ML20141K248

Proposed Tech Specs Revising Testing Methodology Utilized by VCSNS to Determine Operability of Charcoal Adsorbers in Emergency Safeguards Features Air Handling Units

ML20141K248
Person / Time
Site:	Summer
Issue date:	05/21/1997
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20141K245	List: ML20141K248 RC-97-0108, Application for Amend to License NPF-12,revising Testing Methodology Utilized by VCSNS to Determine Operability of Charcoal Adsorbers in Engineering Safeguards Features Air Handling Units
References
NUDOCS 9705280408
Download: ML20141K248 (13)

Text

_ _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ . _ . _ . _ . . _ _ _ _ . _ _ _ _ _ __________

_. --w ASTM b 38$!L - 19&9, a4 e rA h+

' PLANT SYSTEMS J 70W and 3ctc. j% g A \ k h k p %a he m SURVEILLANCE - REQUIREMENTS ( on mu ) -~ ^ =

% of t n.5~ 7*.

m __

m .

. 1. Verifying that the cleanup system satisnes the in-place testing acceptance criteria and uses the test procedures of Regulatory ,

Positions C.5.a, C.5.c and C.5.d ofRegulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 21,270 cfm i 10%.

2. ' f within 31 days after removal, that a laboratory Verifying,f analysis o a re resentative charcoal sample obtained in accord ance with Re atory Position C.6.b of Regulatory Guide 1.52, 1 Revision 2.IV of S ch 1978.

509-1950, at a relmeets the laboratory e humidity at Uptrand 25'C tesHna criter[ia [

! t methyliodide pen tion of <1%

3. Verifyng a system flow rate of 21,270 cfm i 10% durine system operation when tested in accordance with ANSI N510-1375,

d. After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> ofcharcoal adsorber operation by verifying within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory  !

Position C.6.b ofRegulatory Guide 1.52, Revision 2. March 1978,  !

m_eets the laboratory testing criteria ofKNSIy509-1950, at a re ativ Qmrnalty ot 70Vo and 2570 witn a methvl ioc,iae penetration of ><)19 y .ge

e. Atleast once per 18. months by:

1. Verifying that the pressure drop across the combined HEPA and roughmg filters and charcoal adsorber banks is less than i

6 inches Water Gauge while operating the system at a flow rate l of21,270 cfm i 10%.

2. Verifying that on a simulated SI or high radiation test signal, the system automatically switches into a recirculation mode of l operation with flow through the HEPA filters and charcoal j i adsorberbanks.

3. Ve " ~ that on a simulated SI or high radiation test signal the em starts the normal and emergency air handling systems l whi pressurize the control room to a positive pressure of i greater than or equal to 1/8 inch W.G. relative to the outside l atmosphere and maintains the 1/8 inch W. G. positive pressure l

with a maximum of 1000 cfm of outside air during system operation.

l f. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 21,270 cfm i 10%.

g. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or i ec ual to 99.95% of a halogenated hydrocarbon refri gerant test gas when they are tested in-place in accordance with ANSIN510-1975 while operating the system at a flow rate of 21,270 cfm 10%.

I SUMMER-UNIT 1 3/4 7-15 Amendment No. M,131 9705280408 970521 PDR ADOCK 05000395 p PDR m

_. .~ _ . _-_ --

.. ~

~

, ,w

. AsTt4 D 3843 -ws93 a a rde -

l REFUELING OPERATIONS meAky ^io d 4 pwbhq f A 15% i SURVEILLANCE REQUIREMENTSTContinu'e5

\ l

2. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revisio_n 2. March 1978, meets the laboratory testine criteria offMSI N509-1880, at a test nyedia Qe;aterature of 370i  !

