to the test success criteria for CRHEAF by allowing the use of a procedural curve relating differential pressure to 1000 cfm as bounded by TS 3.7.8.2.d. The change also raises the differential pressure criteria to 6 inches from 3 inches of water.

The Code of Federal Regulations. 10CFR50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10CFR50.92, about the issue of no significant hazards consideration. Therefore, in accordance with 10CFR50.91 and 10CFR50.92 the following analysis has been performed.

1. Operating Pilgrim Station in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The CRHEAF creates a positive pressure in the Control Room, using air from which it has filtered out radiolodines and particulates. Currently, TS 4.7.8.2.a requires that at least once every 1,8 months a pressure drop of less than 3 inches of water be demonstrated atross the filters at a flow rate of 1000 cfm. TS 3.7.B.2.d requires that CRHEAF fans operate within 1000 cfm 1107.. The system is designed to provide a positive Control Room pressure if the fans can provide a flow rate of 900 to 1100 cfm and the filters are not plugged. Vendor information indicates that filter degradation from plugging is indicated by a differential pressure of 3 inches or greater of water across each HEPA filter. Therefore, when measured across two HEPA filter elements, and the rest of the CRHEAF components which create differential pressure, a differential of less than 6 inches of water demonstrates that HEPA plugging has not reached action levels. Hence, if the fans can generate 900 to 1100 cfm to satisfy 3.7.B.2.d, and has a pressure drop across the filter trains less than 6 inches at 1000 cfm or the calculated equivalent, sufficient flow exists to provide a positive pressure in the Control Room. Therefore, the purpose of the CRHEAF as a mitigator of the results of an accident will not be impaired by this proposed change. Hence, allowing the differential pressure of 6 inches of water 1000 cfm to be established at flow rates between 900 and 1100 cfm in conformance with a calculated procedural acceptance curve will not involve a significant increase in the probability or consequences of an accident previously analyzed.

2. Operating Pilgrim Station in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

. . - - .. ~ ~ .-

The purpose of CRHEAF is to mitigate the consequences of certain accidents Oy filtering out radiolodines and particulates from air which is then used to maintain a positive pressure in the Control Room. The amendment allows a tolerance by allowing a calculated value. based on 6 inches of water at 1000 cfm. to be used for demonstrating that the filter train elements are not plugged. The flow range for the calculated value is 900 - 1100 cfm, ceterminea by existing TS 3.7.B.2.d.

The change to 6 inches of water from 3 is in compliance with vendor information. The change of these criteria therefore is consistent with the design and fan capabilities of the system, and does not degrade the system's ability to perform its designed function of providing positive pressure in the Control Room with filtered air; therefore, operating Pilgrim in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident .

previously evaluated.

3. Operating Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.

The proposed change does not reduce the CRHEAF's ability to perform its designed function of creating a positive pressure in the Control Room with filtered air. Hence, accident analysis which take credit for CRHEAF as a mitigator are not affected and the safety margin remains the same.

Therefore, the operation of Pilgrim in accordance with the proposed amendment to TS 4.7.B.2.a will not involve a significant reduction in the margin of safety.

Schedule of Change This change will become effective immediately following approval by the Commission.

Fee Determination Pursuant to 10CFR170.12(c) an application fee of $150.00 is appropriate. The fee will be provided under a separate cover letter in the near future.

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l 4

3.7.5 (Continued) 4.7.B (Continued)

- 2. Control Room High Efficiency Air 2. Control Room High Efficiency Air

,, Filtration System Filtration System

- *a. Except as specified in a. At least once every 18 months Specification 3.7.B.2.c below, the pressure drop across each

. both trains of the Control Room combined filter train shall be 4 High_ Efficiency Air Filtration demonstrated to be less than 6 System used for the processing inches of water at 1000 cfm or

] .of inlet-air to the control room the calculated equivalent.

under accident conditions and the diesel generator (s) required b. (1.) The-tests and analysis for operation of each train of- of Specification the system shall be operable 3.7.B.2.b shall be whenever secondary containment. performed once every 18

