ML17313A336

Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors

ML17313A336
Person / Time
Site:	Palo Verde
Issue date:	03/27/1998
From:	Ide W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR9581 102-04101-WEI-S, 102-4101-WEI-S, 63FR9581-00022, 63FR9581-22, NUDOCS 9804140135
Download: ML17313A336 (10)

Text

CATEGORY 2 REGULA Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9804140135 DOC.DATE: 98/03/27 NOTARIZED: NO DOCKET ¹ FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION IDE,W.E. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP . NAME RECIPIENT AFFILIATION Rules &. Directives Review Branch (Post 920323)

SUBJECT:

Comment opposing proposed GL re "Lab Testing on Nuclear-Grade Activated Charcoal." Believes that proposed 60 day implementation schedule would severely challenge resources of limited number of cpxalified vendors.

DISTRIBUTION CODE: DS09D TITLE: SECY/DSB Dist: Public COPIES RECEIVED:LTR Comment on Proposeee 3 Rule J(PR)-Misc ENCL SIZE:

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8 NOTES: STANDARDIZED PLANT 05000528 Standardized plant. 05000529 Q Standardized plant. 05000530 R

RECIPIENT COPIES RECIPIENT. COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL. I CE 1 1 1 NMSS/IMOB T8F5 1 1 OGC DR 15-B-18 1 1 RES DIR 1 1 RES/DRA/DEPY 1 1 RES/DST 1 ~

1 EXTERNAL: NRC PDR 0

WASTETH NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEZVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES 'REQUIRED: LTTR 7 ENCL 7

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ScQ g(Q William E. Ide Mail Station 7605 Palo Verde Nuclear

,, , Vice President Nuclear TEL 602/3934116

'.'AX'602/3934077 P.O. Box 52034 Phoenix, AZ 65072-2034 Generating Station Engineering ~

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M g 1 102-04101-WEI/SAB/RMW/RKB March 27, 1998 Chief, Rules and Directives Branch Division of Administrative Services f~

U. S. Nuclear Regulatory Commission we Mail Stop T6-D69 Washington, DC 20555-0001

Dear Sirs:

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Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Comments on Proposed Generic Letter Regarding "Laboratory Testing of Nuclear-Grade Activated Charcoal."

Arizona Public Service Company (APS) appreciates the opportunity to comment on the proposed Generic Letter regarding "Laboratory Testing of Nuclear-Grade Activated Charcoal." APS acknowledges that clear regulatory guidance is needed by the nuclear industry on this issue. However, APS has several concerns with the proposed Generic Letter approach. First, APS believes that the proposed 60-day implementation schedule does not provide licensees with sufficient time to perform tests and submit results to the NRC. In addition, the proposed 60-day implementation schedule would severely challenge the resources of the limited number of vendors currently qualified to perform the proposed tests and provide replacement charcoal as necessary. An implementation schedule of at least 180 days, commensurate with the safety significance of this issue, is recommended. Second, APS believes that it is inappropriate to use the compliance exception to 10 CFR 50.109, the backfit rule, to impose new requirements. In accordance with 10 CFR 50.109(a)(3), the NRC staff must demonstrate a significant safety improvement relative to the costs to be incurred by licensees before imposing new requirements.

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Chief, Rules and Directives Branch Division of Administrative Services U. S. Nuclear Regulatory Commission Comments on Proposed Generic Letter Regarding "Laboratory Testing of Nuclear-Grade Activated Charcoal."

Page 2 While APS believes there is merit in addressing this matter, APS believes a more comprehensive effort should take place between the industry and NRC staff prior to the issuance of any finalized generic communication. Enclosure 1 provides APS'etailed comments. In addition to the comments provided in the Enclosure, APS endorses the comments provided by the Nuclear Energy Institute (NEI) regarding the proposed Generic Letter.

Please contact Mr. Scott Bauer at (602) 393-5978 if you have any questions. This letter does not make any commitments to the NRC.

Sincerely, WEI/SAB/RMW/RKB/rlh cc: E. W. Merschoff M. B. Fields K. E. Perkins J. H. Moorman

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ENCLOSURE 1 Comments on Proposed Generic Letter:

"Laboratory Testing of Nuclear-Grade Activated Charcoal."

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APS endorses the comments provided by the Nuclear Energy Institute (NEI) regarding the proposed Generic Letter on "Laboratory Testing of Nuclear-Grade Activated Charcoal ~" In addition, APS provides the following detailed comments:

The third bullet of paragraph 9 of "Discussion" requires licensees to submit an amendment request to their technical specifications. Implied in this bullet is that licensees are required to amend their technical specifications to reference ASTM D3803-1989. Clarification should be provided to state that this amendment request may propose an alternative test protocol.

Paragraph 7 of "Discussion" states that the staff plans to make conforming changes to Regulatory Guide (RG) 1.52. The RG should be revised in parallel with the effort to transition to the new code in order to ensure consistency.

Paragraph 7 of "Discussion" allows systems with humidity control to be tested at 70% relative humidity (RH) Systems that do not have explicit humidity control, but

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which have been designed to ensure that RH remains less than or equal to 70%,

should also be permitted to test at 70% RH, and the appropriate safety factor applied.

Paragraph 7 of "Discussion" states that the staff has previously approved reductions in the safety factor for plants adopting ASTM D3803-1989 on a case-by-case basis.

Generic guidance should be provided that outlines the NRC-accepted criteria used to allow reductions in the safety factor such that facilities may implement the reduced safety factor, if appropriate, without having to obtain prior NRC approval.

5. The last paragraph of "Requested Information" states that "the independent laboratory should not be engaged in the measurement of iodine penetration of charcoal as a business either for TS compliance purposes or for the sale and/or production of activated charcoal for nuclear power plant applications." While it is obvious that this requirement is to prevent a conflict of interest, it also increases the burden of finding an acceptable independent lab that is capable of performing the required tests and providing adequate quality assurance. The laboratories that currently perform testing to the ASTM standard should not be excluded from performing the qualification testing for new, proposed, test protocols. These

'laboratories have extensive nuclear-grade charcoal testing experience, established quality assurance programs and the equipment and facilities to safely perform this testing. In addition, the extensive experience that these laboratories have gained by performing testing to the ASTM standard provides added assurance that the proposed test protocol will be evaluated accurately and objectively.

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