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Application for Amends to Licenses NPF-4 & NPF-7,clarifying Requirements for Testing Charcoal Adsorbent in Waste Gas Charcoal Filter Sys,Cr Emergency Habitability Sys & Safeguard Area Ventilation Sys
	ML20101F789
Person / Time
Site:	North Anna
Issue date:	03/21/1996
From:	Ohanlon J; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20101F790	List: ML20101F789; ML20101F797;
References
	96-145, NUDOCS 9603260193
	Download: ML20101F789 (13)
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. VIHOINIA ELECTHIC ANu PownH CoMI*ANY l RICIIMOND, VIRGINIA 202 61 March 21, 1996 Document Control Desk Serial No.96-145 U. S. Nuclear Regulatory Commission NLOS/ETS: R0 Washington, D. C. 20005 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

1 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATIONS CHANGES I CHARCOAL FILTER TESTING CLARIFICATION Pursuant to 10 CFR 50.90, Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Nos. NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2.

The proposed changes clarify the requirements for testing charcoal adsorbent in the the Waste Gas Charcoal Filter System, the Control Room Emergency Habitability System, and the Safeguards Area Ventilation System. The proposed changes to the Technical Specifications for Units 1 and 2 are provided in Attachments 2 and 3, respectively.

The interpretation of these requirements and the related application of referenced industry test standards has been the subject of several recent NRC telephone conference calls regarding the charcoal adsorbent in the ventilation systems. Although no safety or technical concems have been identified in these discussions, questions have been raised concerning interpretation of requirements and the consistency by which referenced industry standards are applied.

We continue to believe that North Anna Power Station is in compliance with its Technical Specifications for testing charcoal adsorbents. However, to preclude subjective interpretations and future misinterpretations of the testing standards, ,

Technical Specifications changes are being proposed for North Anna Units 1 and 2 that I explicitly specify the current test method or standard currently being used to test new and used charcoal adsorbent.

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These changes have been reviewed and approved by the Station Nuclear Safety and i Operating Committee and the Management Safety Review Committee. It has been l determined that the proposed changes do not involve an unreviewed safety question as defined by 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. A discussion of the proposed changes and the basis for our no significant hazards considerations are included in Attachment 1.

i To facilitate the NRC's review of these changes, we are available to meet with the NRC staff at their earliest convenience. Should you have any questions or require additional >

information, please contact us.

Very truly yours, l

James P. O'Hanlon Senior Vice President - Nuclear Attachments i cc: United States Nuclear Regulatory Commission Regional Administrator Region 11 101 Marietta Street, N. W Suite 2900 Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power Station Commissioner Bureau of Radiological Health Room 104A 1500 East Main Street Richmond, Va. 23219 l

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COMMONWEALTH OF VIRGINIA )

) 4 COUNTY OF HENRICO ) !

The foregoing document was acknowledged before me, in and for the County and j Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President -

Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute l i and file the foregoing document in behalf of that Company, and the statements in the l document are true to the best of his knowledge and beli f.

Acknowledged before me this [/fhay of d#r h .1996.

My Commission Expires: ( 3/ .19_If.

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Attachment 1 Discussion of Changes and Significant Hazard Consideration Determination Proposed Technical Specifications Changes i for North Anna Units 1 and 2 l

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l Discussion of Change l Introduction Currently, North Anna tests the charcoal adsorbent in the Waste Gas Charcoal Filter System, the Control Room Emergency Habitability System, and the Safeguards Area Ventilation System in accordance with ASTM D3803-1979' (ASTM D3803 Method B is

, the same test as RDT M16-1T-1977 2). This method of testing provides better

assurance that these ventilation systems will perform their safety function than testing I

to the earlier versions of the RDT standard. Although it is a superior test method, use l of the 1977 version of the RTD standard is subject to some interpretation as to whether l or not it fully complies with requirements which may be implied by Regulatory Guide l (RG) 1.52 which is referenced in the Technical Specifications. Therefore, to preclude subjective interpretations of the standard, Technical Specification changes are being proposed for North Anna Units 1 and 2 to clarify test requirements by explicitly establishing the current test method (ASTM D3803-1979) as the Technical Specification testing requirement for charcoal adsorbent. The current testing methodology fully establishes operability of the charcoal adsorbent in the ventilation systems. Since the proposed clarification only explicitly specifies current testing practice, the proposed changes do not create an unreviewed safety question or generate a significant hazards consideration.

