ML20202C069
| ML20202C069 | |
| Person / Time | |
|---|---|
| Issue date: | 12/24/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-299, SECY-97-299-01, SECY-97-299-1, SECY-97-299-R, NUDOCS 9802120156 | |
| Download: ML20202C069 (28) | |
Text
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n n n n RELEASED TO THE PDR fs r h J hM8 DW i$.f4;....n. I dat9 initials I u POLICY ISSUE (NEGATIVE CONSENT) December 24.1997 SECY-97-299 EDB: The Commissioners MQM: L Joseph Callan Executive Director for Operations
SUBJECT:
LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL EURPOSE-To inform the Commission that the NRC has determined that testing nuclear. grade activated charcoal to standards other than American Socie'y for Testing and Materials (ASTM) D38031989, ' Standard Test Method for Nuclear-Grade Activated Carbon," does not provide assurance of licensees complying with their current licensing basis as it relates to the dose limits of General Design Criterion (GDC) 19 of Appendix A to 10 CFR Part 50 and Subpart A of 10 CFR Part 100. Therefore, the staff proposes to send a generic letter to licensees requesting that those licensees whose technical specifications (TS) do not reference ASTM D38031989 should either amend their TS to reference ASTM D3803-1989 or propose an alternate test protocol and provide the information discussed in the Requested Actions section of the generic letter, Consultation with the Comrni:,sion is warranted because the staff proposes to exercise enforcement discretion in certain situations as discussed in this paper, BACKGROUNQ: Safety related air cleaning units that are part of the engineered safety features (ESF) ventilation systems are used to reduce the potential onsite and offsite consequences of a radiological CONTACT: John P, Segata, NRR To be made publicly available when the C / final SRM is made available. SECY NOTE: In the absence of instructions to the contrary, SECY will notify the staff on January 12, 1998, that the Commission, by negative consent, assents to the action proposed in this paper. hH k G-lGO suai! 39no47 t 4-//a m /2 5, N dif~ g g g'..j' 'g l A 9002120156 971224 ,anww, ~.. PDR SECY M nmana 5 - SSSSSSSSS
I The Commissioners 2 accident at a nuclear power plant by adsorbing radiolodine. Design-basis accident analyses assume a particular ESF charcoal filter adsorption efficiency when calculating offsite and control room operator doses. To ensure that the charcoal filters in these systems will have a filter adsorber efficiency greater than that assumed in the design basis accident analysis, most licensees of operating plants have a TS requirement to perform a periodic laboratory test on o samples c he charcoal extracted from the air cleaning units. The laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumed in the accident analysis is still valid at the end of the Operating cycle. DISGMSSION Licensees of four plants (V.C. Summer, Davis Besse, Oconee, and Brunswick) determined that tests they performed were not in compliance with their TS (see Enclosure 1 of the generic letter for deta4) The TS for the four plants required a test in which the temperature of the gas stream is instantaneously increased. This results in water condensing on the charcoal, thereby causing the test to be aborted (to fail). The four licensees modified the testing method to perform the TS surveillance at a constant temperature and/or utilized a newer test method. Although each of the four licensees performed modified tests that were intended to test the capability of their charcoal, in doing this, they failed to comply with their TS. Licensees of three of the four plants (V.C. Summer, Davis Besse, and Ocenee) submitted emergency TS amendment requests (which were approved by the staff) to establish compliance. Rather than submit an emergency TS amendment, the licensee of the fourth plant (Grunswick) immediately transported a charcoal sample to a testing laboratory to perform a test in accordance with its TS before restarting a unit. However, in order to perform the TS test, the fourth plant had to modify the TS test to thermally equilibrate the charcoal before introducing - the challenge gas. Although such testing does not cause condensation in the test rig, it is not acceptable because the results are not easily reproducible, and even when the test is successfully completed, the results may not be representative of the charcoal's capability. The licensee has not requested a TS amendment to correct the problem and is awaiting guidance from NRC. tJRC's and the nuclear industry's understandings of the appropriate laboratory tests for nuclear-grade charcoal have evolved over the years since the issuance of Regulatory Guide (RG) 1.52 " Design, Testing, and McIntenance Criteria for Postaccident Engineered Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants," which is referenced in many pe,t TS. It was initially assumed that high-temperature /high-relative humidity (RH) conditions were the most severe. Later, with more testing experience, it became clear that the most conservative test is performed at low temperature /high humidity. The use of test protocols other than ASTM D3803-1989 or inappropriate test conditions can lead to an overestimation of the charcoal's ability to adsorb radioiodine following an accident. As a result of the emergency TG changes, the staff performed an internal survey of TS of operating plants to determine whether other plants have the potential for similar compliance problems. The survey indicated that at least one third of operating reactor licensees ms.y be out of compliance with their TS. Although_their TS reference RG 1.52 or American National i
~.... - The Commissioners 3 Standards Institute (ANSI) N509-1976," Nuclear Power Plant Air-Cleaning Units and R Components,' the licensees may have used later versions of the standards for the laboratory 1 tests of their nuclear-grade charcoal. On the basis of this survey, the staff established the E following four groups of plants: (1) plants in comphance with their' 3 that test in accordance with ASTM D3803-1989 (2) plants in compliance with their TS that test in accordance with a test protocol othe-than 1 ASTM D3303-1989 (?) plants not in compliance with their YS that test in accordance with ASTM D3803 e } (4) plants not in compliance with their TS tnat test in accordance with a test proto: ,an J ASTM D3803-1969 P Group 1 plants are not of concem; Group 3 rnd 4 plants have TS com, s oce problems; and Group 2 and 4 plants have technically ineffective testing standard problems. To address these four groups of licensees, the staff developed the attached generir,letter. The generic letter has been endorsed by the Committee to Review Generic Requirements (CRGR), and w!'5 ComrnisrM approval, wili be made available for public comment. The generic letter proposes to exercise enforcement discretion for licensees in Group 3. When licensees in Group 4 test their charcoal in accordance with ASTM D3803-1989 as requested in the generic letter, they become licensees in Group 3 and are eligiole for enforcement discretion. L Recent available laboratory test results for more than 50 chamoal samples demonstrated that there were significant differences in filter efficiencies for aoout 15 to 20 percent of the tested samples when comparing the test results from ASTM D3803-1979 and ASTM D3803-1980. When the charcoal samples were tested in accordance with ASTM D3803-1979, they always appeared to have very high officbncies. However, when the same charcoal samples were tested in accordance with ASTM D3803-1989, significant reduction in efficiency was noted for about 15 to 20 percent of the tested samples. Depnding on the system arrangement, this reduction in filter efficiency can result in calculated doses to the c -*rol room operators exceeding the GDC 19 limits by as much as a factor of 1.5 to 2 F x pressurized-water reactors (PWRs) with secondary containments an i ts all boiling-water ructors (BWRs), this reduction in filter efficiency can result in offsite iodine doses from a filtered pathway increasing by as much as a factor of 10 to 15. On the basis of thesa test results, the staff believes that most licensees have relatively new charcoal that i' in good c;ndition. However, the staff believes that a few licensees have old charcoal that is degraded and their TS-required test is ineffective in iden'ifying the degradation. As a result, the staff has determined that testing of nuclear-grade activated charcoailo etandards other than ASTM n3803-1989 does not provide g~ assurance for compiying with the plant's licensing basis as it relates to the doso limits of GDC 19 and Part 100. [ The staff proposes to resolve this situation by first issuing a pneric letter to all licensees. The generic letter will reaueat all licensees to review their TS to identify their current TS requirements for the laboratory testing of charcoal semples for esch ESF ventilation system. z -J