, integrity is required and during months or following fuel handling operations, painting, fire or

- chemical release in any ,

i

b. (1.) The results of the inplace ventilation zone cold DOP tests.on HEPA communicating'with the filters shall show 199% ' system while the system DOP removel. The results is operating.

of the halogenated i

hydrocarbon tests on (2.) Inplace cold DOP testing charcoal adsorber banks shall be performed after shall show 199% .

each complete or partial halogenated hydrocarbon .

replacement of the HEPA j removal when test results filter bank or after any

{ are extrapolated to the structural maintenance 4

i initiation of the test. on the system housing which could' affect the-

) (2.) The results of the HEPA filter bank bypass i laboratory carbon sample leakage.

analysis shall show 195% .

l methyl lodide removal at a (3.) Halogenated hydrocarbon

velocity within 10% of testing shall be

, system design, 0.05 to performed after each

! 0.15 mg/m' inlet methyl complete or partial iodide concentration, 170% replacement of the R.H., and 1 125'F. charcoal adsorber ba,nk or after any structural

• c . From and after the date that one maintenance on the i train of the Control Room High system housing which i Efficiency Air Filtration System could affect the is made or found to.be incapable charcoal adsorber bank of supplying filtered air to the bypass leakage.'

control room for any reason,

- reactor operation or refueling. (4.) Each train shall be operations are permissible only operated with the '

during the succeeding 7 days, heaters in automatic for If the system is not made fully at least 15 minutes operable within 7 days, reactor every month.

• Conditional Relief granted from this (5.) The test and analysis of-LC0 for the period February 5,1982 Specification to startup for cycle 6. 3.7.8.2.b.(2) shall be performed after every-720 hours of. system

, operation.

Amendment No. 1588.

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,- BOSTON EDISON , COMPANY P ,

800 50VLaTON ETREET -

BOSTON. MAssAcHustTTs D2199  ?

J. EDWARD HOWARD

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January-27,.1987' BECo 87-015 i

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U.S. Nuclear Regulatory Commission

Attn: ~ 0ocument Control Desk

- Washington,'DC 20555 i License DPR-35

j. Docket 50-293

Subject:

Request for Emergency Relief from Technical Specification j 4.7.B.2.a. Control Room High Efficiency Air Filtration System i

References:

1) BECo Letter #87-007, dated January'19, 1987, " Proposed Technical Specification Change to Section 4.7.B.2.a"

2) NRC Letter to Boston Edison dated January 7, 1975

3) BECo Letter to NRC dated May 1,'1975

Dear Str:

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1 This letter requests emergency relief from Technical Specification.(Tech' Spec)

4.7.B.2.a while our Tech Spec change (Reference 1) is being processed.

j Relief is required by January 31, 1987 in order to support fuel off-load at i Pilgrim Station.

Emergency relief is requested because the Tech Spec required surveillance is l overly conservative and unachievable even when the system performs as-

] designed. At this time the system is physically operable, can perform its intended safety function and yet is unable to pass the surveillance test as currently specified.

j. Our rescarch into the origin of this surveillance requirement has led us to

~

conclude that it was incorrectly incorporated into the Tech Spec probably due

to an undetected typographical error (see enclosure). Since it's receipt, the 4 surveillance has been met only with great difficulty and.by utilizing'a 110%

fan flow tolerance on the design flow rate (1000 cfm).

The NRC resident inpsector and plant personnel believed a-Tech Spec change requested in August 1985 would address this problem. This Tech Spec change referred to involved the same section of the Tech Spec but did not address this issue. Accordingly, we did not recognize the continued existence of this problem until late December 1986.

1 l Recognizing the impending fuel movement date, we pursued all available_' avenues-

! of compilance to avoid requesting relief. We tested and retested the system, making adjustments and replacing _ components. We also considered the m

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BOSTON EDISON COMPANY

. January 27.-1987

, . . U.S. Nuclear Regulatory _ Commission

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Page 2 Lre-scheduling of-fuel movement. However, our attempts proved to be unsuccessful.