3. Verifying a cystem flow rate of 30,000 cfm 10% during system operation when tested in accordance with ANSI N510-1975.

c. Prior to the movement of fuel or crane operation with loads over the pool by verifyino that a laboratory analysis of a representative carbon sample oltained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2, March 1978. mee ts the labora-tory testing criteria ofGUW1 N509-19M Alt a test meala temoeramfel cotMO. Subsequent to eacn initial ana_ysis (which must be completed prior to fuel movement or crane operation with loads over the pool),

during the period of time in which there is to be fuel or crane e

movement with loads over the aool, verify charcoal adsorber operation every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> by oitaining and analyzing a samole as described above. These subsequent analyses are to be completed within thirty-one (31) days of sample removal.

d. Atleast once per 18 months by:

~

1. Ver' g that the pressure drop across the combined HEPA and .

mg filters and charcoal adsorber banks is less than l 6 es Water Gauge while operating the system at a flow rate of 30,000 cfm 10%. )

l

2. Verifying that on a loss of oEsite power test signal, the I system automatically starts. l

3. Verifying that the system mainbins the spent fuel pool area at a negative pressure greater than or equal to 1/8 inches Water Gauge relative to the outside atmosphere during system operation. l

e. Aftereachcom leteor artialre l verifying that t e HEPA filter bbacement of a HEPA remove greater than orfilter equalbank to by 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 30,000 cfm 10%.

f. After each complete or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove greater than or ecual to 99.95% of a halooenated hydrocarbon refrigerant test gas w2en they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 30,000 cfm i 10%.

SUMMER-UNIT 1 3/4 9-13 Amendment No. //,131

• t 2

. 2

,, r ..

i' I l PLANT SYSTEMS c

~

SURVEILLANCE REQUIREMENTS (Continued)

j. 1. i Verifying that the cleanup system satisfies the in-place testing 4 acceptance criteria and uses the test procedures of Regulatory 1

Positions C.S.a. C.5.c and C.S.d of Regulatory Guide 1.52, l;

Revision 2, March 1978, and the system flow rate is 21,270 cfm 10%. d 1

2. Verifying, within 31 days after removal, that a laboratory analysis of a representative charcoal sarr'ple obtained in accord- i ance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria q

of ASTM D3803-1989, at a relative humidity of 70% and 30*C

j. with a methyliodide penetration of <2.5%. *

3. . Verifying a system flow rate of 21,270 cfm i 10% during system operation when tested in accordance with ANSI N510-1975.

)

]

d. . After every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation by verifying j

within 31 days after removal, that a laboratory analysis of a i i representative carbon sample obtained in accordance with Regulatory j j, Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, j

j meets the laboratory testing criteria of ASTM D3803-1989, at a relative j humidity of 70% and 30*C with a methyliodide penetration of <2.5%..

j

' l i

i e. At least once per 18 months by:

1 )

j 1. J

. Verifying that the pressure drop across the combined HEPA and i i-roughing filters and charcoal adsorber banks is less than  !

L 6 inches Water Gauge while operating the system at a flow rate of 21,270 cfm 10%.

~

2. 1

+

Verifying that on a simulated Si or high radiation test signal, '

the system automatically switches into a recirculation mode of i  ;

operation with flow through the HEPA filters and charcoal 1

L adsorber banks. 1

3. Verifying that on a simulated Sl or high radiation test signal the system starts the normal and emergency air handling systems 1 .

which pressurize the control room to a positive pressure of "

greater than or' equal to 1/8 inch W.G. relative to the outside atmosphere and maintains the 1/8 inch W.G. positive pressure with a maximum of 1000 cfm of outside air during system operation.

f. After each complete or partial replacement of a HEPA filter bank by

~

1 verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 21,270 cfm 10%.

i s' g. After each complete or partial replacement of a charcoal adsorber 4

bank by verifying that the charcoal adsorbers remove greater than or

equal to 99.95% of a halogenated hydrocarbon refrigerant test gas '

when they are tested in-place in accordance with ANSI N510-1975 1

while operating the system at a flow rate of 21,270 cfm 10%.

