ML20207B707

Safety Evaluation Supporting Amends 196 & 206 to Licenses DPR-51 & NPF-6,respectively

ML20207B707
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20207B691	List: ML20207B684 ML20207B707
References
NUDOCS 9906020068
Download: ML20207B707 (12)

Text

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NUCLEAR REGULATORY COMMISSION i

WASHINGTON, D.C. 30e86 4001 i

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

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l BELATED TO AMENDMENT NO.196 TO FACILITY OPERATING LICENSE NO. DPR-51 AND AMENDMENT NO. 206 TO FACILITY OPERATING LICENSE NO. NPF-6 l

ENTERGY OPERATIONS. INC.

ARKANSAS NUCLEAR ONE. UNIT NOS.1 AND 2 l

DOCKET NOS,50-313 AND 50-368

1.0 INTRODUCTION

l By letter dated April 4,1995, as supplemented June 22,1995, Entergy Operatione, Inc. (the licensee) submitted a request for changes to the Arkansas Nuclear One, Units 1 arid 2 (ANO-1, ANO-2), Technical Specifications (TSs). The requested changes revise those TSs associated with the ANO-1 and ANO-2 control room emergency ventilation systems. The changes to the ANO-1 TSs clarify the control room emergency habitability equipment requirements and make the requirements more consistent with those specified for ANO-2.

' During subsequent discussions between ANO and the Nuclear Regulatory Commission (NRC) staff, the staff requested that the licensee revise the proposed control room filter testing requirements for ANO-1 and the existing control room filter testing requirements for ANO-2 to l

include the testing methodology of ASTM [American Society for Testing and Materials) D3803-1989," Standard Test Method for Nuclear-Grade Activated Charcoal," as the laboratory testing standard. The staff also requested changes in the proposed ANO-1 and existing ANO-2 filter testing acceptance criteria.

. The licensee superseded its April 4,1995, amendment request by [[letter::05000313/LER-1996-010-02, :on 961119,failed to Test Reactor Protection Sys (RPS) High Temp Trip Function.Caused by Inadequate Procedure Rev.Declared RPS Inoperable,Revised RPS Test Procedures & Tested All Four Channels|letter dated December 19, 1996]], as supplemented August 6 and December 3,1998. An additional change was requested for both the ANO-1 and ANO-2 TSs in the December 19,1996, amendment request to extend the allowed outage time for one inoperable train of the emergency air conditioning system from 7 days to 30 days. The licensee also proposed changes to the Bases of the TSs in order to make the Bases consistent with the TS changes.

The August 6,1998, letter incorporated the addition of a new red!ation monitor in the ANO-1 control room normal air intake duct and ANO-2 operator's guidance as an enhancement in certain situations. The letter also revised the December 19,1996, submittal pages to reflect the incorporation of ANO-1 Amendment 192 and ANO-2 Amendment 191, issued on July 13,1998.

The December 3,1998, letter corrected a surveillance requirement reference table in the [[letter::05000313/LER-1996-010-02, :on 961119,failed to Test Reactor Protection Sys (RPS) High Temp Trip Function.Caused by Inadequate Procedure Rev.Declared RPS Inoperable,Revised RPS Test Procedures & Tested All Four Channels|December 19,1996, letter]].

The August 6 and December 3,1998, letters provided additional information that did not change the scope of the original Federal Reaister notice and did not change the staff's initial proposed no significant hazards consideration determination.

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2-2.0 EVALUATION

2.1 Background

The current control room ventilation system has evolved from two subsystems, one for ANO-1 and another for ANO-2. Each subsystem includes a control room emergency ventilation system (CREVS) and a control room emergency air conditioning system (CREACS). Air conditioning for both control rooms under isolated control room conditions is maintained by package units located in the ANO-2 portion of the control room. The package air conditioners are normally powered from vital buses in ANO-2, but one package unit can be temporarily powered from a vital bus in ANO-1. The ANO-1 control room ventilation systems are described in ANO-1 Safety

' Analysis Report (SAR) Sections 1.7.2 and 9.7.2.1. The ANO-2 control room ventilation systems are described in ANO-2 SAR Sections 1.2.2.10.B and 9.4.1. The existing TSs for both ANO-1

'and ANO-2 address the same equipment, but with different requirements. 'This complicates system functional performance with respect to how the system operates in the off-normal and emergency modes. The ANO-1 and ANO-2 control rooms are located adjacent to each other.