The Commissiones 4 Licensees whose 'iS do not reference ASTM D3803-1989 will be requested to either amend their TS to reference ASTM D3803-1989 or to propose an alternate test protocol and provide the information discussed in the Requested Actions secdon of the attached generic letter. A y sample TS is enclosed with the generic letter foi licencees proposing a license amendment. The staff will process license amendment requests in the normal manner, with an opportunity for hearing. This course of action may result in a situation in which a licensee is not its compliance with its TS until the staff 0 9 cesses the license amendment. 8:.cause of the (1) conflicting guidance, (2) complex and ambiguous standards, and (3) licensee belief that using later versions of the standard would satisfy their TS requirements, the staff does not believe that licentees in Group 3 should be cited for willful violation of their TS. Therefore, the staff intends to exercise enforcement discretion, consistent with Section Vll.B.6 of the C Enforcement Policy, for all licensees in Groups 3 and 4, provided that e within 60 days of the date of the generic letter, either charcoal samples are tested in accordance with ASTM D3803-1989 and the results meet the current TS accepance criteria or all of the charcoalis replaced with new charcoal that has been tested in accordance with ASTM E,3803-1989; e acceptable charcoal sample test results discussed in the fWt condition aro submitted to NRC within 60 :iays of the date of the generic letter; e a TS amendment request is submitted to NRC within 60 days of the date of the letter; and 9 the charcoal camples continue to be tested in accordance with ASTM D3803-1989 unt;l the 1S amendment is approved by NRC. In cases in which the charcoal samples were previously tested in accordance with . ASTM D3803-1989 during the last scheduled laboratory test and the results met the current TS acceptance criteria (Group 3), the results can be used to satisfy the first condition above. On the basis of the available laboratory test results, the staff believes that most charcoal in use is not degraaed to an extent that would adversely affect control room habitability or public health and safety. This confidence in charcoal performance, and the low probability of a design-basis accident, justify the time frames for the resolution of this rratter. As a longer-term action, the s 7tii* considering increasing its efforts to complete a revision to RG 1.52. The staff prepared Rev. son 3 to RG 1.52 in 1993 but has not yet issued it for public cor.1 ment because of higher p iority work. However, just issuing a new revision of the regulatory guide will not solve the problem, because the TS for licensees in Groups 3 and 4 refer to a specific revision of RG 1.52. Therefore, licensees would still have to change their TS to refer to the proper revision of the regulatory guide. The Office of Enforcement willissue an Enforcement Guidance Memorandum to reflect the enforcement discretion described in this paper.
The Commissioners 5
SUMMARY
Within 10 working days from the date of this paper, unless instructed otherwise by the Commission, the staff will seek public comments on the attached generic letter which will: (1) request alllicensees to determine whether their TS relerence ASTM D3803-1989 for laboratory testing of charcoal filters, (2) request licensees whose TS do not reference ASTM D3803-1989 to either amend their TS to reference AOTM D3803-1989 or propose an alternative test protocol and provide the information discussed in the requested actions section of the generic letter, and (3) permit the exercising of enforcement aiscretion for all licenr.ees in Groups 3 and 4 provided they meet the above-mentioned conditions. COORDINATION The Office of the General Counsel (OGC) has reviewed this paper and has no legal objection to its contents, L. Jdhph Callan Exe sutive Director for Operations
Attachment:
Proposed Generic Letter to Licensees " DISTRIBUTION. Commissioners OGC OIG OPA OCA-CIO CFO EDO REGIONS SECY I
1 l l \\' ATTACHMENT 1 { UNITED STATES NUCLEAR REGULATORY COMMISSION - OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20355-0001 (Date} NRC GENERIC LETTER 97-XX: LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL Addressees All holders of operating licensea for nuclear power reactors, except those who have permanently ceased ops,ations and have cer;ified that fuel has baen permanently removed from the reactor vessel. Puroose The U.S. Nuclear Regulatory Cummission (NRC) is issuing this generic letter to: i (1) A'ert addressees that the NRC has determined that testing nuclear-grade activated charcoal to standards other than American Society for Testing ar;d Materials (ASTM) D3803-1989, " Standard Test Method for Nuclear-Grade Activated Carbon," does not provide assurance for complying with their current licensing basis as it relates to the dose limits of General Design Criterion (GDC) 19 of Appendix A to 10 CFR Part 50 and Subpart A of 10 CFR Part 100. In addition, the staff has determined that ASTM D3803-1989 should be used for both new and used charcoal because it allows for accurately monitoring the degradction of the charcoal over time. (2) Request that all addressees determine whether their tec'inical specifications (TS) reference ASTM D3803-1989 for charcoal filter laboratory testing. Addressees whose TS do not reference ASTM D3803-1989 should either amend their TS to reference ASTM D3803-1989 or propose an attemative test pwtocol and provide the information discussed in the rquested actions. (3) Alert addressees of the staff's intent to exercise enfoitement diser6;.on under certain r,onditions. (4) Require the C andressees send the NRC written responses to this generic letter, relating to irrA...antation of the requested actions. ,Backcround Safety-related air-cleaning units used in the engineered safety feature (ESF) ventilation systems of nuclear power plants reduce the potential onsite and c,ffsite censequences of a radiological accident by ac'sorbing radioiodine. To ensure that the charcoal filters used in these systems will perform in a manner that is consistent with the licensing basis of a facility, most licensees have