I SUMMER - UNIT 1 3/4 7-15 Amendment No. 24,131,

i

.g REFUELING OPERATIONS ,

- SURVEILLANCE REQUIREMENTS (Continued)

2. - Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989, at a relative humidity of 95% and 30*C with a methyliodide penetration i of <2.5%.

3. Verifying a system flow rate of 30,000 cfm 110% during system openation when tested in accordance with ANSI N5101975.

c. Prior to the movement of fuel or crane operation with loads over the  !

pool by verifying that a laboratory analysis of a representative  :

carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the labora- t tory testing criteria of ASTM D3803-1989, at a relative humidity of i 95% and 30'C with a methyl iodide penetration of <2.5%.

I Subsequent to each initial analysis (which must be completed prior to fuel movement or crane operation with loads over the pool), i during the period of time in which there is to be fuel or crane ,

movement with loads over the pool, verify charcoal adsorber

• operation every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> by obtaining and analyzing a sample as described above. These subsequent analyses are to be completed within thirty-one (31) days of sample removal. '

d. At least once per 18 months by: .

1. Verifying that the pressure drop across the combined HEPA and -

roughing filters and charcoal adsorber banl<s is less than

• 6 inches Water Gauge while operating the system at a flow rate of 30,000 cfm 10%.

2. Verifying that on a loss of offsite power test signal, the system automatically starts. '

3. Verifying that the system maintains the spent fuel pool area at  ;

a negative pressure greater than or equal to 1/8 inches Water i i Gauge relative in the outside atmosphere during system operation.

e. After each complete or partial replacement of a HEPA filter bank by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 30,000 cfm 10%.

f. After each complete or partial replacement of a charcoal adsorber i bank by verifying that the charcoal adsorbers remove greater than or i

equal to 99.95% of a halogenated hydrocarbon refrigerant test gas I

when they are tested in-place in accordance with ANSI N5101975

[ while operating the system at a flow rate of 30,000 cfm 10%.

SUMMER -. UNIT 1 3/4 9-13 Amendment No. 42,131

.. s

\

Documtnt Control Desk )

Attachment 11 l TSP 960005 i RC-97-0108 Page 1 of 6 SAFETY EVALUATION FOR REVISING THE METHODOLOGY FOR

-TESTING THE CHARCOAL ADSORBEM ,

IN THE VIRGIL C. SUMMER NUCLEAR STA,:UN I TECHNICAL SPECIFICATIONS 1

Description of Amendment Reauest The Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS) are being revised to change the methodology for testing the charcoal adsorbers in the Control '

Room Normal and Emergency Air Handling System (3/4.7.6) and the Spent Fuel Pool Ventilation System (3/4.9.11) from ANSI N509-1980 (which references ASTM D 3803-1979) to ASTM D 3803-1989.

Specifically, Surveillance Requirements 4.7.6.c.2 and 4.7.6.d (for the Control Room), l methodology references will be changed from ANSI N509-1980, at a relative humidity of 70% and 25'O with a methyliodide penetration of < 1% to ASTM D 3803-1989, at a relative humidity of 70% and 30*C with a methyl iodide penetration of < 2.5%.

Surveillance Requirements 4.9.11.b.2 and 4.9.11.c (for the spent fuel pool),

methodology references will be changed from ANSI N509-1980, at a test media temperature of 30'C to ASTM D 3803-1989, at a relative humidity of 95% and 30 C with a methyliodide penetration of < 2.5%.

This change is the result of a statement made by South Carolina Electric and Gas (SCE&G) in a letter to the NRC. SCE&G submitted an emergency Technical Specification change request in a letter from Mr. S. A. Byrne (SCE&G) to Ms. Tilda Y.

Liu (NRC) dated February 10,1996 (approved by the NRC in an SER dated February 10,1996 and issued as Amendment 131). In the letter, SCE&G proposed to change the methodology for testing the charcoal adsorbers in the ESF air handling units from Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978 to ANSI N5091980. Also, in the letter SCE&G committed to revising the test methodology to ASTM D 3803-1989 which is the test methodology the NRC claims is the preferred method.

