ML20197H552

Proposed Tech Specs Revising Testing Methodology Used by Vcns to Determine Operability of Charcoal Adsorber in ESF Air Handling Units

ML20197H552
Person / Time
Site:	Summer
Issue date:	12/04/1998
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20197H548	List: ML20197H552 RC-98-0214, Application for Amend to License NPF-12,revising Testing Methodology Utilized by Vsns to Determine Operability of Charcoal Adsorbers in ESF Air Handling Units
References
NUDOCS 9812140134
Download: ML20197H552 (13)

Text

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/ , PLANT SYSTEMS. _GsTM b G B63 - 19 D, cA a ch h-7orana'acec.su = m-%\6Ab. ph.%w e ...

SURVEILLANCE REQUIREMENTS ( -

--t M 4 2 5~ 74, n

1. Verifying tb at the cleanup system satis 5es the in-place testing._-_m ,

acceptance criteria and uses the test procedures ofRegulatory n 1 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 10%. i

2. Verifying, within 31 days after removal, that a laboratory I analysis of a re recentative charcoal sample obtained in accord- -

ance with atory Position C.6.b of Regulatory Guide 1.52, j Revision 2. arch 1978. meets the laboratory testin e criteria l) '

ofANSfiN509-1960, at a re humicity or nycrane 25* , [

6Fitb4methyliodide pe

'on of <1%

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

d. AEer 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 i

reuresentative carbon sample obtained in accordance with Regulatory ,

Pc~sition C.6.b ofRegulatory Guide 1.52, Revision 2. March 1978,- '

meetsthelaboratorytestingcriteria of1NS1y509-1950,atare' avge (nupicity or 70% and 290 witn t.metnvlion, ice Denetration of Iff.

e. Atleast once per18 monthsby: k i

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

rourMn e Elters and charcoal adsorber banks is less than

~

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

2. Verifving that on a simulated SI or high radiation test sihal, the system automatically switches into a recirculatiot 2 ode of eneration with flow through the HEPA Elters and cha2 coal

~ ~

adsorber banks.

3. Verifying that on a simulated SI or high radiation test signal the system starts the normal and emergency air handling systems which pressurize the control room to a positive pressure or, greater than or equal to 1/8 inch W.G. relative to the outside atmosphere and maintains the 1/8 inch W. G. positive with z. maximum of1000 cfm of outside air during @mpressure operation.

E ARer wach complete or partialreplacement of a HEPA 51ter b=1- by verifying that the HEPA Elter banh remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSIN510-1975 while operating the system at a flow rate of 21,270 cfm 10%.

g. After each complete or partial replacement of a charcoal adsorber I baal- by verifying that the charcoal adsorbers remove greater than or ecual to 99.95% ofa halogenated hydrocarbon refrigerant test gas w'nen they are tested in-place in accordance with ANSI N510-1975 while operating the system at a flow rate of 21,270 cfm 10%.

SUMMER-UNIT 1 _

3/4 7-15 AmendmentNo. //,131 9912140134 981204 '

PDR ADOCK 05000395 p PDR .

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_ _ --en AsTWD 3aS 3 -\ a ss, +

• rM REFUELING OPERATIONS " I me.My joaM rw,cep, 9 of e _2.5% ~ ~~

l SURVEILIANCE REQUIREMENTSlContinued)

\ L l 2. Verifying within 31 days after removal that a laboratory '

analysis of a representative carbon sample obtained in /

l

' accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2. March 1978, meets the laboratory testine criteria ofylSI N509-)E80. at a test nyeala (te;aperature of 37_QC 1

3. Verifying a system flow rate of 30,000 cfm i 10% during smem ~

operation wnen tested in accordance with ANSI N510-1975.