GL 97 XX (Date) Page 2 of 10 requirements in their facility TS to petdically test (in a laboratory) samples of charcoal taken from the air-cleaning units. The NRC's and the nuclear industry's understandings of the appropriate laboratory tests for nuclear. grace charcoal ieve wolved over the years since the issuance of Regulatory Guide (RG) 1.52, " Design, Testing, and Maintenance Criteria for Postaccident Fagineered-Safety Feature Atmosphere Cleanup System Air Filtraticn and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," which is referenced in many plant TS. It was initially assumed that high-temperature /high-relative humidity (RH) conditions were the most severe. Later, with more testing experience, it became clear that the most conservative test is at low temperature /high humidity. l nic use of outdated test protocols or inappropriate test conditions can lead to an overestimation c' the charcoal's ability to adsorb radioiodine following an accident. Problems associated with the performance of the I..aratory tert of charcoal under inapprop;iate test conditions were discussed in Attachment 1 of C. nation rJotice (IN) 86-76. Attachment 1, ' Summary of Control Room Habitability Reviews," noted that charcoal was being tested at much higher temperatures than any expected during the course of an accident, and that the performance of the laboratory test at that temperature can result in erroneously high efficiency measurements. In 1982, the Amencan Society of Mechanical Engineers (ASME) Committee on Nuclear Air and Gas Treatment (CONAGT) conducted an inter-laboratory comparison t,st using ASTM D3803-1979 and found that seven U.S. laboratories and eight foreign laboratories obtained vastly different results when testing samples of the same charcoal. After effc ts to resolve the differences failed, the NRC contracted with EG&G at Idaho National Engineering Laboratory (INEL) to assess the problem. As a result of this assessment, the NRC issued IN 87-32. Through IN 87-32, the NRC informed licensees of deficiencies in the testing of nuclear-grade charcoal, specifically noting serious problems with the capabilities of the testing laboratories and with the testing standard (ASTM D3803-1979). The NRC contractor detailed the specific problems in its technical eva!uation report, EGG-CS-7653, " Final Technical Evaluation Report for the NRC/INEL Activated Carbon Testing Program." Specifically, EG&G reported that ASTM D3803-1979 had unacceptable test parameter tolerances and instrument calibraSon requirements, and that ASTM D3803-1979 was nonconservative in not requiring humidity pre-equilibration of used charcoal. The information notice indicated that the protocol developed by EG&G could be utilized for performing the laboratory test until the D-28 committee responsible for ASTM D3803 revised the standard. The committee completed the ievision and issued it in December 1989. The problems associated with the testing laboratories were resolved after the number cf U.S. firms performing such tests diopped from seven to the current two. On April 29,1993, representatives from ASME and CONAGT met with the NRC staff to express their concerns about laboratory testing of charcoal. CONAGT discussed the "sriation in laboratory test results obtained (methyl iodide penetration) when temperature, RH, face velocity, bed depth, test protocol, and impregnate were varied. CONAGT stated that ti,e 1989 version of ASTM D3803 is the only acceptable test method for TS applications and compared the results of laboratory tests performed using the 1988 version of ASTM D3803 (which is the 1979 version l
GL 97 XX s -{Date} Page 3 of 10 I with editorial changes) to results using the 1989 version. The results from the 1986 protocol ~ showed significantly higher lodine-removal capabilities than the results from the 1989 version. In addition, CONAGT indicated that testing charcoal at temperatures greater than 30'C [8v F) almost always results in the charcoal meeting the TS seceptance criteria, even when the charcoal is deficient. To support this promise, CONAGT preser,ted the results of laboratory tests conducted at temperatures of 30'C [86'F),80'C (176'F], and 130'C [266'F). The data show significant increases in iodine-removal capabilities as the test temperature increases, CONAGT indicated that all systems located outs'de of centainment should be tested at 30'C [86'F], which is more representative of the limiting accident conditions. Tests conducted at 80'C [176'F] or 130'C [266'F] are inappropriate because tests at these temperatures result in the regeneration of the charcoal. At elevated temperatures, the charcoal contains less moisture than at 25'C [77*F] and 30'C [86'F] which results in the chatcoal having more surface area available for adsorption of iodine. Therefore, testing at the elevated temperatures results in an overestimation of the actual iodine-removal capability of the charcoal, and testing at 25'C [77'F] or 30*C [86'F] gives results that represent a more realistic assessment of the capability of the charcoal. CONAGT concluded its presentation bij atating that the major - problems associated with the laboratory test of charcoal are the designation of the test protocol ard the TS that designate the test to be performed. On November 6,1996, the staff visited the two remaining laboratories that test nuclotr-grade e activated charreal, NCS Corporation and NUCON International, Inc.. Both laboratories have resolved the poor reproducibility problem identified in the EG&G report by performing all tests with calibrated equipment that is capable of maintaining the tight tolerances of the test parameters as specified in ASTM D3803-1989. Tight tolerances are very important when tests are performd at high RH, because slight variations in RH result in unacceptably large - differences in the tested efficiency of the char::oal. Discussion Although some licensees have changed their TS to reference the latest testing standard (ASTM D3803-1989), many still use outdated standards and/or test conditions that may overestimate the capability of the charcoal in their ESF systems, As a result, the ability of the charcoal filters in these systems to perform in a manner consistent with the licensing basis for the facility may be in ouestion. ' The licensees of four plants (V.C. Summer, Davis-Besse, Oconee, and Brunswick) determined that the tests they performed were not in compliance with their TS and submitted emergency TS amendments (see Enriosure 1 for details). As a result of the emergency TS changes, the staff has performed an intemed survey of the TS of operating plants to determine whether other plants have the potential for similar compliance problems. The survey indicated that at least one-third of operating reactor licensees may be out of compliance with their TS because, although the plant TS reference RG 1.52 or American National Standards Institute (ANSI) N509-1976, " Nuclear Power Plant Air-Cleaning Units and Components," tte licensees may have m
L GL 97-XX {Date} Page 4 of 10 used later versions of the strndards for the laboratory tests of their nuclear-grada charcoal. On the basis of this survey, the waff established the followinre four groups of plants: (1) plants in compliance with their TS that test in accordance with ASTM D3803-1989 (2) plants in compliance with their TS that test in accordance with a test protocol other than ASTM D3803-1989 (3) plants not in compliance with their TS that test in accordance with ASTM D3803-1989 (4) plants not in compliance with their TS that test in accordance with a test protocol other than ' ASTM D3803-1989 Licensees in Group i have TS that require charcoal to be tested in accordance with ASTM D3803-1989, which adequately demonstrates the capabi"ty of the charcoal. As discussed in Enclosure 1, the staff considers ASTM D3803-1989 to be the most accurate and most realistic protocol for testing charcoal in ESF ventilation systems because it offers the greatest assurance of accurately and consistently determining the capability of the charcoal. For example, it requires the test to be performed at a constant low temperature of 30'C [86'F]; it provides for smaller tolerances in temperature, humidity, and air flow; and it has a humidity - pre-equilibration. Licensees in Group 2 have TS that require charcoal to be tested in accordance with test standards other than ASTM