ML20214G906

Responds to NRC Concerns Re NUREG-0737 Items on Long Term Auxiliary Feedwater Sys Evaluation,Noble Gas Effluent Monitors & Control Room Habitability Requirements,Requiring Tech Specs

ML20214G906
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/15/1987
From:	Brey H PUBLIC SERVICE CO. OF COLORADO
To:	Calvo J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.1.1, TASK-TM P-87133, TAC-54535, TAC-66365, NUDOCS 8705270213
Download: ML20214G906 (27)

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PublicService .

Company of Colorado 2420 W. 26th Avenue, Suite 100D, Denver, Colorado 80211 May 15, 1987 Fort St. Vrain Unit No. 1

.P-87133 U. S. Nuclear Regulatory Commissio. -

ATTN: Document Centrol Desk Washington, D.C. 20555 ,

Attention: Mr. Jose A. Calvo Director, Projects Directorate IV

.,. Docket No. 50-267

SUBJECT:

NUREG-0737 Items Requiring Technical Specifications

REFERENCES:

1) HRC letter, Heitner to Williams, dated 11/24/86 (G-86613)

2) PSC letter to NRC dated 1/22/87 (P-87044)

3) PSC letter, Brey to Berkow, dated

,, t 2/20/87 (P-87063)

Dear Mr. Calvo:

This letter provides Public Service Company of Colorado's (PSC) response to NRC concerns identified in Reference 1, regarding NUREG-0737 items requiring Technical Specifications.

The NRC's Safety Evaluation reviewed PSC conformance to eleven NUREG-0737 Action Items, and additional information was requested for three of these items. PSC's . response to the comments for these three items, Long Term Auxiliaiy Feedwater System Evaluation, Noble Gas Effluent Monitors, and Control Room Habitability Requirements, is provided'in the Attachment to this letter.

8705270213 870515 PDR ADOCK 05000267 P PDR _ h i ,I

<b P-87133

.Page 2-May.15, 1987-If you have any questions regarding the attached information, please 1 contact Mr._ M. H. Holmes at (303) 480-6960.

Very truly yours, Wt^ "

H. L. Brey, Manager Nuclear Licensing and Fuels Division Attachment

'*LB/SBH/ paw cc: Regional Administrator, Region IV l Attention: Mr. J. E. Gagliardo, Chief

Reactor Projects Branch

! Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain l

S a e e

ATTACHMENT TO P-87133 RESPONSE TO NUREG-0737 CONCERNS t

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Attachment to P-87133 e

This attachment addresses the NRC concerns about the Fort St. Vrain NUREG-0737 Action Items requiring Technical Specifications, as identified in NRC letter dated November 24, 1986. Each NRC comment is summarized and followed by PSC's response. The three Action Items where PSC was judged to be not in compliance are as follows:

Action Item 3. Long Term Auxiliary Feedwater System Evaluation (II.E.1.1) 3.1 NRC Comment:

The NRC disagreed with PSC's previous position that the PCRV liner cooling system is comparable to the PWR Auxiliary Feedwater System.

PSC Response:

PSC agrees that the functions of a PWR Auxiliary Feedwater System are more appropriately compared to - the provision of cooling water to the steam generators via the emergency feedwater or emergency condensate headers at FSV. These headers are used (1) to provide cooling water during normal startup and shutdown, which are the primary functions of a PWR Auxiliary Feedwater System identified in NUREG-0770 and NUREG-0800, and (2) to remove heat from the primary coolant system when the main feedwater system is not available.

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It - is important to note that.FSV does not have an emergency feedwater system or emergency condensate system. The emergency feedwater header and emergency condensate header are safety related, seismically qualified lines that provide flow to the steam generators and to the helium circulator water turbine (pelton wheel) drives. The emergency feedwater header can be supplied by three main boiler feed pumps and two firewater pumps. The emergency condensate header can be supplied by eight different pumps: two.12 1/2% condensate pumps, two 60%

condensate pumps, two auxiliary boiler feed pumps (for- the auxiliary boiler), or two firewater pumps. Only the firewater pumps are relied upon to provide safe shutdown cooling.

During normal startup and shutdown, flow is provided to the steam generators via the emergency feedwater header supplied by a main boiler feed pump, o- via the emergency condensate header supplied by anylof four condensate pumps, depending on plant conditions. Also, primary coolant circulation is provided by driving the helium circulators either with the steam turbines supplied from the auxiliary boiler (s), or with the pelton wheels. The pelton wheels are normally supplied with either emergency feedwater from the main boiler feed pumps or emergency condensate from the condensate pumps.

