ML18152B398
| ML18152B398 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/28/1999 |
| From: | Christian D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 99-339, GL-99-02, NUDOCS 9908020081 | |
| Download: ML18152B398 (5) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
July 28, 1999.
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 60-DAY RESPONSE TO GENERIC LETTER 99-02 Serial No.99-339 SPS/CGL-SLW RO' Docket Nos.
50-280 50-281 License Nos.
DPR-32 DPR-37 LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL On June 3, 1999, the NRG issued Generic Letter (GL) 99-02, entitled "Laboratory Testing of Nuclear-Grade Activated Charcoal".
The GL documents the NRC's determination that testing of new and used charcoal should be performed using ASTM D3803-1989. Consistent with that determination, the GL requires testing of new and used charcoal to ASTM D3803-1989 starting 60 days after issuance of the GL. In addition, the GL requests a 180-day response committing to test charcoal using ASTM D3803-1989 and, if necessary, submittal of a Technical Specification (TS) amendment request reflecting the ASTM D3803-1989 protocol. A 60-day response is requested from those licensees that choose to not satisfy the required actions of the GL.
Although we plan to satisfy the requirements of GL 99-02 for Surry, our planned method of interim testing will include minor qualification of the ASTM D3803-1989 requirements for methyl iodide due to the atypical design features in Surry's engineered safety feature (ESF) ventilation systems. In addition, we plan to perform a separate test to confirm elemental iodine removal capabilities.
Therefore, this 60-day response is being provided to outline our interim testing plans and present the necessary qualification, as discussed in the attachment.
Our current TS-required testing is performed using ASTM D3803-1979. The GL states that the NRC will exercise enforcement discretion to eliminate unnecessary testing of charcoal samples to.both ASTM D3803-1989 and the current TS testing during the interim and until approval of a TS amendment. Please be advised that, because our design necessitates minor qualification of the ASTM D3803-1989 requirements, we plan to test to both ASTM D3803-1979 and ASTM D3803-1989 until we receive feedback from the NRC indicating that we may exercise the enforcement discretion granted by the GL.
Our 180-day response to GL 99-02 tor Surry will include a TS amendment request tor charcoal testing that incorporates ASTM D3803-1989 requirements for testing methyl iodide removal efficiency with minor qualification relative to higher face velocity, as well as elemental iodine removal efficiency testing in accordance with ASTM D3803-1979.
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In addition, Surry is participating in an ongoing source term reduction pilot program.
Therefore,* our TS amendment request may also incorporate source term reduction results as they may apply to Auxiliary Ventilation and Control Room Filtration systems.
If you have any further questions or require additional information, please contact us.
Very truly yours, Dave A. Christian Vice President - Nuclear Operations Attachment Commitments contained in this correspondence:
1. ESF charcoal absorbers will be tested for methyl iodide removal efficiency in accordance with ASTM D3803-1989 as discussed and qualified herein for samples taken beginning August 2, 1999.
- 2. ESF charcoal absorbers will be tested for elemental iodine removal efficiency in accordance with ASTM D3803-1979 as discussed and qualified herein for samples taken beginning August 2, 1999.
3; Because our design necessitates minor qualification of the ASTM D3803-1989 requirements, we plan to test to both ASTM D3803-1979 and ASTM D3803-1989 until we receive feedback from the NRC indicating that we may exercise the enforcement discretion granted by the GL.
- 4. A TS amendment request will be submitted by November 30, 1999.
cc:
U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Resident Inspector Surry Power Station
ATTACHMENT TO LETTER SERIAL NO.99-339 60-DAY RESPONSE TO GENERIC LETTER 99-02 LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL INTRODUCTION Surry Power Station intends to comply with the requirements of GL 99-02 in that, for samples taken beginning on August 2, 1999, interim testing of new and used charcoal for ESF ventilation systems will include testing methyl iodide removal efficiency
.consistent with the methodology of ASTM D3803-1989 with minor qualification. Our method of interim testing will include minor qualification of the ASTM D3803-1989 requirements due to the atypical design of Surry's engineered safety feature (ESF) ventilation systems. Specifically, the face velocity specified in ASTM D3803-1989 is approximately 12 M/min. The Surry Auxiliary Ventilation Exhaust Filter Trains have a nominal face velocity of 24.4 M/min and the Control Room Air Filtration System has a nominal face velocity of 18.3 M/min.