One avenue-which we are continuing'to explore is'to perform a temporary.

modification under 10CFR50.59. This would enable the system to pass the-test and would negligibly reduce design margin. While this is_ allowable, in our judgement, emergency relief is preferred to the temporary modification because 1t does not unnecessarily change the configuration of the plant to-resolve an administrative error.

Should the Tech Spec problem not be resolved, the impact on the outage is twofold:

1. -delay fuel movement which results in additional delays'of other outage tasks that cannot begin until fuel is removed from the vessel, and

2. replacement of fuel costs of approximately 300 thousand dollars per day could total in excess of 13 million dollars.

Additional information and justification for this request is enclosed.

No interim compensatory measures are required while the Tech Spec change is being processed because the system is fully operational and meets its design basis. It cannot, however, be quallfled against overly _ restrictive criteria currently in the Tech Spec.

The system exists to protect control room personnel in the event of a radiological event; its presence or absence therefore has' negligible impact on the external environment. Emergency breathing apparatus is available as a back-up measure to ensure control room habitability. The' change does not create undue risk, and will not endanger' life or property because the change will serve to ensure proper system operability.

Reference 1 provided the information necessary to conclude no significant hazards considerations exist and included revised Tech Spec pages.

Mr. Robert Hallisey, Director Radiation Control Program, Mass. Dept. of Public-Health was contacted on January 26, 1987 and apprised of the contents of this letter, the January 19, 1987 letter, and the circumstances involved in this issue.

Very truly yours, TAV/ns Enclosure cc: see next page

i. '

TBOSTON EDISON COMPANY January 27, 1987

. ., . - U.S. Nuclear Regulatory Commission 1

Page 3 cc:

. John A. Zwolinski, Director SWR _ Project Directorate #1 Division-of Licensing.

Office of. Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC' 20555 >

Dr. Thomas E. Murley_

Regional Administrator i Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region I .

631 Park Avenue King-of Prussia, PA 19406 I

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J' Enclosure to BECo Letter 87-015 dated, January 27, 1987 OISCUSSION:

The intent of the existing Tech Spec surveillance 4.7.B.2.a is to ensure that filter cartridges in the control room high efficiency air filtration system are clean and unrestricted. To ensure this a differential pressure measurement is taken at design flow rate and compared to the surveillance test limit. The existing limit is too restrictive in that the acceptance criterion of 3" of water at 1000 cfm can only be achieved with the application of the +~

107. fan flow tolerance found in Tech Spec 3.7.B.2.d. This has been our procedural practice since the incorporation of 4.7.B.2.a into Pilgrim's Tech Specs. The history of how these acceptance criteria came about lends credence to the fact that this is not a technical issue but merely administrative.

In a letter dated January 7, 1975, (Attachment 2) the NRC requested BECo to augment the Limiting Conditions for Operation (LCO) and Surveillance Requirements related to installed filter systems. These additional LC0's and Surveillances were considered necessary in order to ensure high confidence that the systems will function reliably, when needed, at a degree of efficiency equal to or better than that assumed in the accident analyses.

Accompanying this letter was a set of model Tech Specs for guidance in what the NRC would consider acceptable. For Control Room Air Treatment Systems, the model Tech Specs recommended an acceptance criteria of less than 6" of water at system design flow rate. BECo responded by proposing an acceptance criteria of less than 9.5" of water at 1000 cfm (Attachment 3).

Our notes from a series of telephone conversat.l.ons between BECo and NRC management indicate that less than 8" of water at 1000 cfm was an acceptable change to our initial proposal of less than 9.5" of water. When the amendment was issued (Amendment 42 dated May 12, 1980) the wording specified less than 3" of water at 1000 cfm. No material can be found on our docket concerning the origin of the 3". This probably was a typographical error. Amendment 42 was necessary for startup from Refuel Outage #4. The surveillance was conducted and passed with the procedural acceptance criteria of i 107. fan flow. This acceptance criteria of Tech Spec 3.7.B.2.d was assumed to be inherent to the 1000 cfm of Tech Spec 4.7.8.2.a. Plant startup occurred on May 21, 1980.