D3803-1989. On the basis of available laboratory test results for more than 50 charcoal sampics, J.lere were significant differences in filter efficiencies for about 15 to 20-percent of the tested samples when comparing the test results from ASTM D3803-1979 and ASTM D3803-1989. When the charcoal samples were tested in accordance with ASTM D3803-1979, they always appeared to have very high efficiencies. However, when the some charcoal samples were tested in accordance with ASTM D3803-1989, - significant reduction in efficiency was noted. Depending on the system arrangement, this reduction in filter efficiency can result in calculated doses to the control room operators exceeding the GDC 19 limits by as much as a factor of 1.5 to 2. For pressurized-water reactors (PWRs) with secondary containments and for all boiling-water reactors (BWR ), this reduction in filter efficiency can result in offsite doses from a filtered pathway increasing by as much as a factor of 10 to 15. As a result, the testing of nuclear-g.ade activated charcoal to standards other ' than ASTM D3803-1989 does not provide assurance for complying with the plant's licensing basis as it relates to the dose limits of GDC 19 and Part 100. In addition, the staff has determined that ASTM D3803-1989 should be used for both new and used charcoal because it allows for accurately monitoring the degradation of the charcoal over time. The original rationale for testing used and new charcoal differently was the belier that a long equilibration period would regenerata the used charcoal by removing contaminants adsorbed by the charcoal during normal plant use. However, an EG&G technical evaluation report, described in Enclosure 1, demonstrated that this is not true. As a result,- ASTM D3803-1989 specifies testing both used and new charcoal in the same manner. C e
F 1 GL 97 XX {Date} Page 5 of 10 Currently, before shipping, suppliers test mcst new charcoal with the ASTM D38031989 protocol at 30'C [88'F] and 95-percent RH in addition to the test protocol ar.d test conditions the addressee records on the purchase order. The results from the new charcoal tested via ' ASTM D3803-1989 present a solid baselirie for the initia; capability of the charcoal. Using ASTM D3803-1989 to test used charcoal is a very accurate and reproducible method for determining the capability of the charcoal. By comparing the results of the used charcoal tests with the new charcoal test baseline, the addressee can be certain of the charcoal's level of _ degradation. Analyses of design-basis accidents assume a particular engineered safety features (ESF) ] ~ harcoal filter adsorption efficiency when calculating offsite and control room operator doses. c Licensees then test charcoal fitter samples to determine whether the filter adsorber efficiency is greater than that assumed in the design-basis accident analysis.- The laboratory test : acceptance criteria contain a safety tactor to ensure that the efficiency asssumed in the accident analysis is still valid at the end of the operating cycle. Be;ause ASTM D3803-1989 is a more accurate and demanding test than older tests, addressees that upgrade their TS to this new protocol will be cble to use a safety factor as low as 2 for determining the acceptance criteria for charcoal filter efficiency. This safety factor can be used for systems with or without humidity control because the lack of humidity control is already accounted for in the tes: conditions (systerns without humidity control test at 95-percent RH and systems with humidity control can test at 70-percent RH). The staff has previously approved reductions in the safety foetor for plants adopting the ASTM D3803-1989 standard on a case-by-case basis. (The staff olans to make conforming changes to RG 1.52.) I he licensees that received emergency TS changes were in Groups 3 and 4. Licensees in Groups 3 and 4 have TS that requ'it., cha; cow to be tested in accordance with RG 1.52 or ANSI N509-1976, and are not in compliance with their TS because the specified test protocol can not be successfully completed as discussed in Enclosure 1. These licensees are either (1) testing in accordance with the desired ASTM D3803-1989 (Group 3) or (2) using earlier revisions of ASTM D3803 or an older standard which they believe are acceptable (Group 4). 4 The staff does not have confidence that the results from RG 1.52 or ANSI N509-1976 meet the intent of the TS which is to ensure that the doses are within the required limits. Therefore, licensees in these groups have not adequately demonstrated compliance with their licensing basis as it relates to the dose limits of GDC 19 and Part 100. The staff believes that (1) conflicting guidance, (2) complex and ambiguous standards, and (3) licensee belief ti.at using later versions of the standard would satisfy their TS requirements, contributed to confusion regarding charcoal testing. These factors may explain why licensees did not adopt ASTM D3803-1989 (See Enclosure, for further discussion). In addition, based on the available laboratory test results, the staff believes that most charcoal in use is not degraded c to an extent that would adversely affect control room habitability or public health and safety. This ccnfidence in charcoal performance and given the low probability of a design basis 4 q
GL 67-XX {Date} Page C of 10 accident, justify the time frames for the resc'ution of this matter. Therefore, the staff intends to exercise enforcement discretion, consistent with Section Vll.B.O of the Enforcement Policy, for all addressees in Groups 3 and 4, provided: A e Within 60 days of the date of this generic letter, either charcoal samples are tested in accordance with ASTM D3803-1989 and the results meet the current TS acceptance criteria or all of the charcoal is replaced with new charcoal that has been tested in accordance with ASTM D38031989; e Acceptable charcoal sample test results Jiscussed in the first condition are submitted to the NRC within 60 days of the date of this generic letter, e A TS amendment request is submitted to the NRC within 60 days of the date ci this letter, and e The charcoal samples continue to be tested in accordance with ASTM D3803-1989 until the TS amendment is approved by the NRC. In ceses in which the charcoal samples have been previously teste,d in accordance with ASTM D3803-1989 for the last scheduled laboratory test and tha results met the current TS acceptance criteria (Group 3), the results can be used to satisfy the first condition above. Licensees in Group 2 have been complying with their TS by testing their charcoal in accordance with their TS. Thorefore, enforcemeat discretion is not required. Recuested Actions Addressees are requested to take the followhg actions: 1. If your current TS require the laboratory testing of charcoal samples for each ESF ventilation system to be conducted in accordance with ASTM D3803-1989, then no TS amendment is required. 2. If your current TS do not require the laboratory testing of charcoal saniples to be conducted in accordance with ASTM D3803-1989, then: (1) Your charcoal samples should be tested in accordance with ASTM D3803-1989 and the results should be submitted to the NRC within 60 days of the date of this generic letter. If your charcoal samples were alrecjy tested in accordance with ASTM D3803-1989 for the last scheduled laboratory test and the results met the currsnt TS acceptance criteria, then the results should be submitted to the NRC within 60 days of the date of th' generic letter, in either case, the charcoal samples should continue to be tested in accordance with ASTM D3803-1989 ur.til the TS amendment is approved by the NRC, and