The control panels and equipment are physically separated by glass doors to eliminate interaction between the ANO-1 and ANO-2 systems. The glass doors do not extend to the ceiling and are open at the top to allow the ventilation systems to be shared by the two control rooms, comprising a common control room ventilation envelope. One system is redundant to the other and, therefore, the TS for each unit's control room habitability system should address the same surveillance requirements (SRs) and acceptance criteria.

The CREVS is designed to reduce the potential control room operator dose from a radiological accident to within the General Design Criterion 19 limits. The CREVS consists of two redundant filter trains, both of which are located outside the ANO-1 section of the common control room. Each filter train includes a centrifugal fan, a roughing filter, a high efficiency particulate (HEPA) filter, and a charcoal adsorber. Besides recirculation and filtration of control room air, filtered outside makeup air is also provided to pressurize the control room in order to i

minimize unfiltered air in-leakage into the control room under isolated conditions. A new ANO-1 intake duct radiation monitor, identical to the ANO-2 intake duct radiation monitor, was installed to replace the existing area radiation monitor's input signal to the control room high radiation automatic isolation circuit. Additionally, the CREVS trains are normally isolated from the control room by dampers. In the event of detection of high radiation, the normal control room ventilation systems of both ANO-1 and ANO-2 are automatically isolated and both trains of the CREVS are automatically actuated.

The control room emergency ventilation system filtration train for each unit consists of an

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emergency filter and fan unit and its associated filters. The ANO-1 filter train is located above the ANO-1 control room in the computer room. Outside air, drawn from the computer room and turbine building, is supplied for ANO-1 control room makeup when the ANO-1 CREVS is placed in operation. The ANO-1 recirculated air flow is filtered by a roughing filter, a HEPA filter, and a 2-inch charcoal tray adsorber. The outside air supplied for makeup for ANO-1 is filtered through a roughing filter, a HEPA filter, and a 2-inch charcoal tray adsorber, mixed with the recirculated air flow, and then filtered again through a roughing filter, a HEPA filter, and a 2-inch recirculation charcoal tray adsorber. The licensee states that this arrangement results in filtering the makeup air flow through 4 inches of charcoal adsorber as defined in Regulatory e4%

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s Guide 1.52, " Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants," Revision 2, March 1978, Table 2.

The ANO 2 filter train is located in the ANO-1 Auxiliary Building. The ANO-2 filter train rated flow consists of recirculation air, taken from and returned to the control room envelope, and outside air drawn from the ANO-1 Auxiliary Building and supplied for control room makeup

' when the ANO-2 CREVS is placed in operation. After mixing, the recirculated air and the makeup air flows for ANO-2 are filtered by a roughing filter, HEPA filter, and a 4-inch deep bed charcoal adsorber. The ANO-1 and ANO-2 emergency filter and fan unit trains are not equipped with heaters and are not designed to control the relative humidity of the ventilation flow stream.

Currently, TS 3.9 and TS 4.10 for ANO-1 and TS 3/4.7.6 for ANO-2 are written in such a way that ANO must test the charcoal from each unit twice using two different testing requirements.

2.2 Evaluation of Proposed Chanaes for ANO-1 The licensee proposes to revise the titles, applicability, and objectives of TS Sections 3.9 and 4.10 to refer to the control room emergency ventilation and air conditioning system rather than the control room emergency air conditioning and isolation system. The licensee also proposes to revise Table of Contents pages (i) and (ii) to reflect the new titles of Sections 3.9 and 4.10.

The proposed changes are administrative and are acceptable to the staff.

The licensee proposes to separate TS 3.9.1 into TS 3.9.1 for the CREACS and TS 3.9.2 for the CREVS. The proposed change is administrative and is acceptable to the staff.