BECo continued to utilize this assumption, but meeting this specification has been difficult and marginal.

Absent the NRC granting this emergency relief fuel movement could be delayed.

This would effectively derate Pilgrim for whatever period of time it takes to process the change in the normal fashion (i.e., DL Operating Procedure 228).

Delaying fuel movement would result in additional delays of other outage tasks that cannot begin until fuel is removed from the vessel. The external expertise needed to perform these tasks has been pre-arranged and is available for a specified period of time only. Re-scheduling this work would depend'

,m h .

upon their flexibility in changing commitments already made elsewhere_in the

, Industry. Examples of the tasks wnien would be jeopardized are:

Relocation of the Reactor Water Level reference legs outside the drywell to eliminate heatup induced level _ errors Analog Trip System Installation to improve reliability and eliminate RPS System challenges Reactor Vessel Dry Tube Inspection / Replacement (SIL 409)

In-Vessel Instrument Line Inspection (SIL 420)

Installation of Hydrogen Water Chemistry Probe.

Fuel unload'ing is scheduled to commence on January 31, 1987 and will take between 10 and 30 days to complete. Recognizing this date could shift slightly due to unforeseen circumstances, we will keep the NRR Project Manager apprised on a daily basis.

Attachments: 1) BEco Letter #87-007, dated January 19, 1987, " Proposed Technical Specification Change to Section 4.7.B.2.a"

2) NRC Letter to Boston Edison dated January 7, 1975

3) BEco Letter to NRC dated May 1, 1975

1. o g UNITED STATES J. ,  ! g NUCLEAR REGULATORY COMMISSION

4 ._ ,  ; WASHINGTON. D. C. 20$$$

k ..... ,o8 January 29, 1987 Docket No. 50-293 Mr. James M. Lydon Chief Operating Officer Boston Edison Company POO Boylston Street Boston, Passachusetts 02199

SUBJECT:

CORRECTION TO AWENDMENT 42 Pe: Pilgrim Nuclear Power Station Amendment 47 to Facility Operating License No. DPR-35 for the Pilgrim Nuclear Power Station was issued on May 12, 1980. Technical Specification (TS) 4.7.B.2.a for the Control Room High Efficiency Air Filtration System (CRHEAFS) specified that the pressure drop across each combined filter train shall be less than 3 inches of water at 3000 cfm. Your letter of January 19, 1987 as supplemented January 77, 1987 requested a change to provide a pressure drop of less than 6 inches of water and a 10% tolerance to the flow rate (1000 cfm). You also stated that your research into the origin of the 3 inch surveillance requirement indicates that there was a typographical error in this pressure drop number.

The staff's review of the correspondence between Boston Edison Company and NRC from 1975 to 1980 indicates that there was a typographical error in TS 4.7.B.2.a as issued in Amendment 42. We have arrived at this conclusion via a thorough review of the activities of the time which included ongoing dialogue to establish the proper technical specification number to be used in both the

! Standby Gas Treatment System (SBGTS) and CRHEAFS. The TS for the SBGTS was issued using the number "8 inches" while the TS for the CRHEAFS was issued

! with "3 inches." We have detemined that the number 3 is a typographical error i and that the correct value is 8 inches for the CRHEAFS. We have enclosed a corrected TS page number 158P.

)

Your request as stated in letters dated January 19 and '17,1987 is being addressed in a separate licensing action.

Joh

%Cf Sincerely, q.

A. Zwolinski, Director BWR Pro,iect Directorate #1 Division of BWR Licensing '

cc w/ enclosure:

See next page

-S;ZGRd6G,376 l 1

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Mr. James M. Lydon Boston Edison Company Pilgrim Nuclear Power Station CC:

_Mr. Alfred E. Pedersen, Station Manager Boston Edison Company i

RFD #1, Rocky Hill Road Plymouth, Massachusetts 02360 Resident Inspector's Office U. S. Nuclear Regulatory Commission Post Office fox 867

Plymouth, Massachusetts 02360 l Chairman, Board of Selectnen 11 Lincoln Street Plymouth, Massachusetts 02360 i

Office of the Commissioner Massachusetts Department of

, Environmental Quality Engineering One Winter Street i Poston, Massachusetts 02108 .