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

. pool by verifyine that a laboratory analysis of a representative .i carbon sample oltained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52. Revision 2, March 1978 meets the labora-  !

l tory testine criteda of@M1 N 009-19eu/at a test meeia temterazre] I cotKO. Subsequent to eacn mitial analysis (which must be completed prior to fuel movement or crane operation with loads over the nool),

l curing the period of time in which there is to be fuel or crane '

i 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 o atninmg and analyzing a samule as ,

described above. These subsecuent analvses are to be comuleted ~

i within thi:ty-one (31) days of sample re:noval. l

d. Atleast once per 18 monthsby:

~

1. Verifying that the pressure dron across the combined HEPA and ronchin g Hlters and charcoal adsorber b anks is less than

~

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

2. Verif"ying that on a loss of offsite power test signal, the system automatically starts.

3. Verifying that the system maintains the spent fui pool area at a negative pressure greater than or equal to l/S inches Water Gauge relative to 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 ANSIN510-1975 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 I 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%.

e ST.7LDdER-UNIT 1 3/4 9-13 Amendment No.g,131

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l j PLANT SYSTEMS

, SURVEILLANCE REQUIREMENTS (Continued)

1. Verifying that the cleanup system satisfies the in place testing acceptance criteria and uses the test procedures of Regulatory Positions C.S.a, C.S.c and C.S.d of Regulatory Guide 1.52, i Revision 2, March 1978, and the system flow rate ii., ~ 270 cfm 10%.

2. Vesifying, within 31 days after removal, that a laboratory l

analysis of a representative charcoal sample obtained in accord- i ance with Regulatory Position C.6.b of Regulatory Guide 1.52, l Revision 2, March 1978, meets the laberatory testing criteria of ASTM D38031989, at a relative humidity of 70% and 30*C l

with a methyliodide penetration of <2.5%. '

3. Verifying a system flow rate of 21,270 cfm 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 within 31 days after removal, that a laboratory analysis of a l representative carbon sample obtained in accordance with Regulatory Position C.6.b of Reguletory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D38031989, at a relativo humidity of 70% and 30'C with a methyliodide penetration of <2.5%.

e. At least once per 18 months by: )

1. Verifying that the pressure drop across the combined HEPA and roughing filters and charcoal adsorber banks is less than 6 inches Water Gauge while operating the system at a flow rate of 21,270 cfm i 10%.

2. Verifying that on a simulated Sl or high radiation test signal, the system automatically switches into a recirculation mode of operation with flow through the HEPA filters ano charcoal adsorber banks.

3. Verifying that on a simulated Si or high radiation test signal the system starts the normal and emergency air handling systems 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 c'm of outside air during system operation.

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 10%.

g. After each complete or partial replacement of a charcoal adsorber 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 while operating the system at a flow rate of 21,270 cfm 10%.

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

REFUELING OPERATIONS I SURVElLLANCE REQUIREMENTS (Continued)

, 2. Verifying within 31 days after removal that a laboratory l analysis of a representative carbon sample obtained in l 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% end 30*C with a methyliodide penetration i of <2.5%.

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

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c. Prior to the movement of fuel or crane operation with loads over the f 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-tory testing criteria of ASTM D3803-1989, at a relative humidity of 1 95% and 30*C with a methyl iodide penetration of <2.5%.

Subsequent to each initial analysis (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

{

movement with loads o/er the pool, verify charcoal adsorber i 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 banks 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 Gauge relative to the outside atmosphere during system operation.

e. After each complete or partial replacement of a HEPA filter bank by I 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 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 while operating the system at a flow rate of 30,000 cfm 10%.

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

Documtnt Contrcl D:sk

' - l l Attachment 11 TSP E60005, Revision 1 RC-97-0214 l Page 1 of 6 SAFETY EVALUATION FOR REVISING THE METHODOLOGY FOR

! TESTING THE CHARCOAL ADSORBERS IN THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS 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),

methodology references will be changed from ANSI N509-1980, at a relative humidity of 70% and 25'C with a methyliodide penetration of < 1% to ASTM D 3803-1989, at a relative humidity of 70% an') 30*C with a methyliodide penetration of < 2.5%.

Surveillance Requirements 4.9.'i1.b.2 and 4.9.11.c (for the spent fusi 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 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.