In the event the main feedwater system is not available, the emergency condensate header and the condensate pumps would normally be- used to remove- heat from the primary coolant system. For safe shutdown cooling, either the motor driven or diesel engine driven firewater pump would be relied upon to supply cooling water to the steam generators and helium circulator pelton wheel drives, via the emergency condensate header or the emergency feedwater header.

Although primary coolant circulation is not a function of the Auxiliary Feedwater System in a PWR, it is appropriate to consider this function at FSV because it is required, along with secondary coolant flow, for forced circulation cooling.

3.2 NRC Comment:

PSC should provide Technical Specifications to ensure forced circulation emergency cooling capability.

PSC Response:

PSC considers that the current FSV Technical Specifications provide adequate assurance of forced circulation emergency cooling capability. Operability of the systems or subsystems identified in the response to comment 3.1 above is assured by the FSV Technical Specifications as follows:

1. The emergency condensate and emergency feedwater headers are required to be operable per LCO 4.3.4.

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2. The capability to provide flow through these headers is-assured by the following specifications:

LCO 4.3.2 ensures operability of the boiler feed pumps.

LCO 4.2.6 and SR 5.2.10 ensure operability of the firewater pumps and pipinn.

LCO 4.2.5 ensures operability of the circulating water makeup system and LC0 4.3.5 ensures operability of the storage ponds. These features provide a water supply for the firewater pumps.

LC0 4.2.19 ensures operability of the. emergency water booster pumps that are required to boost the low pressure firewater to provide motive power for the helium circulator water turbines. (Depending on the operating history of the core and the amount of cooling required, these pumps may also be used to operate the helium circulator water turbines with condensate.)

LCO 4.2.3 ensures operability of the turbine water removal pumps that are used to remove water from the helium circulator water turbines.

3. The steam generator heat transfer surfaces in the economizer-evaporator-superheater and reheater sections

, are required to be operable per LCO 4.3.1.

4. The capability of-the helium circulators to provide forced circulation'via water turbine drive is assured by the following specifications:

LC0 4.2.2 ensures operability of_ the helium-circulator water turbine drives, bearing water, and

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bearing water accumulators.

SR 5.2.7 demonstrates operation of the circulator water turbine drive on condensate, feedwater, and boosted condensate (simulated firewater).

SR 5.2.8 demonstrates operability of the circulator bearing water pumps and makeup pumps.

SR 5.2.9 demonstrates operability of the bearing water accumulators. a Neither the auxiliary boiler feed pumps nor the condensate pumps are explicitly addressed by the Technical Specifications. The auxiliary boiler feed pumps are a design feature of FSV that are not relied upon for any accident. PSC considers that Technical Specifications are not required for i these pumps. The condensate pumps are operating during normal i

plant operating conditions, and pump inoperability would be readily detected. PSC believes that explicit Technical Specifications for these pumps are not required because of l

their normally operating condition. In addition, condensate l

pump capability is demonstrated during the performance of SR l

5.2.7, as discussed above.

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Action Item 4. Noble Gas Effluent Monitors (II.F.1.1) 4.1 NRC Comment:

I ELCO 8.1.1.g.3 does not identify mode applicability.

PSC' Response:

ELCO 8.1.1.g.3 provides acceptable sampling requirements for gaseous effluent releases from the reactor building ventilation system ~in the event the noble gas monitoring instrumentation becomes inoperable. These requirements apply at all times during a' gaseous effluent release, independent of the plant operating mode. ELCO 8.1.1.g.1 identifies tne operability requirement for the gaseous effluent monitors and, states the applicability as during power operation and/or a release from the gaseous waste holdup system. PSC considers that the specification of grab samples or auxiliary monitoring equipment during gaseous effluent releases, as provided in ELCO 8.1.1.g.3, assures adequate monitoring and is consistent with the rest of the FSV effluent monitoring Technical Specifications. PSC proposes that the specification be accepted without the addition of a made applicability statement.

4.2 NRC= Comment:

ELCO 8.1.1.g.8 currently requires failed instrumentation to be returned to operable status within thirty days and reported in the next Semi-Annual Radioactive Effluent Release Report. This does not comply with the 7 day return to service or the 14 day Special Report as. required by the Generic Letter.