Background

Technical Specifications require that the charcoal adsorbent be tested in accordance with RG 1.52, Revision 2, Regulatory Position C.6.a. This Regulatory Position refers to Table 2 in the Regulatory Guide, which in turn references Table 5-1 of ANSI N509-1976 for the test conditions, physical properties, and lodine removal efficiencies of activated 4

charcoal. ANSI N509-1976 references RDT M16-1T as an acceptable test method for determining lodine removal efficiencies. ANSI N509-1976 does not however specify a date or revision for the RDT M16-1T standard referenced in Table 5.1.

1 The test method described in ANSI N509-1976 as an acceptable test refers to the pre-and po.st-sweep at 25'C and the test temperature at 80*C. This test would create a condition that would cause moisture to condense in the charcoal which would invalidate the test. As stated in the " Applicable Documents" section of ANSI N509-1976, the first paragraph contains the following text:

i "The following documents supplement this standard and are a part of it to the ,

extent indicated where they are cited in the text. The issue of the document in l effect at the time of the purchase order shall apply unless otherwise specified." !

l In the list of documents that follows this paragraph is the reference to RDT M16-1T with no date reference. Since no date is specified, this means that the standard that was in place when the North Anna Technical Specifications were issued (Unit 1 in 1978 and Unit 2 in 1980) would be the correct standard (RDT M16-1T-1977). The 1977 version l 1

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l of the RDT standard was issued in December of 1977 which would make it the appropriate standard using the rules stipulated directly in the ANSI standard.

Descriotion of Amendment Reauest The proposed changes will revise Surveillance Requirements for the charcoal adsorbent in the Waste Gas Charcoal Filter System (TS 3/4.6.4.3), Control Room Emergency Habitability System (TS 3/4.7.7.1), and the Safeguards Area Ventilation System (TS 3/4.7.8.1) to reflect the current testing criteria for new and used carbon adsorbent. These changes specify ASTM D 3803-1979 as the laboratory testing standard for both new and used charcoal adsorbent used in the ventilation system identified above. Laboratory testing of the carbon samples adsorbers will be performed as noted below:

Used charcoal: (ASTM D3803-1979, Method B) l i

l . Relative humidity (RH) of 70% (Control Room and Safeguards Area banks) heaters are installed i

. RH of 95% (Gaseous Waste banks), heaters are not installed.

. Temperature of 80 C.

. 12.2 M/ min. face velocity.

l . Temperature equilibrated to 80 C without flow.

l . Loading with 1.75 mg/M methyliodide for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

. Elution period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

. Acceptance criteria is < 1% penetration.

New charcoal:

l Oualification Testing Methyl lodide Removal Efficiency (ASTM D3803-1979, Method A, except at 25 C) l l . RH of 95%.

i . Temperature of 25 C.

. 12.2 M/ min. face velocity.

. Equilibrated for 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months with flow at 25 C and 95% RH.

. Loading with 1.75 mg/M methyliodide for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Elution period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

. Acceptance criteria is < 1% penetration.

Batch Tests Physical Properties:

. The ASTM D2862 method for Particle Size Distribution.

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. The ASTM D3802 method for Hardness Number.

. The ASTM D3466 method for Ignition Temperature.

. The ASTM D3467 method for Activity.

. The ASTM D2854 method for Bulk Density.

. Impregnate Content determined by calculation not to exceed 5% by weight.

Methyl lodide Removal Efficiency (ASTM D3803-1979, Method A):

. RH of 95%.

. Temperature of 30 C.

. 12.2 M/ min. face velocity.

. Equilibrated for 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months with flow at 30 C and 95% RH.

. Loading with 1.75 mg/M methyl!odide for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

. Elution period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . l

. Acceptance criteria is < 1% penetration.

Elemental lodine Retention (ASTM D3803-1979, Method E):

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. No equilibration. l

. 12.2 M/ min. face velocity through a 1 inch sample for a residence time of 0.125 seconds.

. Loading with 75 mg/M elemental iodine with flow at ambient laboratory temperature and relative humidity for 10 minutes.

. Elution period of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during the first 30 minutes gas temperature is raised to 180 C.

. Acceptance criteria is > 99.5% retention.