1 Safety Evaluation A methodology change from ANSI N509-1980 to ASTM D 3803-1989 for testing the ESF air handling units charcoal adsorbers is being proposed. The ANSI N509-1980 methodology utilizes ASTM D 3803-1979. The essential elements of the current testing I

l .

i Docum:nt Control D:sk Attachment ll TSP 960005 RC-97-0108 Page 2 of 6 requirements (ANSI N509-1980) and proposed testing requirements (ASTM D 3803-

1989) and the differences are listed in the Tables on pages 5 and 6.

Each of the differences between the current Technical Specification (TS) and the proposed TS test methodologies have been reviewed. The test parameters for the proposed TS change more accurately demonstrates the actual performance of the charcoal adsorbers following the worst case design basis accident. Therefore, there will be no degradation in the ability of the components to perform their design function.

The differences are addressed individually below.

Test Medium Temperature increase From 25 C To 30 C (Control Room Oniv)

This change proposes to change the VCSNS test medium temperature from 25'C to 30 C, which is consistent with the recommendations of ASTM D 3803-1989. This proposed change is a less restrictive change because ASTM D 3803-1989 states, " Increasing the temperature at which the test is performed generally increases the removal efficiency of the carbon....," however, the ASTM endorses the proposed temperature as a very stringent test which is recornmended for qualification of new carbons and the quantification of the degradation of used carbons. Therefore, this change is justified based on the recommendations of the ASTM, the minor difference in the adsorption behavior of carbon between 25 C and 30 C, and the fact that there are no features of the VCSNS systems that justify deviating from the ASTM.

Methyl lodide Penetration Acceptance Criteria increased From < 1% to < 2.5%

(Control Room Only)

This change proposes to revise the VCSNS methyliodide penetration acceptance criteria from < 1% to < 2.5%. The VCSNS calculations that form the design basis for the control room ventilation plenums assume a 95% radiciodine removal efficiency of the carbon. Therefore, the proposed change to a penetration of < 2.5% continues to support the assumption of a s 5%

penetration in the VCSNS safety analysis. The value of < 2.5% also supports tests performed on the VCSNS carbon using the requirements of ASTM D 3803-1979 (current methodology) and ASTM D 3803-1989 (proposed methodology).

This change is justified based on the safety analysis assumptions and the new testing methods required by ASTM D 3803-1989. Also, in a study performed for the NRC (EGG-CS-7364) by Idaho National Engineering Laboratory (INEL), it I was recommended that all Technical Specifications be revised to the most recent revision of the ASTM for testing carbon and that the penetration limit be l increased (to 20% for used carbons (20% is not feasible based on the safety I analysis assumptions] and 3% for new carbons).

i

l ..

• l Docum:nt Control D:sk l Attachment 11 l TSP 960005 l

RC-97-0108 Page 3 of 6 i

Methyl lodide Penetration Acceptance Criteria Decreased From s 3.0% to <

! 2.5% (Soent Fuel Pool Oniv) l l This change proposes to revise the VCSNS methyl iodide penetration j acceptance criteria from s 3.0% to < 2.5%. ANSI N5091980 requires a

) penetration of s 3.0% which is within the assumptions of the VCSNS safety l . analysis. The VCSNS calculations that form the design basis for the fuel i handling building exhaust plenums assume a radioiodine removal efficiency of the carbon of 95%. Therefore, the proposed change to a penetration of < 2.5%

continues to support the assumption of a s 5% penetration in the safety analysis l and is more restrictive than the current Technical Specification requirements.

t Methyl lodide Feed Period Decreased From 120 Minutes To 60 Minutes This change proposes to decrease the methyl iodide feed period from 120 l minutes to 60 minutes as recommended by ASTM D 3803-1989. This change l will not affect the test results because the methyl iodide adsorption i

effectiveness of the carbon is the same for a 60 minute feed time as it is for a 120 minute feed time as shown in laboratory testing. This change is justified based on the independence of the test results from a 120 minute to a 60 minute feed time.