PSC Responsee PSC agrees to propose a change to this ELCO to require a Special Report within 14 days if failed monitoring instrumentation is not returned to operable status within 7 1 days. This is.in lieu of a report in the Semi-Acnual Radioactive Effluent Release Report. This proposed. change will be provided by October 1, 1987.

4.3 NRC Comment:

The daily channel checks and quarterly functional tests required by ESR 8.1.1 do not comply with Generic Letter requirements of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and at least once per 31 days, respectively.

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a PSC Response:

PSC considers that' the daily channel checks and quarterly functional tests required by ESR 8.1.1 _for gaseous effluent monitors are acceptable. These frequencies are consistent with those required by the FSV Technical Specifications for- similar instrumentation in other systems and with the frequencies retained in the TSUP. The retention of these frequencies was agreed to by the NRC during the development of the first TSUP draft, and was recently confirmed during meetings held in October 1986.

PSC does not believe that the increased frequencies. for surveillances provided in the Generic Letter would result in a substantial increase 'in the overall protection of the public health and safety.

4.4 NRC Comment:

Existing Technical Specifications ELCO 8.1.1g and ESR 8.1.1 are not in standard format.

pSC Response:

PSC considers that the format of the existing FSV Radiological and Environmental Technical Specifications is acceptable.

, Consistent with agreements reached with the NRC at the beginning of the TSUP, PSC proposes to not re-format the ELCOs and ESRs to agree with the Standard Technical Specifications at

, this time.

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. PSC does not believe that reformatting the ELCOs and ESRs would result in a substantial increase in the overall protection of the public health and safety.

Action Item 11. Control Room Habitability Requirements (III D.3.4):

As indicated by the NRC in Reference 1, this item is being reviewed as a part-of the Technical Specification Upgrade Program (TSUP).

Final resolution of the concerns identified in Reference 1 will be achieved in conjunction with the resolution of other TSUP issues.

The concerns identified in Reference 1 are addressed as follows:

11.1 NRC Comment:

The Action statement for the Chlorine Detection and Alarm LCO (Action a of TSUP LCO 3.3.2.6) is not in compliance with the guidelines.

PSC Response: ,

PSC considers that the Action Statement provided with TSUP LCO 3.3.2.6 is acceptable for meeting the intent of ensuring control room habitability.

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During TSUP discussions with the NRC in July 1985, it was agreed that switching to the minimum makeup mode is not the most desirable action to take in the event of a chlorine incident. The intake for the minimum makeup mode is lower than the normal intake and, since chlorine is a dense gas, use of the minimum makeup intake increases the likelihood of introducing chlorine into the ventilation system. The emergency ventilation makeup filter is rated for chemical releases. Notwithstanding this rating, PSC considers that securing and monitcring any potential sources of chlorine in the event of an inoper.51e chlorine detector is a positive action that will ensure control room habitability.

11.2 NRC Comment:

The surveillance frequency for the Chlorine Detection and Alarm channel check (TSUP SR 4.3.2.6.a) is not in compliance with the guidelines.

PSC Response:

PSC proposes that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> channel check identified in SR 4.3.2.6.a be retained.

One of PSC's objectives in the TSUP is to obtain consistency with applicable guidance and also between comparable systems within the -Technical Specifications. Early in the TSUP

-development, PSC and the NRC agreed that the daily channel checks required by _the existing FSV Technical Specifications were acceptable, even though STS guidance suggested a once per shift channel check. Currently, TSUP requires channel checks once per shift for core reactivity and primary coolant system parameters. Other parameters that are used in accident mitigation or other PPS activities are checked on a daily basis.

PSC agrees with the importance of a chlorine detection system to assure control room habitability. In addition, the areas between the rather remote chlorine storage area and the ventilation intake are areas of frequent activity and regular patrol. It is likely that any chlorine leak would be detected and isolated promptly as a result of this activity, in addition to the local detection system.

PSC considers that a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> channel check is appropriate for the local chlorine detection and alarm system, when considered in the perspective of the remainder of TSUP instrument surveillances previously agreed to by the NRC.

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11.3 NRC Comment:

The Action Statement for the control room emergency ventilation system filter (TSUP Action 3.7.9.c) is not in compliance with the guidance.