, Office of the Attorney General i

1 Ashburton Place i 19th Floor l Boston, Massachusetts 02108

, Mr. Robert M. Hallisey, Director Radiation Control Program Massachusetts Department of l Public Health

! 150 Tremont Street, 2nd Floor Boston, Massachusetts 02111

' Regional Administrator, Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. James D. Keyes Boston Edison Company 25 Braintree Hill Office Park

Braintree, Massachusetts 0?l84 l

i I

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3.7.5 (Continued) ,

4.7.3.(Continued)

2. Control Room High Ef'ficiency Air 2. Control Room High Efficiency Air I 1 Filtration System

. Filtration system ga. Except as specified in

s. At least once every la -

Specification 3.7.3.2.c months the pressure drop below, both trains of the - across each combined filter ,

train shall be demonstrated  ;

Control Room High Efficiency Air Filtration System used to be less than 8 inches of -

for the processing of inlet water at 1000 cfin. ,

air to the control room under .

accident conditions and the 6. (1.) The tests and analysis of. I diesel generator (s) required Specification 3.7.8.2.b (

, for operation of each shall be performed once t train of the system shall every 18 months or be operable whenever secondary following painting, fire Y containment integrity is or chemical release in yi -

required and during fuel any ventilation zone -

handling operations. comunicating with the c.'

, sys_132 while the system

b. ('1.) The results of the in- . is operating, .

place cold DOP tests on . I, HEPA filters shall show - (2.) Inplace cold D0P testing  ?

>991 DOP removal. The shall be performed after 7esults of the halogenat- each complete or partial

&r ed hydrocarbon tests on replacement of the HEPA f

charcoal adsorber banks filter bank or after any 3 shall show >99% halogenat- .

ed hydrocarion removal structural maintenance g.

• on the system housing j when test results are .

which could affect the extrapolated to the HEPA filter bank bypass initiation of the test. ",-

, ,. leakage. ,

(2.) The results of the (3.) Halo enated hydrocarbon -

laboratory carbon sample - test ng shall be performed 4 analysis shall show >g55 after each complete or methyl iodide removaT at ,.

partial replacement of

- a velocity within 10% of the charcoal adsorber .

. system de i n. 0.05 to .

bank or after any 0.15 mg/m niet methyl . structural maintenance l fedide concentration. on the system housing

>701 R.H., and >1250F. - which could affect the charcoal adsorber bank ..

e c. From and after the date that bypass leakage. ,y j one train of the Control Room High Efficiency Air Filtration (4.) Each ftrain shall be r-System is made or found to be .. operated with the heaters incapable of supp ying filtered in automatic for at least air to the contro room for any 15 minutes every month, i.

reason, reactor operation or refueling operations are (5.) The test and analysis of e.

permissible only during the S zecification 3.7.3.2.b.(2.) ,

succeeding 7 days. If the siall be perfomed after system is not made fully oper- l every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system a51e within 7 days, reactor operation. .

• Conditional Relief granted from ',

this LCO for the period February -

i 5 .1982 to startup for cycle 6.

I Amendment No. . J/. 52 '

y0L Corrected: anuary 29. 1987

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3.7.3 (Contin 6ed) , 4.7.3 (Continued)

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2. Control Room HigH Efficiency Air 2. Control Room High Efficiency Air Filtration System Filtration System g a. Except as specified in

a. At least once every 18 Specification 3.7.3.2.c . months the pressure drop below, both trains of the

• across each combined filter Control Room High Efficiency train shall be demonstrated

. Air Filtration System used to be less than 8 inches of l for the processing of inlet water at 1000 cfa. ,

air to the control room under accident conditions and the b. (1.) The tests and analysis of.

diesel generator (s) required Specification 3.7.8.2.b .

for operation of each shall be performed once train of the system shall every 18 months or be operable whenever secondary following painting, fire 3 containment integrity is or chemical release in y required and during fuel any ventilation zone .'

handling operations. comunicating with the sys_1t2 while the systen .

b. ('1.) The results of the in- - is operating,  ;

place cold DOP tests on .