Specific Chanaes i The Unit 1 and 2 Technical Specifications are identical. The specific changes identified below are for both Units. In addition, typographical errors are being corrected as shown on the attached pages.

. Waste Gas Charcoal Filter System The laboratory testing requirements for the Waste Gas Charcoal Filter System identified in both Technical Specifications 4.6.4.3.b.2 and 4.6.4.3.c are changed from:

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

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... meets the laboratory testing criteria of TS 4.6.4.3.g."

New Specification 4.6.4.3.g provides the test method and acceptance for used charcoal and reads as follows:

"g. Used charcoal shall be tested in accordance with ASTM D3808-1979 (Method B), for a residence time of 0.25 seconds. The measured Methyl lodide Penetration shall be less than 1%."

New Specification 4.6.4.3.h is being created to establish the test method and acceptance for new charcoal and reads as follows:

"h. New charcoal shall be tested as follows:

1. Each batch of new charcoal shall be tested as described below:

a. ASTM D3803-1979 (Method A) to demonstrate a Methyl lodide Penetration of less than 1% for a residence time of 0.25 seconds.

l b. ASTM D3803-1979 (Method E) to demonstrate an Elemental l lodine Retention of greater than 99.5%. i 1

2. A one-time qualification test shall be performed in accordance with ASTM D3803-1979 (Method A, except at 25 C), for a residence time of 0.25 seconds to demonstrate a Methyl lodide Penetration of less than 1%."

. Control Room Emergency Habitability System l

The laboratory testing requirements for the Control Rocm Emergency Habitability System identified in both Technical Specifications 4.7.7.1.b.2 and 4.8.1.c are changed l from:

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

to:

... meets the laboratory testing criteria of TS 4.7.7.1.g."

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% ,- , j New Specification 4.7.7.1.g provides the test method and acceptance for used charcoal and reads as follows:

"g. Used charcoal shall be tested in accordance with ASTM D3808-1979 (Method B, except at 70% RH), for a residence time of 0.25 seconds. The ,

measured Methyl lodide Penetration shall be less than 1%."

New Specification 4.7.7.1.h is being created to establish the test method and acceptance for new charcoal and reads as follows:

"h. New charcoal shall be tested as follows:

1. Each batch of new charcoal shall be tested as described below:

a. ASTM D3803-1979 (Method A) to demonstrate a Methyl lodide Penetration of less than 1% for a residence time of 0.25 seconds. 1 1

b. ASTM D3803-1979 (Method E) to demonstrate an Elemental lodine Retention of greater than 99.5%.

2. A one-time qualification test shall be performed in accordance with ASTM D3803-1979 (Method A, except at 25 C), for a residence time of 0.25 seconds to demonstrate a Methyl lodide Penetration of less than 1%."

. Safeguards Area Ventilation System l

The laboratory testing requirements for the Safeguards Area Ventilation System identified in both Technical Specifications 4.7.8.1.b.2 and 4.7.8.1.c are changed from:

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

to:

... meets the laboratory testing criteria of TS 4.7.8.1.g."

New Specification 4.7.8.1.g provides the test method and acceptance for ,

used charcoal and reads as follows.

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"g. Used charcoal shall be tested in accordance with ASTM D3808-1979 (Method B, except at 70% RH), for a residence time of 0.25 seconds. The measured Methyllodine Penetration shall be less than 1%."

New Specification 4.7.8.1.h is being created to establish the test method l and acceptance for new charcoal and reads as follows:

"h. New charcoal shall be tested as follows:

l 1. Each batch of new charcoal shall be tested as described below: 1 1

a. ASTM D3803-1979 (Method A) to demonstrate a Methyl l l lodide Penetration of less than 1% for a residence time of l 0.25 seconds.

b. ASTM D3803-1979 (Method E) to demonstrate an Elemental l l lodine Retention of greater than 99.5%.

! 2. A one-time qualification test shall be performed in accordance with ASTM D3803-1979 (Method A, except at 25 C), for a residence time of 0.25 seconds to demonstrate a Methyl lodide Penetration of

! less than 1%."

l Safety Significance i

l The proposed changes represent a clarification in the current testing methodology and, I therefore, are administrative in nature. This charcoal test methodology accurately determines the lodine removal efficiencies and fully establishes operability of the charcoal adsorbent in the Waste Gas Charcoal Filter System, Control Room Emergency Habitability System, and the Safeguards Area Ventilation System.

l Therefore, there is no degradation in the ability of the charcoal adsorbent to perform its l safety function based on the proposed clarification which specifies current testing l

practice for charcoal adsorbent in the ventilation systems noted above.

