BSEP-97-0168, Application for Amends to Licenses DPR-71 & DPR-62,revising Surveillance Requirements to Require Testing of Control Room Emergency Ventilation Sys Charcoal & Revising Acceptance Criteria for Subject Charcoal Testing
| ML20138G109 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/30/1997 |
| From: | Hinnant C CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138G115 | List: |
| References | |
| BSEP-97-0168, BSEP-97-168, NUDOCS 9705060177 | |
| Download: ML20138G109 (11) | |
Text
.
p 0
j l
'CP&L i
Carolina Power & Light Company C. S. Hinnant l'
PO em 10429 Vice Presidet Southport, NC 28431 4429 Brunswi.;k steani Electric Plant I
Apri! 30,1997 SERIAL: BSEP 97-0168 1
10 CFR 50.90 TSC 9TfSB03 U. S. Nuclear Regulatory Commissicn ATTN: Document Control Desk 4
Washington, DC 20555, BRUNSWFCK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR 71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS i
CONTROL ROOM EMERGENCY VENTILATION SYSTEM CHARCOAL TESTING REQUIREMENTS Gentlemen:
in accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light (CP&L) Company is requesting a revision to the Technical Specifications for the l
Brunswick Steam Electric Plant (BSEP), Unit Nos.1 and 2. These proposed amendments revise Surveillance Requirements 4.7.2.b.2 and 4.7.2.c to require testing of the control room l~
emergency ventilation system charcoal in accordance with ASTM D3803-1989," Standard Test 1
Method for Nuclear-Grade Activated Carbon." The proposed amendments also revise the acceptance criteria for the subject charcoal testing. Current testing demonstrates a filter efficiency of 95%; the proposed Surveillance Requirements will demonstrate a filter efficiency of l
90%, consistent with the bounding calculations of control room doses.
CP&L is providing, in accordance with 10 CFR 50.91(b), Mr. Mel Fry of the State of North Carolina with a copy of the proposed license amendments.
In order to allow time for procedure revision, orderly incorporation into copies of the Technical Specificatioris, CP&L requests that the proposed arnendments, once approved by the NRC, be issued with an effective date of no later than 30 days from the date of issuance of the amendments.
Please refer any questions regarding this submittal to Mr. Keith Jury, Manager - Regulatory A.ffairs, at (910) 457-2783.
I Sincerely, 8
C S jac rA O DJ 9705060177 97043o C. S. Hinnant PDR ADOCK 05000324 P
PDR ll E. I.ll I!I.ll!,lill.Ill w -
+
l j
=
I Document Control Desk
{
BSEP 97-0168 / Page 2
{
i i
MAT / mat 1
{
Enclosures:
' 1.
Basis for Change Request 2.
10 CFR 50.92 Evaluation 3.
Environmental Considerations i
4.
Page Change instructions j
5.
Marked-up Techn: cal Specification Pages - Unit 1 i
6.
Marked-up Technical Specification Pages - Unit 2 '
l 7.
Typed Technical Specification Pages - Unit 1
)
[
8.
Typed Technical Specification Pages - Unit 2 i
C. S, Hinnant, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources i
.of his information are officers, employees, and agents of Carolina Power & Light Company.
b O2&L ed. 770Jas
)
l i
j Notary (Seal)
My commission expires: Cb d _2, { ) pq 9
\\
I i
i j
1 i
.l 4
i 1
i i
j Document Control Desk
- BSEP 97-0168 / Page 3 I
a i
j
. pc (with enclosures).