PSC Response:

This concern was discussed with the NRC during TSUP meetings in October 1986. As indicated in PSC's documentation of these meetings (P-87063, Attachment 2, NRC Comment 3.7.9-2), with an inoperable filter, an option acknowledged by FSAR Section 7.4.1 is to shift to the recirculation mode until the filter is returned to OPERABLE status, although this option usually leads to a gradual buildup of temperature within the control room (FSAR 7.4.1 states 13 degrees F over 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> but within limits for equipment qualification). Further, backup breathing air sources, including a breathing air system, are available if required.

In the October 1986 meetings, it was agreed by NRC and PSC that 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is an acceptable ACTION time for an inoperable control room emergency makeup ventilation filter and that the backup breattiing air system should be mentioned in the BASIS. The ,

ACTION c. and the BASIS were changed as shown in the attached markup of Specification 3/4.7.9, attached to this discussion.

11.4 NRC Comment:

The Action Statement for the control room emergency ventilation system in shutdown and refueling is not in compliance with the guidance.

PSC Response:

This concern was also discussed with the NRC during TSUP meetings in October 1986. As indicated in PSC's documentation of those meetings (P-87063, Attachment 2, NRC Comment 3.7.9-3),

due to the fact that FSV does not have complete dual control -

l room ventilation systems, some provisions must be made for an (

appropriate time to repair or perform maintenance on one-of-a-kind components. The PSC proposed technical specification '

allows 7 days to restore control room emergency ventilation to OPERABLE status.

Additionally, the amount and level of overall radioactive sources at FSV are several orders of magnitude lower than comparable LWRs. With the reactor shutdown or in refueling, potential sources of radioactivity are so small that the risk is also correspondingly small. Backop air sources are available to operators such that control room habitability is not threatened at any time. PSC believes 7 days is an appropriate ACTION time while shutdown, due to backup breathing air capability and due to the overall risk reduction associated with a lower likelihood of events leading to uninhabitable

, control room spaces.

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At the October 1986 meetings, it was agreed by NRC and PSC that a 7 day Action time is appropriate and acceptable.

11.5 NRC Comment:

FSV does not have a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency check of the control room air temperature or 31 day frequency of a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> flow check.

PSC Response:

TSUP SR 4.3.3 requires a daily check of control room temperature. As discussed in comment 11.2 above, PSC believes that a daily check is appropriate and proposes that this be (

accepted.

As a result of the TSUP meetings in October 1986, PSC agreed to add a surveillance requirement to operate the emergency ventilation system for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, once per 31 days as shown in i

Attachment 1 to P-87063. This is consistent with STS and was agreed to by the NRC.

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15-f 11.6 NRC Commen': t Testing . of the emergency ventilation system filter is not in compliance with th'e guidelines in the following ways:

(1) specifies a one sided test flow versus a range (450 ACFM versus- 450 ACFM plus or minus 10*.'); (2) lacks a penetration test after partial or complete charcoal adsorber replacement;(3) lacks a heater dissipation test; (4) lacks a test of automatic switchover into the recirculation mode; (5) specifies penetration of less than 5% at 30 degrees C, 95% RH rather than 3% at 30 degrees C, 95% RH (see ANSI N509-1980).

PSC Response:

1. PSC agrees to revise the one sided minimum flow requirement to a required flow range. As with the reactor building ventilation filter (P-87063, Attachment 2, NRC Comment 3.6.5.2 #11), PSC proposes to identify a minimum flow rate consistent with the design and a maximum flow rate consistent with past performance and filter design efficiency. PSC will provide this information with the resolution for other open items in the TSUP, as discussed in P-87063.

2. A penetration test after partial or complete charcoal adsorber replacement is required by TSUP SR 4.7.9.d in the Technical Specification markup provided as Attachment I to P-87063.

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3. A heater dissipation test is not required because the FSV control room emergency ventilation system does not include electrical heaters. The dry climate at FSV is such that these heaters are not required.

4. As part of the TSUP, PSC agrees to include a surveillance to demonstrate automatic switchover into the recirculation mode, as shown in the markup of SR 4.7.9, attached to this discussion. This test will be performed once per refueling, not to exceed 18 months, consistent with the STS. Also, high radiation in the reactor building exhaust will -be simulated as this is the only signal that automatically initiates this action.

5. PSC agrees to revise the iodine penetration limit to less than 3% at 30 degrees C, 95% RH, as shown in the markup of

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SR 4.7.9 attached to this discussion.

11.7 NRC Comment:

The existing- requirement for reactor shutdown after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with inoperable d-mpers has been deleted without justification.