GL 97 XX {Date) Page 7 of 10 (ii) Your TS shou'd be amended to require the laboratory testing of charcoal samples to be conducted in accordance with: (a)- ASTM D38031989, or - (b) An altemate test protocol should be proposed for the laboratory testing of charcoal and the following information should be submitted for staff review to determine the acceptability of the altemate protocol: 1. s,ummary of the test method - 2. precision of the method - 3. description of the test apparatus along with tolerances 4. parameter specifications 5. material requirements 6. hazrrds 7. preparation of the apparatus before initiation of the test 8. calibration requirements of the test equipment - 9. test procedure
- 10. manner of calculating ponstration and error 11, repeatability and reproducibility of the res-. for 1-percent and 10-percent -
penetration and the penetration at a 9P,,ercent confdonce interval for-charcoal tested at 70-percent RH and at 95-percent dH 12 bias associated with the method
- 13. results from an independent laboratory which demonstrate that the attemate test protocol gets results that are consistent with, or more conservative than,-
that associated with ASTM D3803-1989 The demonstration identified in item 13 above should be based upon a series of tests comparing the altemate test prutocol and ASTM D3803-1989, and it should apply to both new and used charcoal tested at 70-percent RH and at 95-percent - RH. The independent laboratory should be able to demonstrate that the attemate protocol is at least as conservative as ASTM D3803-1989, and should be able to perform the ASTM D3803-1989 test and achieve repeatable and reproducible resuits. The laboratory should 6,ot be engaged in the measurement of iodine penetration of charcoal as a business either for TS compliance purposes or for the sale and/or production of activated charcoal for nuclear power plant applications. Reauested Information 'Nithin 60 days of the date of this generic letter, addressees are requested to provide to the NRC the following information: 1. Identify the current TS requirements for the laboratory testing of charcoal samples for each ESF ventilation system including the specific test protocol, temperature, RH, and penetration at which the TS require the test to be performed. If your current TS specifically require testing in accordance with the ASTM D3803-1989 protocol, and you have been testing in accordance with this standard, then no additional information is required. s
l GL 97-XX {Date) Page 8 of 10 2. If you choose to adopt the ASTM D3803-1989 protocol, then submit a TS amendmerit request to require testing to this probcol. The request should contain the test temperature, RH, and penetration at which the proposed TS will require the test to be performed and the basis for these values. If the system has a face velocity greater than 10 percent of 0.203 m/s (40 ft/ min), then the revised TS should specify the face velocity. Also, indicate when the next laboratory test is scheduled to be performed. (Enclosure 2 is a sample TS that the NRC considers acceptable.) 3. If you are proposing an attemate test protocol, then address the attributes discussed in Section 2(ii) of the Roquested Actions and submit a TG amendment request to require testing to this alternate protocol The request should contain the test temperature, RH, and penetration at which the pioposed TS will require the test to be performed and the basis for these values. If the system has a face velocity greater than 10 percent of 0.203 m/s [40 ft/ min), then the revised TS should specify the face velocity. Also, indicate when the next laboratory test is scheduled to be performed. Roouired Resoonse Within 30 days of the date of this generic le'ter, aadressees are required to submit a written response indicating: (1) whether the requested actions will be completed, (2) whether the requested infonnation will be submitted and (3) whether the raquested information will be sub-mitted within the requested time period. Addressees who choose not to complete the requested actions, or choose not to submit the requested information, or are unable to satisfy the requast-ed completion date, must desenbe in their responsa any attemative course of action that is proposed to be taken, including the basis for establishing the acceptability of the proposed alternative course of action and the basis for continued operability of affected sys+ ems and components as applicable, Address the required written response to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, under oath or affirmation, under the provisions of Section 182a, Atomic Energy Act of 1954, as amended, and 10 CFR 50.54(f). In addition, send a copy to the appropriate regional administrator. Backf L Discussio_Lrl Appendix A to 10 CFR Part 50, General Design Criteria (GDC) for Nuclear Power Plants, and the plant safety antlyses require and/or commit that licensees design and test safety-related structures, systems and components to offer adequate assurance that they can perform their safety functiona. Specifically, GDC 19 of Appendix A to 10 CFR Part 50 specifies dose limits to ensure ' hat control room operators are provided with adequate radiation protection under accident conditions Following the accident at Three Mile Island (TMI), TMI Action Plan item lil.D.3.4," Control Room Habitabil'r.y Requirements,"as specified in NUREG-0737," Clarification of TMI Action Plan Requirements," required alllicensees to perform evaluations and identify appropriate modifications to ensure that control room operators are adequately protected from the release of radioactive gases and that the nuclear power plant can be safely operated or shut down under design-basis accident conditions (GDC 19). When modifications were proposed by licensees, the NRC issued Orders confirminfj licensees commitments. As a result, all licensees l ___.__-_-__m-
GL 97-XX {Date} Page 9 of 10 - are required to meet the dose limits of GDC 19. In addition, Subpart A of 10 CFR Part 100 specifies reference dose values which can be used in the evaluation of the suitability of - proposed sites for nucicar power plants with respect to potential reactor accidents that could result in the release or significant quantities of radioactive fission products. The expectation is that the site location and the engineered safety feature included as safeguards against the hazardous consequences of an accident, should one occur, ensure a tisk of public exposure, in this regard, Imensees commit to dose limits that can be used as the basis for - assessing the performance of safety-related structures, systems and components. Accordingly, licensees are required to test the nuclear-grade activated charcoal of their engineered safety feature ventilation systems in accordcnce with a suitable testing standard to ensure that the chawoal filters are capable of performing their required safety tunction and that the licensing bases of their respective facilities regarding onsite and offsite dose consequences continue to be satisfied. The actions requested in this generic letter are considered compliance backfits under the provisions of 10 CFR 50.109. If some " ensees test their che.rcoal in accordance with their TS which reference an outdated test stano a the staff does not have confidence that the results of those tests will demonstrate compliance with the plant's licensing basis as it relates to the dose . requirements of GDC 19 and Part 100, including commitment to the resolution of TMI Action Plan item lil.D.3.4. Therefore, the staff has endorsed the testing standard ASTM D3803-1989 for referencing in plant TS. In accordance with the provisions of 10 CFR 50.109(a)(4)(l), .regarding compliance backfits, a full backfit analysis was not performed. However, an evaluation was performed in accordance with NRC procedures, including a statement of the objectives of and reasons for the requested actions and the basis for invoking the compliance . exception and is reflected in this backfit discussion. EederalReaisterNotification A notice of opportunity for public comment will be published in the Federal Registen Eaoerwork Reduction Act Staterrtant This generic letter contains information collections that are subject to the Paperwork Reduction ' Act of 1995 (22 U.S.C. 3501 at seq.). These information collections were approved by the Office of Management and Budget, approval number 3150-0011, through August 31,2000. The public reporting burden for this collection of information is estimated to average 40 hours . per response, including the time Sr reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The U.S. Nuclear Regulatory Commission is seeking public comrnent on the potential impact of the collection of information contained in the generic letter and on the following issues: (1) - Is the proposed collection of information necessary for the proper performance of tim . fur'.cticns of the NRC, including consideration of whether the information will have practical udlity? c