Safety Evaluation A methodology change froi : ANSI N509-1980 to ASTM D 3803-1989 for testing the ESF air handling units charceal adsorbers is being proposed. The ANSI N5091980 methodology utilizes ASTM D 3803-1979. The essential elements of the current testing 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.

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Docum:nt Control D sk l Attachment ll TSP 960005, Revision 1 1 RC-97-0214 Page 2 of 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 *here will be no degradation in the ability of the components to perform their design t, iction.

The differences are addressed individually below.

Test Medium Temperature Increase From 25*C To 30*C (Control Room Only) i This change proposes to change the VCSNS test medium temperature from l 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....," howevar, the ASTM endorses the proposed temperature as a very stringent test which is recommended for qualification of new carbons and the quantification of the degradation of used carbons. Therefore, this change is justified based on the l 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. j Methyl lodide Penetration Acceptance Criteria increased From < 1% to < 2.5%

4 This change proposes to revise the VCSNS methyl iodide penetration acceptance criteria from < 1% to < 2.5%. The VCSNS calculations that form the design basis for the control room and fuel handling building ventilation plenums assume a 95% radioiodine removal efficiency of the carbon. Therefore, the l 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 38031979 (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 NaSonal Engineering Laboratory ( .iL), it 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 increased (to 20% for used carbons

[20% is not feasible based on the safety analysis assumptions) and 3% for new carbons).

Methyl lodide Penetration Acceptance Criteria Decreased From s 3.0% to

< 2.5% (Soent Fuel Pool Ontv)

Deleted.

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Document Control D sk AttachmGnt ll TSP 960005. Revision 1 RC-97-0214 4

Page 3 of 6 f Methyl lodide Feed Period Dacreased From 120 Minutes To 60 Minutes 4

This change proposes to decrease the methyl iodide feed period from 120

! minutes to 60 minutes as recommended by ASTM D 3803-1989. This change will not affect the test results because the methyliodide adsorption effectiveness of the carbon is the same for a 60 minute feed time as it is for a I

i 120 minute feed time as shown in laboratory testing. This change is justified l based on the independence of the test results from a 120 minute to a 60 minute

. feed time.

i Elution Period Decreased From 240 Minutes To 60 Minutes

This change proposes to decrease the elution (post-sweep) period from 240 I l minutes to 60 minutes as recommended by ASTM D 3803-1989. This change j

$ verifies the effectiveness of the retentive capability of the carbon. This change j

will not affect the test results because the retentive capability of the carbon is  ;

i

' the same whether the elution time is 60 minutes or 240 minutes as shown in i laboratory testing. This change is justified based on the independence of the test results from a 240 minute to 60 minute elution time.

{ 16 Hour Pre-Eauilibration Period Added 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 l

recommended by ASTM D 38031989. This change was made to be l

conservatively representative of the worst case accident conditions by allowing i 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 2

responsible for the increased penetration percentage results that are obtained.

INEL Report, EGG-CS-7364, recommended that the NRC increase the allowed penetration requirements. This change is justified because it conservatively

. encompasses postulated accident condtions that can be applied to the i adsorber.

j 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 /> 4 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 i

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 addtion 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.

a Documtnt Control Desk Atttchm2nt ll TSP 960005, Revision 1 RC-97-0214

Pago 4 of 6 l

Overall this change applies a more restrictive testing methodology to the ESF air hancling 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 l streams. The single test method described is for application of both new and used l

carbons....The conditions employed were selected to approximate operating or accident condtions of a nuclear reactor which would severely reduce the performance of the l 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 l the degradation of used carbons." I As stated in the above paragraph, ASTM D 38031989 contains stringent testing I requirements. These requirements are being adopted at VCSNS as stated in the  !

emergency Technical Specification change submitted and approved on February 10, l 1996. The new testing requirements will provide assurance that the charcoal adsorbers I used in the VCSNS ESF air handling units will perform their designed safety function.