The licenses proposes to move existing TSs 3.9.1.a,3.9.1.b,3.9.1.c,3.9.1.d, and 3.9.1.f to TS 4.10 because they are surveillance requirements associated with the CREVS. Specifically, the licensee proposes the following changes:

Current Soecification Eauivalent Proposed Soecification 3.9.1.a 4.10.2.b.1, 4.10.2.e, and 4.10.2.f 3.9.1.b 4.10.2.b.2 and 4.10.2.c 3.9.1.c 4.10.2.b.3 3.9.1.d 4.10.2.d.1 3.9.1.f 4.10.2.d.2 These proposed changes are administrative changes and are acceptable to the staff.

The licensee proposes to add TS 3.5.1.13 to specify that the radiation monitoring system instrumentation must be operable whenever the reactor coolant system is above the cold shutdown condition or during the handling of irradiated fuel. The current TS does not specifically require operability of the ANO-1 area radiation monitor. The licensee installed an intake duct radiation monitor for ANO-1, identical to the ANO-2 intake duct radiation monitor, to provide improved radiation detection capability and redundancy. For purposes of the TS, the ANO-1 intake duct radiation monitor's signal will replace the area radiation monitor's input signal to the control room isolation circuit. The incorporation of TS 3.5.1.13 results in a more

i restrictive requirement than previously specified and assures the operability of the control room ventilation radiation monitoring system during those modes of operation in which the CREVS is required to be operable. The change is acceptable to the staff.

The licensee proposes to add the control room radiation monitor channels to TS Table 3.5.1-1,

" Instrumentation Limiting Conditions for Operation," Other Safety Related Systems functional unit 14. The addition of the control room isolation on high radiation to Table 3.5.1 1 clearly defines the requirements for the control room radiation monitoring instrumentation systems and maintains consistency with TS 3.5.1.13 as previously discussed.

The licensee proposes to delete existing TS 3.9.1.e. Currently, TS 3.9.1.e requires that one -

circuit of the control room emergency air conditioning and isolation system be capable of automatic actuation whenever reactor building integrity is required. The licensee's submittal referred to TS 3.9.1.c; however, since the description of the requirement was correct, the staff identified the typographical error and verbally confirmed that it was an error with the licensee.

- The TS 3.9.1.e requirement will be maintained by the inclusion of proposed new TS 3.5.1.13, and the addition of the control room radiation monitor channels to TS Table 3.5.1-1, Other

. Safety Related Systems functional unit 14. Relocation of TS 3.9.1.e requirements to TS 3.5.1.13 and Table 3.5.1-1 is administrative and acceptable to the staff.

The licensee proposes to revise Note 17 of TS Table 3.5.1-1 for clarity by deleting the phrase,"... restore the inoperable channels to operable status, or...." Note 17 as currently j

worded could be interpreted as conflicting with Note 18. The revision clarifies that Note 17 applies if no channels are operable, and Note 18 applies if one channel is inoperable. The revision is administrative and is acceptable to the staff.

The licensee proposes to revise the Bases associated with proposed new TS 3.5.1.13 to replace the reference to the ANO-1 area radiation monitor with a reference to the ANO-1 control room ventilation intake duct monitor. The installation of the ANO-1 control room ventilation intake duct monitor was found acceptable under 10 CFR 50.59. For consistency in terminology, the licensee also proposes to replace the reference to the ANO-2 control room ventilation process monitor in its December 19,1996, submittal with a reference to the ANO-2 control room ventilation intake duct monitor. The current ANO-1 TSs require operability of the radiation monitors only by requiring that the control room ventilation dampers be capable of isolating within 10 seconds after receipt of a high radiation signal. The proposed change in nomenclature of the radiation monitors is administrative in nature and is acceptable to the staff.

The licensee proposes to revise TS 3.9.1 to specify the Limiting Conditions for Operation and the Required Actions associated with the CREACS. The proposed revision combines the requirements of existing TSs 3.9.1 and 3.9.4 into proposed TS 3.9.1. This revision to TS 3.9.1 is administrative and is acceptable to the staff.

The licensee proposes to revise TS 3.9.2 to specify the Limiting Conditions for Operation and the Required Actions associated with the CREVS. The proposed revision combines the requirements of existing TSs 3.9.2 and 3.9.4 into proposed TS 3.9.2. These proposed changes are administrative changes and are acceptable to the staff.

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I' 5-l The licensee proposes to delete current TS 3.9.4 and incorporate its requirements into proposed TSs 3.9.1 and 3.9.2, as previously described. The change is administrative and is acceptable to the staff.