GL 97-XX (Dato} l Page 10 of 10 (2) is the estimate of burden accurate? (3) is there a way to enhance the quality, utility, and clarity of the information to be collected? (4) How can the burden of the collection of information be minimized, including consideration of the use of automated collection techniques? Send comments on eny aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch, T-6 F33, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the Desk Officer, Office of Information and Regulatory Affairs, t!EOB-10202 (3150-0011), Office of Management and Budget Washington, D.C. 20503. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of ir. formation unless it displays a currently valid OMB control number. If you have any questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager. Sincerely, Jack Roe, Acting Directot Division of Reactor Program Mar.agement Office of Nuclear Reactor Regulation Technical contacts: John P. Segala, NRR '301-415-1858 Intemet:jps1@nrc. gov Lead project manager: Brenda L. Mozafari, NRR 301-415-2020 Iritemet: bim@nrc. gov
Enclosures:
(1) Background Information on the Laboratory Testirig of Nuclear-Grade Activated Charcoal (2) Sample Technical Specifications i s
t BACKGROUND INFORMATION ON THE LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL CharcoalTestina Reauirements Analyses of design-basis accidents assume a particular engineered safety features (ESF) charcoal filter adsorption efficiency when calculating offsite and control room operator doses. Licensees then test charcoal filter samples to determine whether the filter adsorber efficiency ls greater th6n that assumed in the design-basis accident analysis. The laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumeo in the accident analysis is still valid at the end of the operating cycle. Guidance on the frequency of, ar.d the test method for, the laboratory testing of charcoal appears in vanous documents, including all revisions of Regulatory Guide (RG) 1.52, " Design, Testing, and Maintenance Criteria for Postaccident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants," and other NRC documents on plant technical specifications (TS). Guidance on the laboratory test protocol appears in such standards as American National Standards Institute (ANSI) N509," Nuclear Power Plant Air-Cleaning Units and Components"; ANSI N510, " Testing of Nuclear Air-Cleaning Sctsms"; Military Specification RDT !W 16-1T," Gas Phase Adsorbents for Trapping Radioactive leare and lodine Components"; and American Society for Testing and Materials (ASTM) Standard D3803, " Standard Test Method for Nuclear-Grade Activated Carbon." E All of the standards describe a pre-equilibration period, a challenge period, and an Son period. During the pre-equilibration (pre-sweep) period, the charcoal is exposed to 4 iw of air controlled at the test temperature and relative humidity (RH) before the challenge gas is fed through the charco31. The pre-equiimatien period ensures that the charcoal has stabilized at the specified test temperature and RH for r, period of time, which results in the charcoal adsorbing all available moisture before the charcoal is challengeri with methyl iodide. During the challenge period, air at the test temperature and RH with radio labeled methyl iodide is injected through the charcoal beds to challenge the capability of the charcoal. During the e!ution (post-sweep) period, air at the test temperature and RH is passed through the charcoal beds to evaluate the abi'ity of the charcoal to hold the methyl iodide once it is captured. The ASTM D3803-1980 standard has two additional testing periods that are not required by other standards: the stabi;ization period and the equilibration period. During the stabilization period, air at the test te.c erature is passed through the charcoal beds to bring the system up to the operating temperature before the start of pre-equilibration. During the equilibration period, air at tne test temperature and RH is passed through the charcoal beds to ensure the charcoal adsorbs all the available moieture before the feed period. During this period, the system is more closely monitored than in the pre-equilibration period to ensure that all parameters are maintained within ineir limits. Depending upon the plant's TS, typical test temperatures are usually one of the following: 25'C [77'F),30'C r,86*F),80*C [176*F), or 130*C [266*F). In adoition, the TS usually require e
that the test be conducted at 70-pero at RH if the ESF system controls the RH to 70-percent or lest., or at 95-percent if the RH is not controlled ta 70-percent. The standard technical specificaticas (STS) and many plant-specific TS specify Regulatory Position C.6.a of RG 1.52, Revision 2, as the requirement for the laboratory testing of the charcoal. Regulatory Position C.6.a refers to Table 2 of RG 1.52. Table 2 references Test 5.b of Table 5-1 of ANSI N509-1976," Nuclear Power Plant Air-Cleaning Units ar'd Components." Test 5.b references the test method frorn paragraph 4.5.3 of Military Specification RDT M 16-1T, " Gas Phase Adsorbents for Trapping Radioactive lodine and lodine Components" (date not indicated), but npecifies that the test is to be conducted at 80'C [176*F) and 95-percent RH with preloading and postloading sweep at 25'C [77'F). This test is referred to as the "25-80-25 test." The essential elements of this test are as follows: e 70-percent or 95-percent RH 5-hour pre-equilibration (pre-sweep) time, with air at 25'C [77'F) and plant-specific RH e 2-hour challenge, with gas at 80~ C [176'F) and plant-specific RH e A 2-hour olution (post-sweep) time, with air at 25'C [77'F] and plant specific RH e The latest acceptable methodology for the, laboratory testing of the charcoal is ASTM Standard D3803-1989," Standard Test Method for Nuclear-Grade Activated Carbon." ASTM D3803-1989 is updated guidance based or, an NRC verification and validation effort on ASTM D3803-1979, which is updated guidance based on RDT M 16-1T. The essential elements of the ASTM D38C3-1989 test are as follows: e 70-percent or 95-percent RH 2-hour thermal stabilization, with air r130'C [86* F) e 16-hour pre-equilibration (pre-sweep) time, with air at 30'C [86*F) and plant-specific RH 2-hour equilibration time, with air at 30*C [86'F) and plant-specific RH e e 1-hour challenga, with gas at 30'C [86*F) and plant-specific RH e 1-hour elution (post-sweep) time, with air at 30'C [86'F) and plant-specific RH The major differences between the ANSI N509-1976 and ASTM D3803-1989 standards for charcoal testing are as follows: MAJOR DIFFERENCES ASTM D3803-1989 ANSI N509-1976 Pre Equilibration 30'C [86* F) 25'C[77'F] (Pre-Sweep) Temperature Challenge Temperature 30*C [86* F) 80*C [176*F] Elution (Post Sweep) 30'C [86* F) 25'C [77"F] Temperature Total Pre-Test Equilibration 18 hours 5 hours Tolerances of Test Smal!er Larger Parameters E.