l Elution Period Decreased From 240 Minutes To 60 Minutes . l This change proposes to decrease the elution (post-sweep) period from 240 i minutes to 60 minutes as recommended by ASTM D 3803-1989. This change l verifies the effectiveness of the retentive capability of the carbon. This change l will not affect the test results because the retentive capability of the carbon is j the same whether the elution time is 60 minutes or 240 minutes as shown in laboratory testing. This change is justified based on the independence of the test results from a 240 minute to 60 minute elution time.

l 16 Hour Pre-Eauilibration Period Added l This change proposes to add a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> pre-equilibration period as recommended by ASTM D 3803-1989. This change was made to be conservatively representative of the worst case accident conditions by allowing the carbon to absorb more moisture which decreases the effectiveness of the adsorber. This test is a more restrictive change because currently no pre-equilibration period is required. This pre-equilibration requirement is directly responsible for the increased penetration percentage results that are obtained.

i INEL Repoit, EGG-CS-7364, recommended that the NRC increase the allowed

{ penetration requirements. This change is justified because it conservatively i

t

i Document Control Drsk ,

Attachment ll i TSP 960005 RC-97-0108 Page 4 of 6 encompasses postulated accident conditions that can be applied to the adsorber.

Eauilibration Period Decreased From 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> This change proposes to decrease the equilibration period from 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for new carbon to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for new and used carbon as recommended by ASTM D 3803-1989. This change is essentially a more restrictive change when combined with the addition of the pre-equilibration period and because used carbon is required to be equilibrated. This change essentially requires a period of two hours after the pre-equilibration period during which the acceptable variability of all parameters is reduced. The test system must be closely  ;

monitored and controlled during the final four hours of the test (equilibration, feed, and elution periods). This change is justified based on the added requirement for a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> pre-equilibration period.

Overall this change applies a more restrictive testing methodology to the ESF air handling unit charcoal adsorbers than is currently used at VCSNS. ASTM D 3803-1989 states, "This standard is a very stringent procedure for establishing the capability of new and used activated carbon to remove radio-labeled methyliodide from air and gas streams. The single test method described is for application of both new and used carbons....The conditions employed were selected to approximate operating or accident conditions of a nuclear reactor which would severely reduce the performance of the activated carbons....Therefore, this test method is a very stringent test of nuclear-grade activated carbon because of the low temperature and high humidity specified. This test method is recommended for the qualification of new carbons and the quantification of the degradation of used carbons."

As stated in the above paragraph, ASTM D 38031989 contains stringent testing requirements. These requirements are being adopted at VCSNS as stated in the emergency Technical Specification change submitted and approved on February 10, 1996. The new testing requirements will provide assurance that the charcoal adsorbers used in the VCSNS ESF air handling units will perform their designed safety function.

l I

I

\

l Docum:nt Control Desk A.ttachment ll TSP 960005 RC-97-0108 '

Page 5 of 6 l CONTROL ROOM l

l CURRENT TECH SPEC PROPOSED TECH SPEC REQUIREMENT REQUIREMENT DIFFERENCES l 70% Relative Humidity 70% Relative Humidity None I test medium temperature of test medium temperature of increase in test medium 6

25'C 30 C temperature from 25 C to l 30'C l \

i methyliodide penetration methyliodide penetration increase allowed methyl  !

of < 1% of < 2.5% iodide penetration from l

< 1% to < 2.5%

l 120 minute methyliodide 60 minute methyliodide 60 minute decrease in I feed period feed period methyliodide feed period i i

I 240 minute elution period 60 minute elution period 180 minute decrease in elution period l no pre-equilibration period pre-equilibration period of increase in pre-equilibration 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for new and used period from 0 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> carbons equilibration period of 16 equilibration period of 2 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> decrease in hours for new carbons hours for new and used equilibration period carbons I

I

.. . __ . _ . _ . _. _ _ - - . .- ~. _ - _ - _ . . . _ .. _ _ . _ . __

~

l o .. ..