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0 17 PSC Response:

PSC deleted the requirement to shutdown the reactor after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with inoperable dampers because there is no comparable requirement in the STS, which PSC is using for TSUP guidance.

Consistent with STS, TSUP SR 4.7.6.3.c demonstrates proper damper action on simulated Halon test signal. This operability test of the dampers, combined with the actuation test-on simulated hign radiation in the reactor building exhaust, discussed in Response 11.6.4 above, assures control room ventilation system damper operability in a manner consistent with STS requirements. Manual isolation capability will also be demonstrated in SR 4.7.9, as the FSV response to a chlorine (toxic gas) incident is to manually actuate the emergency ventilation system.

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4 NOTE: THIS IS A REVISION TO THE MARKUP 0F SPECIFICATION 3/4.7.9 PROVIDED IN P-87063.

THE SOURCE OF EACH CHANGE IS ,

IDENTIFIED IN THE MARGIN.

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JL4,7.9 CONTROL ROOM EMERGENCY VENTILATION SYSTEM DRAFT NOV 3 0158:

LI.MITING CONDITICN FOR OPERATION

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3.7.9 The control room emergency ventilation system shall be OPERABLE in the rectreulation made with minimum mate';p

a. Both the control sne control room supply fan (C-7504X) OPEU8LE, a i

b. The control room (F-7502) OPEM8LE.

emergency makeup ventilation filter APPLICA8ILITY: At all times ACTION:

POWER, LCW PCWER and STARTUP

a. With one with ecual control room positive pressure greaterof than or to 0.05 inches water gauge, restore the inocerable fan to CPEUSLE status within 7 days or se in SHUTCCWN withIn the aext 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

b. With one of the above ecutred fans inoperable, and control room positive cressure less than 0.05 taches water gauge, status next within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in SHUTOCWN eithin the

c. With the control g_,yg status witnin 7 room emergency makeup venttiation m ter,inooeraore restore ene m ter to cPEu8tE

( next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. \ n,;- or be in SHuTCCWN within ene ee

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With the above ventilation systemrequirements not met, for the control room emergency status within restore tne system to CPERA8LE l CORE ALTERATICNS,7 days or suscard control rod movements all operations involvi l

osftfve reacttvity enanges, or resulting in FUEL. movement of IRRADIATED i

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etere.ent s:. I Page 3/4 7 57 l DRAFT 331tVEtt.l.#lCE RE00!RW3 0M 4.7.9 The control room m comonstrated OPERA 8LE:einergency vem:+1 att en-- systen shall be

[ At least once per 18 months, maintenance housings, or on the HEPA fficer ororafter any structural following paintin9e fir #, charcoal adsorcer release in any venti 14 tion Zone or a chemical system by: communicating with the

1. Verifying that in-place penetratton the ventilation system satisfies the and bypass leakage testing acceptance criteria of less than 0.054 and uses the test procedure C.S.a. C.S.c, guidan:o in Regulatory Positions and C.S.d of Regulatory Guice 1.52, Revision 2, March 1978, and the system flow greater than or equal to 450 ACFM. rate is 2.

Veri fying within 31 days after removal, that a

- laboratory analysts of a representative carbon sample of Regulatory Guide 1.52,obtained Revision 2, in accordanc meets the criteria of Regulatory Position March 1978, C.6.a of Regulatory ethyl Guide 1.52, 7evt ston 2. March 1978, for a degrees C, iodine 95". RH. geneter.t on of less than Jal' at 30 3*4 g ,,a I.

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at the essure Ig  %

/f1tersan charcoal csorbers s less tha 6 op across he HEP d *g S 4.i.Sd.1 f or water in es

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• nile than or e one ualting es thej M n ystem Af** at a , ow r e of 3./ Verifying a system flow este of greater than or equal to 450 ACFM durfeg system coeration accordance witn ANSI N510-1975. wnen tested in

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e ver i fy that the charcoal sattsfies tne in place penetration and adsorcer bank testing acceptance accordance with ANSI criteria of less thanbypass 0.054leakagein N510-1975 for hydrocaroon re fef gerant test gas while a halogenated system at a flow rate operating the ACFM. of greater than or equal to 450

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g C* [ After every 6 months e coeration, whichever is scorer,or rzo hours of charcoal adsorb days after removal, that a by verifying within 31 laboratory analysts of a ,

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reoresentative caroon samole cotained in accordance with Regulatory position C.6.b of Regulatory Guide 1.52, 0- Revision 2 March 1978, meets the laboratory criteria testing 1.52, Revision of Regulatory Position C.6.a of Regulatory Guide i 2. March 1973 for a metnyl todice penetration of less tnan,ST at 30 degrees C, 955 RH.