Historically, our charcoal testing has been performed at 24.4 M/min to match the in-service conditions of the Auxiliary Ventilation System and to envelop the in-service conditions of the Control Room Filtration System.
Although testing in verbatim compliance with ASTM D3803-1989 could be performed, use of a test flow not matching/not enveloping the in-service conditions would provide non-representative, as well as non-conservative, results for Surry. In addition to the methyl iodide testing in accordance with ASTM D3803-1989, testing for elemental iodine will be performed in accordance with ASTM D3803-1979. Testing for elemental iodine is performed to ASTM D3803-1979 because ASTM D3803-1989 does not specify a methodology to test using elemental (inorganic) iodine as the challenge medium.
Testing is performed for new charcoal for both the Auxiliary Ventilation and Control Room Filtration Systems. Used charcoal is tested for continued use in the Auxiliary Ventilation System. Charcoal in the Control Room Filtration System is replaced with new charcoal rather than tested for continued use. Charcoal is replaced in the Control Room Filtration System because the charcoal bed design does not include a provision for taking in-place charcoal samples.
For samples taken beginning on August 2, 1999, interim laboratory testing for new and used charcoal will be conducted in accordance with the parameters and acceptance criteria presented in the following discussion.
INTERIM LABORATORY TESTING OF CHARCOAL As stated in Generic Letter 99-02, laboratory testing is to demonstrate that the charcoal is capable of performing at a level greater than that assumed in the design-basis.
accident analysis and associated NRG safety evaluation. The following are the accident analysis requirements for the Surry Auxiliary Ventilation and Control Room Filtration Systems.
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Accident Analysis Minimum Required Test ESF System Efficiency Applying Safety Efficiency with 1 % TS Assumption Factor of 2 Allowable Bypass Leakage Control Room 70% Organic 85% Organic 86% Organic Filtration 90% Inorganic 95% Inorganic 96% Inorganic Auxiliary 70% Organic 85% Organic 86% Organic Ventilation 90% Inorganic 95% Inorganic 96% Inorganic The minimum test efficiency noted above is the value that new and used charcoal is required to meet to comply with the proposed TS criteria in the GL. The Surry accident analysis has a higher efficiency assumption for inorganic iodine than organic iodide. As part of our interim testing, we are planning to perform additional testing for elemental iodine in accordance with ASTM D3803-1979 to validate efficiencies against accident assumptions.
Methyl (Organic) Iodide Testing Parameters for Testing In Accordance With ASTM D3803-1989 With Qualification Noted Temperature of 30 degrees C.
Relative humidity of 95%.
Consistent with design, face velocity of 24.4 M/min (ASTM D3803-1989 requires 12.2 M/min).
Acceptance criteria of~ 86% efficiency.
Equilibration, challenge, and elution consistent with ASTM D3803-1989.
Elemental (Inorganic) Iodine Testing Parameters for Testing In Accordance With ASTM D3803-1979 With Qualification Noted Temperature of 30 degrees C.
Relative humidity of 95%.
Consistent with design, face velocity of 24.4 M/min (ASTM D3803-1979 requires 12.2 M/min).
Acceptance criteria of ~96% efficiency.
Equilibrat_ion, challenge, and elution consistent with ASTM D3803-1979.
The minor qualification of the requirements of ASTM D3803-1989, noted above, is necessary in view of the atypical design of Surry's engineered safety feature (ESF) ventilation systems having a higher face velocity than specified in ASTM D3803-1989.
Testing of the charcoal removal efficiency for elemental (inorganic) iodine will also be performed due to the higher efficiency assumptions in the accident analysis for inorganic iodine. Surry is currently purchasing the highest quality charcoal available.
The only alternative to the minor qualification of the ASTM D3803-1989 requirements Page 2 of 3
wpuld be major modification of the ventilation systems, which is not considered feasible due*to spate limitations. The areas in which both the Auxiliary Ventilation Exhaust Filter Trains and the Control Room Air Filtration System are located do not allow the installation of additional or larger charcoal beds.
We are confident that the approach outlined herein for interim testing satisfies the requirements of GL 99-02, is appropriate for Surry's ventilation system design, and will demonstrate charcoal performance consistent with Surry's licensing basis and accident analyses assumptions.
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