. Document Control D sk Attachment 11 TSP 960005 RC-97-0108 Page 6 of 6 l

l SPENT FUEL POOL l

CURRENT TECH SPEC- PROPOSED TECH SPEC l REQUIREMENT REQUIREMENT DIFFERENCES 95% Relative Humidity 95% Relative Humidity None l

test medium temperature of test medium temperature of None l 30 C 30 C methyliodide penetration methyliodide penetration decrease allowed methyl of s 3% of < 2.5% iodide penetration from l s 3% to < 2.5%

120 minute methyliodide 60 minute methyliodide 60 minute decrease in j feed period feed period methyliodide feed period l

240 minute elution period 60 minute elution period 180 minute decrease in elution period no pre-equilibration period pre-equilibration period of increase in pre-equilibration l 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for new and used period from 0 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> j carbons

equilibration period of 16 equilibration period of 2 14 hour1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> decrease in j hours for new carbons hours for new and used equilibration period l carbons 5

-- . - . - . . . - . - . . - - . - . . . . - . - . . . . - - - ~ . - - . . . . - . _ .

. 1 Documtnt Control Desk Attachment lli TSP 960005 RC-97-0108 Page 1 of 3 4

NO SIGNIFICANT HAZARDS EVALUATION FOR REVISING THE SPECIFICATION FOR TESTING THE CHARCOAL ADSORBERS .

IN THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS l

Description of Amendment Reauest I The _ Virgil C. Summer Nuclear Station (VCSNS) Technical Specifications (TS) are being l revised to change the methodology for testing the charcoal adsorbers in the Control l Room Normal and Emergency Air Handling System (3/4.7.6) and the Spent Fuel Pool l Ventilation System (3/4.9.11) from ANSI N509-1980 (which references ASTM D 3803-1979) to ASTM D 38031989.

Specifically, Surveillance Requirements 4.7.6.c.2 and 4.7.6.d (for the Control Room),

methodology references will be changed from ANSI N5091980, at a relative humidity of 70% and 25 C with a methyliodide penetration of < 1% to ASTM D 38031989, at a relative humidity of 70% and 30 C with a methyliodide penetration of < 2.5%.

Surveillance Requirements 4.9.11.b.2 and 4.9.11.c (for the spent fuel pool),

methodology references will be changed from ANSI N509-1980, at a test media temperature of 30*C to ASTM D 38031989, at a relative humidity of 95% and 30*C with a methyliodide penetration of < 2.5%.

! 1 This change is the result of a statement made by South Carolina Electric and Gas l (SCE&G) in a letter to the NRC. SCE&G submitted an emergency Technical Specification change request in a letter from Mr. S. A. Byrne (SCE&G) to Ms. Tilda Y.

Liu (NRC) dated February 10,1996 (approved by the NRC in an SER dated February  ;

10,1996 and issued as Amendment 131). In the letter, SCE&G proposed to change y the methodology for testing the charcoal adsorbers in the ESF air handling units from

l. Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978 to ANSI N509-1980. Also, in the letter SCE&G committed to revising the test methodology to ASTM D 3803-1989 which is the test methodology the NRC claims is the preferred method.

l l

4 Basis for No Sionificance Hazards Consideration Determination i

South Carolina Electric & Gas Company (SCE&G) has evaluated the proposed i

changes to the VCSNS TS described above against the Significant Hazards Criteria of I

Document Control Drsk Attachment lll l TSP 960005 i RC-97-0108 Page 2 of 3 l

l 10 CFR 50.92 and has determined that the changes do not involve any significant hazard. The following is provided in support of this conclusion.

l 1. ' Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

l The proposed change revises the methodology for testing the charcoal adsorbers in the Control Room Normal and Emergency Air Handling System and the Spent fuel Pool Ventilation System (Engineered Safeguards Feature