a As stated above, ASTM D3803-1989 challenges the representative charcoal samples at 30'C [86'F] rather than at 80'C [176'F). The quantity of water retained by charcoal is dependent on temperature, and less water is retained as the temperature rises. The water retained by the charcoal decreases its efficiency in adsorbing other contaminants. At 30'C [86'F) and 95-percent RH, charcoal will retain about 40 weight-percent water. At 80*C [176'F] and 95-porceat RH, charcoal retains only about 2 to 3 weight-percent water. Becaust most charcoal is anticipated to be challenged at a temperature closer to 30'C [86'F) rather tht.180*C [176*F), the lower temperature test condition of ASTM D3803-19?9 will yield more realistic results than would a test performed at 80'C [176'F). ASTM D3803-1989 specifies a test temperature of 30'C [86*F) for both the pre and post test sweep rather than 25'C [77'F). There is little difference in the adsorption behavior of charcoal between these two temperatures. A temperature of 25'C [77'F) is more conservative; however, the increase from 25'C [77'F) to 30*C [86*F) does not represent a significant variation in the test results. ASTM D3803-1980 provides results that are reproducible compared to RDT M 16-1T because it has smaller tolerances on various test parameters, and it requires that the charcoal sample be pre-equilibrated for a much longer period. The longer pre-equilibration time is more conservative because it will completely saturate the representative charcoal sample until it is in the condition to which the subject charcoal adsorbers are expected to be exposed during design-basis conditions. Therefore, testing in accordance with ASTM D3603-1989 will result in a more realistic prediction of the capability of the charcoal. TS Testina Reference Laboratory tests of the charcoal are typically required (1) once every refueling outage, (2) when certain events occur that could adversely affect the ability of the charcoal to perform its intended function, and (3) following a defined period of ESF system ope'ation. The TS require demonstration by laboratory testing that the charcoal is capable of performing at a level greater than that assumed in the NRC staff's safety evaluation report. If it fails to perform at that level, the charcoal must be replaced. The determination of the appropriate test conditions, test protocol, and acceptance criteria for laboratory testing of nuclear-grade activated charcoal is frequently not a straightforward process. It sometimes requires a complex joumey through a number of documents to ascertain the appropriate test conditions, test protocol, and acceptance criteria. As described earlier, if the plant has STS, the STS reference Regu!atory Position C.6.a of RG 1.521or the requirements for the laboratory testing of charcoal. Regulatory Position C.6.a refers to Table 2 of the regulatory guide. Table 2 references Test 5.b of Table 5-1 of ANSI N509-1976. Test 5.b from Table 5-1 references the tect method from paragraph 4.5.3 of RDT M 16-1T (date not indicated), but specifies that the test is to be conducted at 80*C [176*F) and 95-percent RH with pre-loading and postloading sweep at 25'C [77'F). This test is referred to as the "25-80-25 test." Also contributing to the potential confusion are the various ways in which TS tre written, and conflicting NRC guidance on testing, particularly NRC letters to the nuclear industry and NRC papers presented at national conferences. This problem arose from the evolving understanding of what constituted an appropriate test. At various times, the NRC has stated that the newest version of a standard can be used and the test can be conducted at a temperature of 30*C [86'F). At other tirnes, the NRC indicated that the TS are requirements and that the tests must be performed at the 25-80-25 conditions. In various forums, the NRC has also stated that a technical argument may be made for using the newer standard. However, in some instances when newer standards were utilized to demonstrate conformance with the TS, the NRC required licensees to submit TS amendment reauests because the newer standards were not referenced E in the TS. Therefore, it is understandable that licensees may be confused about laboratory testing protocols, testing conditions, and acceptance criteria. As a result, many licensees are not testing charccal in accordance with their TS, although the tests they conduct may be more conservative than the tests required by the TS. Additionally, the 25-80-25 test has difficulties in that none of the protocols in any version of RDT M 16-1T or ASTM D3803 addresses performing the laboratory test at multiple temperatures as required by ANSI N509-1976. If the test protocol described in paragraph 4.5.3 of RDT M 16-1T (1973) is followed verbatim, a thermal step change must be made after the 5-hour pre-equilibration period to increase the temperature, from 25*C [77'F) to 80*C [176'F) for the challenge period. The problem with such thermal step changes is that they result in condensation forming on the charcoal. The condensation cf free water in the sample bed is cause for aborting the test, according to the 1977 version of RDT M 16-1T and subsequent versions of ASTM D3803. Therefore, the 25-80-25 test cannot be performed pursuant to any q existing test protocol. a Because paragraph 4.5.3 cannot be followed verbatim, a few licensees have changed the 25-80-25 test to thermally equilibrate the charcoal before introducing the challenge gas. Following the pre-sweep conditioning at 25'C [77'F], the bed temperature is raised to 80*C [176'F) before introducing the challenge gas. Although such testing does not cause condensation in the test rig, it is not acceptable bacause the results are not easily reproducible, and even when the test is successfully completed, the results may not be conservative. Section 2 of ANSI N509-1976 str.tes for the various documents that supplement ANSI N509 that
- he issuance of a document in effect at the time of the purchase order shall apply unless otherwise specified, in the case of charcoal, the purchase order date could be considered the date that the charcoal is procured. Therefore, TS that have the STS wording may allow the licensee the flexibility to use a inore recent labccatory protocol than the 1973 version of RDT M 16-1T, depending en the procurement date for the charcoal, without a TS change.