U. S. Nuclear Regulatory Commission, Region 11 j
ATTN.: Mr. Luis A. Reyes, Regional Administrator
' Atlanta Federal Center
'l
. 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303 j
U. S. Nuclear Regulatory Commission l
ATTN: Mr. C. A. Patterson, NRC Senior Resident inspector j
8470 River Road 1
Southport, NC 28461 U. S. Nuclear Regulatory C
. mission
- ATTN.: Mr. David C. TrW
.. (Mail Stop OWFN 1eH22)
-l l
11555 Rockville Pike i
Rockville, MD 208.52-2738
)
i L
The Honorable J. A Sanford Chairman - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 l
' Mr. Mel Fry Acting Director Division of Radiation Protection j
North Carolina Department of Environment, Health, and Natural Resources
{
3825 Barrett Drive.
Raleigh, NC 27609-7221 I
h l
i I
i l
l l
i 4
i
e 1
e
[
ENCLOSURE 1 l
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 i
NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 i'
REQUEST FOR LICENSE AMENDMENTS i
CONTROL ROOM EMERGENCY VENTILATION SYSTEM i
CHARCOAL TESTING REQUIREMENTS j
BASIS FOR CHANGEG l
PROPOSED CHANGE:
l These proposed amendments revise Surveillance Requirements 4.7.2.b.2 and 4.7.2.c to require testing of the control room emergency ventilation system (CREVS) charcoal in accordance with l
ASTM D?803-1989," Standard Test Method for Nuclear-Grade Activated Carbon." The-l proposed amendments also revise the acceptance criteria for the subject charcoal testing.
Current testing demonstrates a filter efficiency of 95%; the proposed Surveillance Requirements will demonstrate a filter efficiency of 90%, consistent with the bounding calculations of control room doses.
{-
Current Reauiroment l
Surveillance Requirements 4.7.2.b.2 and 4.7.2.c require verifying that:
l'
.. a laboratcry analysis of a representative carbon sample obtained in accordance with j'
. Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 1, July 1976, meets the
[
loboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976.
Proposed Change i
.The proposed amendments revise Surveillance Requirements 4.7.2.b.2 and 4.7.2.c to require that:
.. a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C 6.b of Regulatory Guide 1.52, Rev2 ion 1, July 1976, and tested at j.
30.010.2* C and 93.0 to 96.0% relative humidity in accordance with the methodology i_
provided by ASTM D3803-1989, meets the acceptance criteria of < 5.0% penetration of methyl iodide.
i Basis For Proposed Chance in letters dated January 22,1997 (Serial: BSEP 97-0033) and February 15,1997 (Serial:
BSEP 97-0069). CP&L notified the NRC of a concern that the existing CREVS charcoal testing did not adequately bound the relative humidity which could be experienced by the CREVS.
The CREVS uses makeup air, from the outside, as part of the air circulated through the control E1-1
i i
room when operating in the radiation protection mode. There are no heaters to control the relative humidity of the air passing through the system's charcoal. As a result, CP&L has l
determined that there are credible., high humidity, situations when the mixture of the makeup air and the air circulated through the control room can have a relative humidity in excess of 70%.
Surveillance Requirements 4.7.2.b.2 and 4.7.2.c currently require testing in accordance with the criteria of Regulatorj Position C.6.a of Regulatory Guide 1.52 Revision 1,1976 based on the 1
assumption that relative humidity is controlled to 70% or less. Therefore, with relative humidity above 70%, the current Technical Specification testing does not assure a charcoal efficiency of 90% for iodine removal as assumed in the current control room dose analyses.
.1 In order to address this issue, in January 1997, CP&L tested samples of the CREVS filtration train charcoal in accordance with ASTM D3803-1989, at a temperature of 30.010.2 C with a i
relative humidity of 93.0 to 96.0%. The results of the testing for the 2A and 28 CREVS filtration trains were 98.897% and 97.815%, respectively. Therefore, the testing demonstrated the capability of the CREV filtration units to achieve in excess of 95% (current acceptance criteria per Regulatory Guide 1.52, Revision 1,1976) filtration efficiency CP&L also committed to j
submit a license amendment request by April 30,1997, to require CREVS charcoal testing in i
accordance with ASTM D3803-1989.
ASTM D3803-1989," Standard Test Method for Nuclear-Grade Activated Carbon"is an industry accepted standard for charcoal filter testing. The conditions employed by this standard were 1
i selected to approximate operating or accident conditions of a nuclear reactor which would severely reduce the performance of activated carbons. The ASTM D3803-1989 testing is more stringent than that required by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976. Specifically, the testing temperature of ASTM D3803-1989 is 30.010.2 C versus 80 C for the Regulatory Guide 1.52 testing. Also, ASTM D3803-1989 j
requires a relative humidity of 93 to 96% versus 2 70% for the Regulatory Guide 1.52 testing.