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Document Control Desk Attachment ll TSP 960005, Revision 1 RC-97-0214 Page 5 of 6 1

CONTROL ROOM l l

l CURRENT TECH SPEC PROPOSED TECH SPEC l REQUIREMENT REQUIREMENT DIFFERENCES l i

70% Relative Humidity 70% Relative Humidity None l 1

1 test medium temperature of test medium temperature of increase in test medium 25'C 30*C temperature from 25*C to 30*C methyliodide penetration methyliodide penetration increase allowed methyl l of < 1% of < 2.5% iodide penetration from

< 1% to < 2.5%

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

1 1

240 minute elution period 60 minute elution period 180 minute decrease in elution period 1

1

, 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 /> l carbons l l

l l

l 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 i

hours for new carbons hours for new and used equilibration period carbons

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a 4

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Document Contrcl Desk Attachment 11 TSP 960005, Revision 1 RC-97-0214

~ Page 6 of 6 SPENT FUEL POOL CURRENT TECH SPEC PROPOSED TECH SPEC REQUIREMENT REQUIREMENT DIFFERENCES l

l 95% Relative Humidity- 95% Relative Humidity None I i

test medium temperature of test medium temperature of None 30*C 30*C methyliodide penetration methyliodide penetration increase allowed methyl of < 1% of < 2.5% iodide penetration from

< 1% to < 2.5%

120 minute methyliodide 60 minute methyliodide 60 minute decrease in feed period feed period methyliodide feed period l 240 minute elution period 60 minute elution period 180 minute decrease in l l 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 j carbons e

i 4

., e~, , .m,  ;-,r

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Documtnt Control D:sk Attachment lli TSP 960005, Revision 1 RC-97-0214

' Page 1 of 3 i

NO SIGNIFICANT HAZARDS EVALUATION FOR REVISING THE SPECIFICATION FOR TESTING THE CHARCOAL ADSORBERS IN THE VIRGIL C. SUMMER NUCLEAR STATION TECHNICAL SPECIFICATIONS 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.

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

methodology references will be changed from ANSI N509-1980, at a relative humidity of 70% and 2500 with a methyliodide penetration of < 1% to ASTM D 3803-1989, at a relative humidity of 70% and 3000 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 3000 to ASTM D 38031989, at a relative humidity of 95% and 3000 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 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.

Beeis for No Sianificance Hazards Consideration Determination Soutn Carolina Electric & Gas Company (SCE&G) has evaluated the proposed changes to the VCSNS TS described above against the Significant Hazards Criteria of 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.

Document Control Drsk

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Attachment lil TSP 960005, Revision 1 RC-97-0214 Page 2 of 3 l

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

The proposed change a. vises 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 1

[ESF] air handling units) to the updated Standard Test Method for Nuclear-l Grade Carbon. The change will not affect the probability of an accident. The I charcoal adsorbers are not initiators of any analyzed event. The change will not i significantly affect the consequences of an accident. The charcoal adsorbers 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 l 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 performing their safety function and meeting the assumptions in the safety analysis. The l change does not affect the mitigation capabilities of any component or system l

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.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated? l The proposed change revises the methodology for testing the charcoal l 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-l 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 alteration of l the plant (no new or different type of equipment wil! 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

, new or different kind of accident from any accident previously evaluated.

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

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

, [ESF) air handling units) to the updated Standard Test Method for Nuclear-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 the accident analysis because testing regiairements are more stringent and the

Document Control Desk Attachment lll TSP 960005, Revision 1 RC-97-0214 Page 3 of 3 higher allowed percentages continue to be below the assumptions of the safety analysis. Therefore, the change does not involve a significant reduction in a margin of safety 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 and identification of licensing and regulatory actions requiring environmental 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 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 reauirements with respect to inspection or Surveillance Requirements, (i) the proposed change involves No Significance Hazards Consideration (refer to 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 affect any of the permitted release paths; and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Based on the aforementioned and pursuant to 10 CFR 51.22 (b), no environmental assessment or environmentalimpact statement need be prepared in connection with issuance of an amendment to the Technical Specifications incorporating the proposed change.

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