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d. At least once per 18 months by:

1. Verifying that the pressure drop across the HEPA filters and charcoal adsorbers is less than 6 inches of water while operating the system at a flow rate of greater than or equal to 450 ACFM.

2. Verifying that on a simulated signal indicating high radiation in the reactor building ventilation exhaust, {

the system automatically switches into the recirculation made with minimum makeup. >

3. Verifying that the control room emergency ventilation system maintains the control room at a positive pressure in the following configurations:

a) With both the emergency filter fan and the control room supply fan OPERABLE, maintain at least 0.125 inches water gauge pressure.

b) With either the emergency filter fan or the

, control room supply fan inoperable, maintain at least 0.05 inches water gauge pressure.

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. Pago 3/4 7 59 DRAFT SA$!5 FOR 5pfCIFICAf t0N t.C0 3.7.9 / SR 4.7.g _

30 g The control room ventflation system filtered,F5AR makeus. recirculated Table 7.1-1 air at a positive pressure wit pressure is assumed in the spect ff es that 4'511ght pasf ttve analysts of .

environment. an known as tne hi-radiation mode orThe recirculation mode Isalates tne normal the minimum makeup moce supply and return fans tomakeup and uses the normal control room, handling units. recirculate air through the air and passed through a pref t1ter, a HighParticulate EfficiencyM I Air (HEPA) filter,  !

that control room and a charcoal adsorber thereby ensuring personnel atrborne radiation exposures during and following all credible accident conditions will not exceed 10 CFR 20 limits.f gg The control room pressure can be maintained at a positive pressure old0.125 inches water gauge in the rectreulation mode with the suoply fan operating. emergency makeup, with both the e inoperacle, control roomIfpressureeither ofcanthese fans becomes positive, by snutting off the control roomstgg;;g maintained gg g gg closing the toilet z fan and exhaust damper, in which case a positive g t- pressure accuracy ofA0.05 inches water gauge 1s provided. The channel

$ for measuring control room pressure is 2*. or less of the instrument range wnfen is 2 QL 3wt water gauge may be assumed #:e 'nches. Thus, 0.04 inches total channel accuracy.

Specifying as tne a control room pressure ofA0.05 inches water gauge surveillance requiremert arsures positive pressur,e in the control room even fn the eveat of a failure of onetheof  ;

two required the FSAR fans in the emergency ventilation Ifne up. Thus, assumations are verifted through surveillances. required 11). (FSAR Section 11.2.2 and Appendix C. Cetterton The assumptfons relattve to cont?nl room positive pressure assume tne access door to the control room is closed i However, due to plant security reasons, tne access door may as 7

opened In the eventand personnel of an access controlled by a full-time guard.

emergency, tne coor will be closed as l

required by plant ocerating procacures to ensure that 6 positive control room pressure f s .Paintained.

J ' A 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ACTION time associated with an inoperable control room emergency makeup ventilation filter (F-7502) is acceptable based on the fact that it is in service only when the control room O.c6kr ventilation system is in the minimum makeup mode. During

$ normal control room ventilation, air is drawn from outside and

( d r bypasses the filter. In the event that the fficer (F-7502) 4 c3 is inoperable and the control room vent 11atien system is in the i' minimum makeup mode, a backup source of air is provided to operators, if required, via the breathing air system.

l

+ ne n: n.

k

[

MV30 %

l Ensuring that an excessive pressure drop does not ,xigg ,

the emergency adsereers are makeup filter demonstrates that the filters 3"d can be maintained notpositive.

clogged and that the cgntrol reo, '

are adequate to The scociff ed sdriett ensure system OPERA 8ILITY unce)r ng,

[g' abnormal conditions. nomal an slight positive crossure Normal makeuo requirement 5 to matatnin a in the control calculated to ee 450 ACFM. That fs, 450 Accl.rCCS is have been enough to ensure snac a positive reading on the control room pressure gauge exceeds tne maximum caannel accuracy.

The addition of these surveillance requirements is in response to NUREG-0737. Item III 0.3.4.

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