The proposed changes identify the actual charcoal testing methodology and therefore l

do not affect system operation or performance, nor do they affect the probability of any event initiators. These changes do not affect any Engineered Safety Features actuation setpoints or accident mitigation capabilities. As a clarification, the proposed changes do not increase the consequences of an accident or malfunction of equipment important to safety previously evaluated in the UFSAR.

The proposed changes to the charcoal testing methodology will not affect the method of operation of the system. The proposed changes only reflect the actual testing criteria currently being used for the charcoal samples. No new or different accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as 6

a result of these changes. Therefore, tFa possibility of a new or different kind of accident other than those already evaiuated will not be created by this change.

Therefore, no new accident or malfunction of a different kind is created by the proposed changes.

The pr posed changes which represent the current laboratory testing methodology for j charcoal adsorber samples, demonstrates the required performance of the adsorbers j following a design basis LOCA or Fuel Handling Accident. Changing the Technical Specifications to reflect the current test methodology for charcoal sample testing will not affect system performance or operation. Therefore, these changes do not result in a reduction in any margin of safety.

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References:

1. ASTM D 3803-1979, Standard Test Methods for Radiciodine Testing of Nuclear-Grade Gas-Phase Adsorbents.

2. RDT M1-1T-1977, Gas-Phase Adsorbent for Trapping Radioactive lodine and lodine Compounds.

3. Regulatory Guide 1.52, Revision 2, March 1978, 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.

4. ANSI /ASME N509-1976, Nuclear Power Plant Air Cleaning Units and Components.

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4 Basis for No Significant Hazards Consideration Determination The proposed Technical Specifications changes will revise Surveillance Requirements for the charcoal adsorbent in the Waste Gas Charcoal Filter System (TS 3/4.6.4.3),

Control Room Emergency Habitability System (TS 3/4.7.7.1), and the Safeguards Area Ventilation System (TS 3/4.7.8.1) to reflect the current testing methodology for new and used carbon adsorbent. These proposed changes specify ASTM D 3803-1979 as the laboratory testing standard for both new and used charcoal adsorbent for the ventilation l systems identified above.

1 Virginia Electric and power has evaluated the proposed technical Specification changes to the North Anna Units 1 and 2 Technical Specifications against the Significant l Hazards Criteria of 10 CFR 50.92 and determined that the changes do not involve any significant hazard for the following reasons:

l l 1. The probability or consequences of an accident previously evaluated is not significantly increased.

The proposed changes are administrative in nature in that the changes only I l explicitly specify the current testing methodology for charcoal adsorbent. The l proposed changes will not affect system operation or performance, nor do they l affect the probability of any event initiators. These changes do not affect any l Engineered Safety Features actuation setpoints or accident mitigation capabilities. Therefore, the proposed changes will not significantly increase the consequences of an accident or malfunction of equipment important to safety previously evaluated in the UFSAR.

l The possibility of an accident or a malfunction of a different type than any 2.

previously evaluated is not created.

l The proposed changes only clarify the requirements for charcoal testing and will not affect the method of operation of the ventilation systems. Furthermore, the proposed changes are only intended to clarify the existing requirements to i explicitly specify the current test methodology. No new or different accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of these changes. Therefore, the possibility of a new or l different kind of accident other than those already evaluated will not be created I by this change.

3. The margin of safety has not been significantly reduced.

i The proposed changes which represent the current laboratory testing methodology for charcoal adsorber samples, demonstrates the required performance of the adsorbent following a design basis LOCA or I:uel Handling Accident. Changing the Technical Specification to clarify the methodology for charcoal sample testing will not affect system performance or operation.

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Therefore, these changes will not result in a significant reduction in any margin of safety.

Based on the above discussions, it has been determined that the requested Technical Specification changes do not involve a significant increase in the probability or

consequences of an accident or other adverse condition over previous evaluations; or i create the possibility of a nt..v or different kind of accident or condition over previous i evaluation; or involve a significant reduction in a margin of safety. Therefore, the

requested license amendment does not involve a significant hazards consideration.

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ML20101F789

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