The licensee proposes to revise TS 3.9.1 to extend the allowed outage time (AOT) for one inoperable train of the emergency air conditioning system from 7 to 30 days. This proposed TS i

change is consistent with NUREG-1430, Rev.1, " Standard Technical Specifications, Babcock and Wilcox Plants," and NUREG-1432, Rev.1, " Standard Technical Specifications, Combustion l

Engineering Plants." As stated in NUREG-1430, Section B 3.7.11, and NUREG-1432, Section B 3.7.12, the 30-day completion time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining train can provide the required capabilities, and the altemate cooling means that are available. The extension of the AOT for one inoperable train of CREACS is acceptable to the staff.

The licensee proposes to revise the required actions of proposed TSs 3.9.1.2 and 3.9.2.2 for consistency with the associated limiting conditions for operation (LCOs). These LCOs require two independent trains of the CREVS and CREACS to be operable; however, the required actions require restoration of inoperable systems. The proposed required actions require the restoration of the inoperable train. Similarly, the licensee proposes to revise TS 4.10.2 to l

require each train of control room emergency ventilation to be demonstrated operable, rather than each system. The proposed changes are administrative and are acceptable to the staff.

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The licensee proposes to delete TS 3.9.3. Currently, TS 3.9.3 provides the option of isolating i

the fire dampers or disabling the supply fan in order to accomplish sealing the control room in the event that the control room isolation dampers cannot automatically isolate the control room l

following a high radiation signal. Closing the fire dampers provides the intent of sealing the l

control room from a potentially toxic environment. This action is considered to be a contingency measure and has been deleted. Proposed TS 3.9.1, TS 3.9.2, and TS Table 3.5.1-1 functional unit 14 contain the operability requirements for the CREVS and CREACS and the required

- actions if a control room radiation monitor channel is inoperable. With no channel of the control

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room radiation monitoring system operable, the CREVS must be placed in a condition that does l

not require the isoletion to occur (i.e., one operable train of CREVS is placed in the emergency I

recirculation mode of operation). Disabling the supply fan does not result in isolation of the normal control room ventilation, and this option is removed from the proposed TS. The proposed changes are acceptable to the staff.

The licensee proposes to add TS 3.8.18, which states that, "During the handling of irradiated fuel, the control room emergency air conditioning system and the control room emergency ventilation system shall be operable as required by Specification 3.9." The accident e.nalysis for fuel handling in the reactor building assumes that the CREVS is actuated. Currently, TS 3.9.1 only requires CREACS and CREVS to be operable whenever reactor building integrity is required. The proposed change makes the ANO-1 TSs consistent with the fuel handling accident analysis and results in a more restrictive requirement than previously specified and is,

- therefore, acceptable to the staff.

The licensee proposes to combine the current TS surveillance requirements for the CREVS and CREACS TSs 4.10.1,4.10.2,4.10.3, and 4.10.4 into two new TSs 4.10.1 and 4.10.2 for CREVS and CREACS, respectively, as follows:

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6-Current Soecification Eauivalent Prooosed Soecification 4.10.1 4.10.2.d.1 4.10.2 4.10.2.d 4.10.3.a 4.10.2.b and 4.10.2.c 4.10.3.b 4.10.2.e 4.10.3.c 4.10.2.f 4.10.4 4.10.1.a.2 and 4.10.2.a The proposed changes are administrative changes and are acceptable to the staff.

The licensee proposes to revise the Bases associated with TSs 3.5,3.9,4.10, and Table 3.5.1-1 to reflect the changes to these specifications, to address the common control room for the two units, and to clarify the contingency actions allowed for the control room habitability equipment in the event of equipment inoperability. The changes are administrative and are acceptable to the staff.