Both these parameters result in the ASTM D38031989 test being a more conservative test than that required by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976.
}
The proposed changes to Scrveillance Requirements 4.7.2.b.2 and 4.7.2.c require that charcoal samples tested in accordance with the methodology of ASTM D3803-1989 meet the j.
acceptance criteria of < 5.0% penetration of methyliodide. This corresponds to a 90% filtration i
efficiency, which is the filtration efficiency assumed in the current bounding calculations of control room doses. As such, the proposed acceptance criteria of < 5.0% penetration of methyl j
iodide ensures that General Design Criterion (GDC) 19 dose limits for control room operators l
are not exceeded.
i The NRC is currently reviewing control room dose calculations for the control rod drop (CRD) and main steam line break (MSLB) accidents. CP&L submitted these calculations in letters dated March 5,1997 (BSEP 97-0012), and April 15,1997 (BSEP 97-0147), respectively. The limiting accident, from a control room dose perspective, is the MSLB accident, and only the thyroid dose approaches GDC 19 limits. The thyroid dose received by an operator as a result of a MSLB accident would be 25.5 rem, assuming a peak reactor coolant activity of 3.0 micro-curies per gram dose equivalent 1-131. As stated in our letter dated February 28,1997 (RSEP 97-099), CP&L has implemented administrative controls to limit reactor coolant activity to less than 0.1 micro-curies per gram dose equivalent (-131. CP&L will maintain this E1-2
o i
administrative control until a license amendment request limiting reactor coolant peak activity can be approved. The thyroid dose received by an operator as a result of a CRD accident would be 23.2 rem. This is based on tripping the condenser vacuum pumps on a main stearn line radiation monitor - high signal The March 5,1997, letter requested license amendments to 1
incorporate a new Technical Specification which applies to the condenser vacuum pump isolation instrumentation. The proposed Technical Specification covers the use of the main steam line radiation monitor signals for a trip nf the condenser vacuum pumps.
The Bases for Technical Specification 3/4.7.2, Control Room Emergency Ventilation System, have been revised to reflect the upgraded testing methodology and are included with this amendment request.
i i
l
's, n
E1-3 4
~
ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NPC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM 1
CHARCOAL TESTING REQUIREMENTS 10 CFR 50.92 EVALUATION 1
The NRC has provided standards in 10 CFR 50.92 for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of cccident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. CP&L has reviewed these proposed license amendments and concluded that their adoption does not involve a significant hazards consideration. The basis for this determination fol!ows.
1.
T he proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.
i The proposed amendments revise Surveillance Requirements 4.7.2.b.2 ar,d 4.7.2.c to require testing of the control room emergency ventilation system (CREVS) charcoalin accordance with ASTM D3803-1989, " Standard Test Method for Nuclear-Grade Activated Carbon." Currently, Surveillance Requirements 4.7.2.b.2 and 4.7.2.c to require testing in accordance with the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976. The purpose of the CREVS is to mitigate an accident. It is not associated with any initiating events and, therefore, cannot affect the probability of any accident.
ASTM D3803-1989 is an industry accepted standard for charcoal filter testing. The conditions employed by this standard were selected to approximate operating or accident conditions of a nuclear reactor which would severely reduce the performance of activated carbons. The ASTM D3803-1989 testing is more stringent than that sequired by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976.
Specifically, the testing temperature of ASTM D3803-1989 is 30.010.2 C versus 80o C for the Regulatory Guide 1.52 testing. Also, ASTM D3803-1989 requires a relative humidity of 93 to 96% versus > 70% for the Regulatory Guide 1.52 testing. Both these pararneters result in the ASTM D3803-1989 test being a more conservative test that that required by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1, 1976.