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HEPA filters shall show . (2.)InplacecoldDOPtesting y

>99% DOP removal . The shall be performed after j-results of the halogenat- each complete or partial ,

ed hydrocarbon tests on replacement of the HEPA ,

charcoal adsorber banks filter bank or after any shall show >99% halogenat- .

ed hydrocarlion removal structural maintenance .-

[ when test results are -

on the system housing which could affect the extrapolated to the HEPA filter bank bypass initiation of the test.

, ,. leakage.

(2.) The results of the (3.)Halogenatedhydrocarbon laboratory ' carbon sample testing shall be perfomed analysis shall show >951 after each complete or methyl iodide removaT at partial replacement of a velocity within 10% of the charcoal adsorber .

. system design. 0.05 to ,

bank or after any 0.15 mg/m3 inlet methyl . structural maintenance iodide concentration. on the system housing

>705 R.H.. and >1250F.

- - which could affect the charcoal adsorber bank .

e c. From and after the date that -

bypass leakage.  ;

one train of the Control Room High Efficiency Air Filtration (4.) Each .' train shall be System is made or found to be .. operated with the heaters incapable of supplying filtered in automatic for at least air to the control room for any 15 minutes every month. ,

reason. reactor operation or refueling operations are (5.) The test and analysis of permissible only during the 5:ecification 3.7.8.2.b.(2.) ,

succeeding 7 days. If the sia11 be performed after

. system is not made fully oper- every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system anle within 7 days, reactor operation.

( .

• Conditional Relief granted from this LC0 for the period February .

5 .1982 to startup for cycle 6.

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Amendnent No. , J[. 52 - 1588 Corrected: anuary 29, 1987 ..'

1

).- f( h4.7.0 &

. 2_7.B (Continued) (Continued l N' l l

1 shutdown shall be c. At least once every 18 months initiated and the reactor the following shall be - ,'

shall be in cold shutdown demonstrated:

within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

(- and irradiated fuel handling operations shall be teminated within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. (Fuel handl-ing operations in progress

' may be completed).

(1) Operability of heaters

d. Fans shall operate within at ratedJower.

+ lot of 1000 cfm.

3. Perfom an instrument functional test on the humidistate controlling the heaters.

..endment no. pr, Ar s7 .

158C

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1. S , 10CFR50.90 GeneralOffices 809 Boylston street Boston, Massachusetts 02199 February 25, 1987 BECo 87-036 ,

James M. Lydon b.Y. Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 Supplemental Information on Proposed Technical Specification Change to Section 4.7.B.2.a.

Control Room High Efficiency Air Filtration System

Dear Sir:

On January 19. 1987, Boston Edison Company (BECo) made application to change technical specification (TS) 4.7.B.2.a such that the existing surveillance criteria was raised from a differential pressure of 3 inches of water to 6 inches. Additionally, the change added wording which clartfled that this acceptance could be demonstrated through the use of a procedural curve based on the data - point of 6" of water at 1000 cfm.

By letter of January 29, 1987, the NRC informed us that the "3 inches" requirement was the result of a typographical error, and that "8 inches" was correct and to be used. The technical specifications were accordingly modified.

He herein request the continued review and approval of our January 19, 1987 request.

He have reviewed the proposal in view of the January 29, 1987 change, and conclude that it is now more conservative than our original proposal because the reduction from 8" to 6" of water provides an earlier action level for filter replacement than our current 4.7.B.2.a.

For your convenience we have provided an amended Supporting Information and No Significant Hazards Considerations Analyses as an attachment to this letter.

This reflects the conservative direction engendered by the change of January 29, 1987.