[ESF) air handling units) to the updated Standard Test Method for Nuclear-Grade Carbon. The change will not affect the probability of an accident. The charcoal adsorbers are not initiators of any analyzed event. The change will not Ugnificantly affect the consequences of an accident. The charcoal adsorbers l

will be tested to the updated version of the approved standard, which generally l

contains more stringent testing requirements. The change does not affect the operation of the ESF air handling units. The new testing requirements will continue to ensure that the ESF air handling units will be capable of pedorming i

their safety function and meeting the assumptions in the safety analysis. The change does not affect the mitigation capabilities of any component or system nor does it affect the assumptions relative to the mitigation of accidents or transients. Therefore, the change does not involve a significant increase in the probability or consequences of an accident previously evaluated. t

, 2. Does the change create the possibility of a new or different kind of accident l from any accident previously evaluated?

The proposed change revises the methodology for testing the charcoal adsorbers in the Control Room Normal and Emergency Air Handling System and the Spent fuel Pool Ventilation System (Engineered Safeguards Feature

[ESF] air handling units) to the updated Standard Test Method for Nuclear-Grade Carbon. The change does not involve a significant change in the design l or operation of the plant. The changes do not involve a physical e!'.eration of I

the plant (no new or different type of equipment will be installed), or new or unusual operator actions. No new or different accident scenarios, transient precursors, failure mechanisms, or limiting single failures will be introduced as a result of this change. Therefore, the change does not create the possibility of a t new or different kind of accident from any accident previously evaluated.

3. Does this change involve a significant eduction in margin of safety?

i The proposed change revises the methodology for testing the charcoal f adsorbers in the Control Room Normal and Emergency Air Handling System i and the Spent fuel Pool Ventilation System (Engineered Safeguards Feature

i. [ESF) air handling units) to the updated Standard Test Method for Nuclear-

l

.. . +. ,

. Docum:nt Control Dtsk Attachment lll

TSP 960005 RC-97 0108

.Page 3 of 3 Grade Carbon. Testing of the charcoal adsorbers in the ESF air handling units  !

to the new standard will continue to ensure the systems perform their design function. The increase in the allowed penetration percentage does not affect I the accident analysis because testing requirements are more stringent and the '

l higher allowed percentages continue to be below the assumptions of the safety l l analysis. Therefore, the change does not involve a significant reduction in a margin of safety l

l Pursuant to 10 CFR 50.91, the preceding analyses provides a determination that the proposed Technical Specifications change poses no significant hazard as delineated by

10 CFR 50.92.

Environmental Assessment This proposed Technical Specification change has been evaluated against criteria for i and identification of licensing and regulatory actions requiring environmental f

, assessment in accordance with 10 CFR 51.21. It has been determined that the

! proposed change meets the criteria for categorical exclusion as provided for under 10 -

l CFR 51.22(c)(9). The following is a discussion of how the proposed Technical Specification change meets the criteria for categorical exclusion.

10 CFR 51.22(c)(9): Although the proposed change involves change to requirements with respect to inspection or Surveillance Requirements, (i) the proposed change involves No Significance Hazards Consideration (refer b the No Significance Hazards Consideration Determination section of this '

Technical Specification Change Request);

(ii) there are no significant changes in the types or significant increase in the amounts of any effluents that may be released offsite since the proposed change does not affect the generation of any radioactive effluents nor does it l affect any of the permitted release paths; and i

j (iii) there is no significant increase in individual or cumulative occupational radiation

! exposure l <

Accordingly, the proposed change meets the eligibility criteria for categorical exclusion 4

set forth in 10 CFR 51.22(c)(9). Based on the aforementioned and pursuant to 10 CFR i 51.22 (b), no environmental assessment or environmental impact statement need be

, prepared in connection with issusnce of an amendment to the Technical Specifications

incorporating the proposed change.

- -