2.3 Evaluation of Proposed Chances for ANO-2 The licensee proposes to revise TS Table 3.3-6, " Radiation Monitoring instrumentation,"

item 2.b, " Control Room Ventilation intake Duct Monitor," to consider both the ANO-1 and ANO-2 control room ventilation radiation monitor channels as redundant components. The TS has been revised to ensure consistency in specifying the requirements, required actions, and modes of applicability associated with the ANO-1 control room radiation monitor channel and the ANO-2 control room ventilation process mcnitor channel. The current TS requires one channel of control room ventilation intake duct monitor to be operable. The ANO-1 control room area monitor channelis not specifically identified in the current ANO-2 TS. Since the new ANO-1 control room ventilation intake duct monitor is identical to the existing ANO-2 duct monitor with respect to method of operation, sensitivity, and setpoint, the licensee proposes to revise the item 2.b requirements to require two channels of control room ventilation intake monitors to be operable with a setpoint less than or equal to 2 times background and a 8

measurement range of 10 to 10 counts per minute. Since the two monitors are identical, the proposed revision results in a more restrictive requirement than the current TS. The licensee also proposes to revise the ANO 2 TS Bases associated with TS 3/4.3.3.1 to replace the reference to the ANO-1 control room area radiation monitor with a reference to the ANO-1 control room ventilation intake duct monitor. For consistency in terminology, the licensee proposes to replace the reference to the ANO 2 control room ventilation monitor with a reference to the ANO-2 control room ventilation intake duct monitor. In this configuration, the control room ventilation intake duct monitor relies on its respective train of control room emergency ventilation system in order to perform its design function. The proposed AOT for both of these components has been revised and determined to be consistent to support this interdependence. The proposed change will take credit for the new ANO-1 control room ventilation intake duct monitor as a redundant component for the ANO-2 control room ventilation intake duct monitor. The proposed change is more restrictive and is acceptable to the staff.

The licensee proposes to revise TS Table 4.3-3, " Radiation Monitoring instrumentation Surveillance Requirements," ltem 2.b, " Control Room Ventilation intake Duct Mon.itor," to reflect 1

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7 the proposed changes in TS Table 3.3-6. This change will require both intake duct monitors to be tested. The changes are more restrictive and are acceptable to the staff.

The licensee proposes to change the titles of Table of Contents pages (Vlli) and (Xill), and TS 3/4.7.6 to refer to the control room emergency ventilation and air conditioning system rather than the control room emergency air conditioning and air filtration system. These proposed changes are administrative changee and are acceptable to the staff.

The licensee proposes to revise TS 3.7.6.1 to refer to the control room emergency ventilation and air conditioning system. In addition, the licensee proposes to revise the. Actions associated with TS 3.7.6.1 to separately specify the required actions for inoperable emergency air conditioning systems in Action a and inoperable emergency ventilation systems in Action b.

The changes are made for consistency, are administrative, and are acceptable to the staff. The licensee proposes to revise the Mode of Applicability to require the operability of the system in Modes 1,2,3, and 4, and during the handling of irradiated fuel. The change is a more restrictive requiremen! than the current TS and requires the system to be operable in those plant modes in which a postulated accident could require system actuation. The change is acceptable to the staff.

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The licensee proposes to revise TS 3.7.6.1 to specify the AOT for one inoperable train of' CREACS from 7 to 30 days. This proposed TS change is consistent with NUREG-1430, Rev.1,

" Standard Technical Specifications, Babcock and Wilcox Plants," and NUREG-1432, Rev.1,

" Standard Technical Specifications, Combustion Engineering Plants." As stated in NUREG-1430, Section B 3.7.11, and NUREG-1432, Section B 3.7.12, the 30-day completion time is based on the low probability of an event occurring requiring control room isolation, the consideration that the remaining train can provide the required capabilities, and the attemate cooling means that are available. The extension of the AOT for one inoperable train of CREACS is acceptable to the staff.

In the August 6,1998, revised amendment request, the licensee proposes to add an additional required action to TS 3.7.6.1. The required actions proposed in the December 19,1996, submittal provide direction to the operator in the event one control room emergency air conditioning system or one control room emergency ventilation system is inoperable. The proposed required actions did not provide explicit direction to the operator in the event one control room emergency air conditioning system and one control room emergency ventilation system are inoperable. This condition could be interpreted as requiring entry into LCO 3.0.3.

The proposed additional required action (Action c) requires restoration of the inoperable control room emergency ventilation system within 7 days and restoration of the inoperable control room emergency air conditioning system within 30 days, or place the unit in at least hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown within the following 30 Pours. During the review of Action c, the staff determined that the control room emergency mitilation systems and control room emergency air conditioning systems are independent systems. Therefore, the proposed Action !s an acceptable clarification to prevent an unnecessary entry into LCO 3.0.3.