1 The proposed changes to Surveillance Requirernents 4.7.2.b.2 and 4.7.2.c require that charcoal samples tested in accordance with the methodology of ASTM D3803-1989 meet E2-1
a the acceptance criteria of < 5.0% penetration of methyliodide. This corresponds to a 90% filtration efficiency which is the filtration efficiency assumed in the current bounding calculations of control room doses. As such, the proposed acceptance criteria of < 5.0%
penetration of methyl iodide ensures that General Design Criterion 19 dose limits for control room operators are not exceeded.
Therefore, the proposed amendments do not involve an increase in the consequences of an accident.
2.
The propcsed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.
As stated above, the proposed amendments revise the required testing methodology for the CREVS charcoal. The CREVS is not associated with any initiating events. The system design is not affected by the proposed change. Therefore, the proposed i
amendments cannot create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed license amendments do not involve a significant reduction in a margin of safety.
The proposed amendments upgrade the CREVS charcoal testing requirements from the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976 to ASTM D3803-1989. The conditions employed by ASTM D3803-1989 were selected to approximate operating or accident conditions of a nuclear reactor which would severely reduce the performance of activated carbons. The ASTM D3803-1989 testing is more stringent than that required by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revicion 1,1976. The testing temperature of ASTM D3803-1989 lower than that of Regulatory Guide 1.52 and the relative humidity required by ASTM D3803-1989 is higher than that required by Regulatory Guide 1.52. This makes the ASTM D3803-1989 test being a more conservative test that that required by the criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 1,1976. Additionally, the proposed acceptance criteria of < 5.0% penetration of methyliodide ensures that General Design Criterion 19 dose limits for control room operalors are not exceeded. As such, the proposed license amendments do not involve a significant reduction in a margin of safety.
CP&L has evaluated this request in accordance with the provisions of 10 CFR 50.59 and determined that the proposed license amendments do not involve an unreviewed safety question.
E2-2
_-~
e s
ENCLOSURE 3 I
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DF 3-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM CHARCOAL TESTING REQUIREMENTS ENVIRONMENTAL CONSIDERATIONS 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligib!e for categorical exclusion from performing an environmental assessment. A proposed i
amendment to an operating license for a facility requires no environmental assessment if i
operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational radiation exposure. CP&L has reviewed this request and concluded that the proposed amendments meet the eligibility criteria for categorical
' exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 5127(b), no environmental impact statement of environmental assessment needs to be prepared in connection with the 4
issuance of the amendment. The basis for this determination follows.
1.
These amendments do not involve a significant hazards consideration, as shown in 2.
The proposed license amendments do not result in a significant change in the types or a j
significant increase in the amounts of any effluent that may be released offsite. The proposed license amendments do not introduce any new equipment nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The proposed license amendments do not alter the function of existing equipment and will ensure that the consequences of any previously evaluated accident do not increase. Therefore, CP&L has concluded that there will not be a significant increase in the types or amounts of any effluent that may be released offsite and, as such, does not involve irreversible environmental consequences beyond those already associated with normal operation.
3.
These amendmeats do not result in an increase in individual or cumulative occupational radiation exposure.
)
E3-1 4
=
a 1
I ENCLOSURE 4 4
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 i.
REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM CHARCOAL TESTING REQUIREMENTS i
i PAGE CHANGE INSTRUCTIONS UNIT 1 1
Removed page Inserted page
}
3/4 7 4' 3/4 7-4 B 3/4 7-1h B 3/4 7-1h B 3/4 7-1i 8 3/4 7-1i 4
4 s
PAGE CHANGE INSTRUCTIONS UNIT 2 a
Removed page inserted page 3/4 7-4 3/4 7-4 B 3/4 7-1h B 3/4 7-1h B 3/4 7-1i G 3/4 7-11 E4-1
i ENCLOSURE 5 I
BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 j
NRC DOCKET NOS. 50-325 AND 50-324 OPERATING LICENSE NOS. DPR-71 AND DPR-62 i
1 I
REQUEST FOR LICENSE AMENDMENTS CONTROL ROOM EMERGENCY VENTILATION SYSTEM i
CHARCOAL TESTING REQUIREMENTS '
I l
I 4
i a
i 3
MARKED-UP TECHNICAL SPECIFICATION PAGES - UNIT 1 i
3 4
1 l'
4 6
a 1