Very truly yours, moo 7 mon 5 PDR ADOCK 05 3

( 4 h PMK/ns O

Attachment:

Revised Supporting Information and and No Significant Hazards Conditions Analyses cc: See next page 3

/l00 I,Il

. . . . ~ -- . - ~ -

BOSTON EDISON COMPANY Februar 25 1987

.. . U.S.Nucfear*RegulatoryCommission Page 2 cc: U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station Robert M. Hallisey, Director Radiation Control Program Mass. Dept. of Pubile Health 150 Tremont Street F-7 Boston, MA 02111 l

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l Supportina Information and No Significant Hazards Conditions Analyses  !

. I The proposed change provides a tolerance.to the test success criteria for CRHEAF by allowing the use of a procedural curve relating differential pressure to 1000 cfm as bounded by TS 3.7.8.2.d. The change also reduces the ,

differential pressure criteria from 8 to 6 inches of water. l

\

The Code of Federal Regulations, 10CFR50.91 requires that at the time a  !

licensee requests an amendment, it must provide to the Commission its analysis -l using the standards in 10CFR50.92,'about the issue of no significant hazards 4 consideration. Therefore, in accordance with 10CFR50.91 and 10CFR50.92 the following analysis has been performed.

-1. Operating Pilgrim Station in accordance with the proposed amendment will i not involve a significant increase in the proDabillty or consequences of an accident previously evaluated.

The CRHEAF creates a positive pressure in the Control Room, using air from which it has filtered out radiolodines'and particulates. Currently. TS 4

4.7.8.2.a requires that at least once every 18 months a pressure drop of

{ 1ess than 8 inches of water be demonstrated across the filters at a flow J l rate of 1000 cfm. TS 3.7.B.2.d requires that CRHEAF fans operate within

1000 cfm 210%. The system is designed to provide a positive Control Room pressure if the fans can provide a flow rate of 900 to 1100 cfm and the

filters are not plugged. Vendor information indicates that filter j degradation from plugging is indicated by a differential. pressure of 3 c i inches or greater of water across each HEPA filter. Therefore, when .

j measured across two HEPA filter elements, and the rest of the CRHEAF *

components which create differential pressure', a differential of less i' than 6 inches of water demonstrates that HEPA plugging has not reached action levels. Hence, if the fans can generate 900 to 1100 cfm to satisfy

3.7.B.2.d, and has a pressure drop across the filter trains less than 6 1 inches at 1000 cfm or the calculated equivalent, sufficient flow exists to provide a positive pressure in the Control Room. Therefore, the purpose of the CRHEAF as a mitigator of the results of an accident will not be 1 tapaired by this proposed change. -Hence, allowing the differential j pressure of 6 inches of water 1000 cfm to be established at flow rates between 900 and 1100 cfm in conformance with a calculated procedural i

acceptance curve will not involve a significant increase in the probability or cansequences of an accident previously analyzed.

2. Operating Pilgrim f ation in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from'any d

accident previously evaluated.

, The purpose of CRHEAF is to mitigate the consequences of certain accidents.

by filtering out radiolodines and particulates from air which is then used to maintain a positive pressure in the Control Room. The amendment allows

~

a tolerance by allowing a calculated value, based on 6 inches of water at 1000 cfs, to be used for demonstrating that the filter train elements are 1

not plugged. The flow range for the calculated value is 900 - 1100 cfm, '

determined by existing TS 3.7.B.2.d. '

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. The change to 6 inches of water from 8 is in compliance with vendor

""- information, and is more conservative because the action level for the filters is reached earlier. The change of these criteria therefore is consistent with the design and fan capabilities of the system, and does not degrade the system's ability to perform its designed function of providing positive pressure in the Control Room with filtered air; therefore, operating Pilgrim in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Operating Pilgrim Station in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.

The proposed change does not reduce the CRHEAF's ability to perform its designed function of creating a positive pressure in the Control Room with filtered air. Hence, accident analyses which take credit for CRHEAF as a mitigator are not affected and the safety margin remains the same.

Therefore, the operation of Pilgrim in accordance with the proposed amendment to TS 4.7.B.2.a will not involve a significant reduction in the margin of safety.

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