However, although the flexibility of protocol selection exists, the requirement to perform a 25-80-25 test for those plants that have TS that reference either Revision 1 or Revision 2 of RG 1.52, Table 5-1 of ANSI N509-1976, or ANSI N510-1975 can only be relievert by license amendment. Cateacrization of Plants Since February 1996, the staff has issued thr?e emergcr,cy TS changes to licensees that had determined that the tests they performed were not in compliance with their TS, because the required testing standards and test protocols did not support a test in which the temperature is changed as required by the TS. If the temperature in the test apparatus is changed from 25'C [77'F) to 80*C [176* F] during the test without modifying the test protocol, water condenses on the charcoal, thereby causing the test to be aborted (to fail). The emergency TS changes were issued for the V.C. Summer, Davis Besse, and Oconee facilities. TI e details of these TS changes are discussed below. On February 10,1996, the licenwee for the V.C. Summer Nuclear Station, South Carolina Electric & Gas Company (SCE&G), requested an emergency TS change. The systems involved were the control room emergency ventilation system and the fuel handling building exhaust system. On February 10,1996, the NRC granted the emergency TS change. The emergency TS change was requested because SCE&G had determined that laboratory tests of the charcoal of the control room ventilation system and the fuel-handling building system had not been perfcrmed in compliance with the V.C. Summer TS. The laboratory test perfomied for V.C. Summer was a 25-25-25 test in lieu cf the 25-80 25 required by its TS. - The licensee had been performing the 25-25-25 test becaun, in consultation with its testing laboratory, it concluded that performance of the 25-80 25 test would result in condensation on the charcoal and, thus, an invalid test. On Merch 29,1996, the Toledo Edison Company requested an emergency TS change for the Davis-Besse plant. The systems involved were the hydrogen purge, the shield building emergency ventilation, and the control room. The TS for Davis-Besse required the laboratory test to be performed in accordance with RG 1.52, Revision 2. In this case, the licensee was performing a 30-30-30 test using the tosting protocol of ASTM D3803-1979 in lieu of the 25-80 25 test On March 29,1996, the NRC granted the einergency TS change to allow the 30-30 30 test. a On April 2,1996, Duke Power Company requested an emergency TS change for the Ocnnee Nuclear Station. The systems involved were the reactor building purge, the r* 7t fuel pool _ ventilstion, and the penetration room ventilation. The TS for Oconee reqc' ,2 laboratory i test of charcoal to be performed in accordance with ANSI N510-1975, whicn requires the performance of the 25-80 25 test. Hov.ever, the licensee was actual ly performing a 30-30-30 test using the test protocol of ASTM D3803-1989. The NRC granted an emergency TS change on April 2,1996, to permit the 30-30 30 test. In each of these cases, the test periccried to demonstrate compliance with TS provided results that the staff considered closer to reflecting the capability of the charcoal than the test required by the TS. In addition, the licensees believed that usin] the newer standard would satisfy their - TS requirement. Their bases for this belief were the limitations of the test referenced in RG 1.52, their interpretation of ANSI N509 as allowing the use of later versions of the test protocol, and some of the guidance provided by the NRC. In the case of Oconee, the test actually performed is the test that the staff believes is the appropriate one, ASTM D3803-1989. However, because these tests had not been conducted in compliance with the plant's TS, each licensee would have had to shut down its plant or remain in a cold-shutdown mode until the test required by the TS could be successfully performed, or until the TS were cmended. On March 21,1996, Carolina Power & Light Company flew a charcoal sample from the Brunswick standby gas treatmer,t system (SGTS) to its testing laboratory in Ohic for the performance of the 25-80 25 test to comply with the Brunswick TS before restart cf an idle unit. The Brunswick TS required that the laboratory tests be performed in accordance with Revision 1 of RG 1.52. Previously, the licensee directed its testing laboratory to perform an 80-80-80 test. To perform the 25-80-25 test, the laboratory equilibrated the charcoal to 80'C [176*F] before.
Introducing the challenge gas. The licensee has not requested a TS change for Brunswick to correct the problem cnd is awai'.ing guidance from the NRC. As a result of the emergency TS changes, the staff has performed an intemal survey of operating plant TS to determine whether other plants have the pntentiL1 for similar problems with compliance. The survey indicated that at least one-third of operating reactor licenset,3 may not be in compliance with their TS because they referenco the flawed 25 80-25 testing protocol and may have used later versions of the standards for the laboratory tests of their nuclear-grade charcoal. On the basis of this survey, the staff established the following four categories of plants: (1) plants in compliance with their TS that test in accordence with ASTM D3803-1989 (2) plants in compliance with their TS that test in accordance with a test protocol other than ASTM D3803-1989 (3) plants not in compliance with their TS that test in accordance with ASTM D3803-1989 (4) plants not in compliance with their TS that test in accordance with n test protocol other than ASTM D3803-1989 The licensees in Category 1 have TS that require charcoal to be tested in accordance with ASTM D3803-1989, which adequately demonstrates the capability of the charcoal. The licensees in Category 2 have TS that require charcoal to be tested in accordance viith test standards other than ASTM D3803-1989. The licensees that received emergency TS changes were in Categories 3 and 4. Licensees in Categories 3 and 4 have TS that require charcoal to be tested in accordance with the 25-60-25 test. !
SAMPLE TECHNICAL SPECIFICATIONS 1 For Plante With Imoroved Standard Technical Scecifications C. Demonstrate for eech of the ESF systems that a laboratory test of a sample of the charcoL! adsorber, when thtained as described in (Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of s 30*C [86*F] and greater than or equal to the relative humidity specified below. ESF Ventilation System Pent. ration RH _ _1 N_qte: The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility i-s indeterminate. ASTM D3803-1989 is a more stringelt testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period performed at a tempe sture of 30*C [86'F] and a relative humidity (RH) of 95% (or 70% RH with humidity control), and it has more stringent tolerances that improve repeetability of the test. Allowable [100% - Methyl 10dide Efficiency For Charcoal Credited in SER] Penetration Safety Factor When ASTM D5003-1989 is used with 30'C [86*F] and 95% RH (or 70% RH with humidity control) is used, tha staff will accept the following: Safs 'y factor 2 2 for systems with or without humidity control. _l
0 = i. For Plants With Older Technical Specifications Each engineered safety feature (ESF) ventilation system shall be demonstrated OPERABLE: a. At least once per 18 months or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by: 1) Verifying, within 31 days after removal, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatyry Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl lodide Mnetration less than (see note above]% when tested in accordance with ASTM D3803-1989 at a temperature of s 30'C [86'F) and greater than or equal ,v 2 relative humidity of [see note above)%. b. A&x every 720 hours of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows the methyl iodide penetration less than (see note above]% when tested in accordance with ASTM D3803-1989 at a temperature of s 30*C [86*F) and greater than or equal to a relative humidity of (see note above)%. i N. __}}