The propos,ed required action is consistent with proposed ANO-1 TSs 3.9.1 and 3.9.2 and NUREG-1432, Rev.1, Sections B 3.7.11 and B 3.7.12. The proposed Action c is considered to be an administrative clarification and is acceptable to the staff.

The licensee proposes to revise the Bases for TS 3/4.7.6 to reflect the change in title for that

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section, to address the common control room for the two units, and to include clarification of the

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contingency actions allowed for the control room habitability equipment in the event of guipment inoperability. The changes are administrative and are acceptable to the staff.

2.4 Inolace Filter Testing 2.4.1 ANO-1 Inolace Filter Testing Currently, TS 3.9.1.a requires that the results of the inplace cold dioctyl phthalate (DOP) and halogenated hydrocarbon tests at design flow (*10 percent) on HEPA filters and charcoal adsort:er banks shall show greater than or equal to 99 percent DOP removal and greater than or equal to 99 percent halogenated hydrocarbon removal. Additionally, TSs 4.10.3.b and 4.103.c require cold DOP testing of the HEPA filter bank and halogenated hydrocarbon testing of the charcoal adsorber bank after each complete or partial replacement or after any structural maintenance on the system housing.

The licensee proposes to relocate the requirements of TS 3.9.1.a to TS 4.10.2.b.1. The proposed TS 4.10.2.b.1 requires verification, at least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following significant painting, fire, or chemical release in any ventilation zone communicating with the system, that the cleanup system satisfies the in-place testing acceptance criteria and uses the i

test procedures of Regulatory Positions C.S.a. C.S.c, and C.5.d of Regulatory Guide (RG) 1.52, Revision 2, March 1978, and the system flow rate is 2000 cubic feet per minute (cfm)

• 10 percent. These RG 1.52 positions require removal of 99.95 percent of the DOP and hydrocarbon when they are tested in place in accordance with American National Standards Institute (ANSI) N510-1975 while operating the system at a flow rate of 2000 cfm *10 percent.

The proposed TS is more conservative than the existing TS, specif;cally conforms with the guidance of RG 1.52 and requirements of ANSI N510-1975, and is consistent with ANO 2 TS requirements. Therefore, it is acceptable to the staff.

Additionally, the requirements of TSs 4.10.3.b and 4.10.3.c are relocated to TSs 4.10.2.e and 4.10.2.f for testing of the HEPA and charcoal adsorber banks with the specified testing requirements for removal of 99.95 percent of the DOP and hydrocarbon when they are tested in place, in accordance with ANSI N510-1975, while operating the system at a flow rate of 2000 cfm *10 percent. This proposed change conforms with the guidance of RG 1.52, the

- requirements of ANSI N510-1975, and is consistent with ANO-2 TS requirements; therefore, the proposed change is acceptable to the staff.

2.4.2 ANO-2 Inolace Filter Testing ANO 2 inplace filter testing TS 4.7.6.1.2.b.1 is unchanged. TS 4.7.6.1.2.e specifies the DOP testing requirements for the HEPA filter banks following a complete or partial replacement. The licensee proposes to revise the acceptance criteria from 99 percent DOP removal (1 percent penetration) to 99.95 percent DOP removal (0.05 percent penetration) in accordance with Regulatory Position C.S.c of RG 1.52, Revision 2. The change is a more restrictive testing requirement and is acceptable to the staff.

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L ' 2.5 Laboratory Testing 2.5.1 ANO-1 Current TS for I ahnratory Testina ANO-1 TSs 3.9.1.b and 4.10.3.a require that laboratory analyses of the carbon samples use the test procedures of Military Specification RDT M 16-1T, " Gas Phase Adsorbents for Trapping Radioactive lodine and lodine Components" (date not indicated), but specifies that the test is to be conducted at 52 *C and 95 percent relative humidity (RH). The essential elements of this test are as follows:

e 95 percent RH, e 5-hour pre-equilibration (pre-sweep) time, with air at 52 *C and 95 percent RH, e 2-hour challenge, with gas at 52 *C and 95 percent RH, and e a 2-hour slution (post sweep) time, with air at 52 *C and 95 percent RH.

2.5.2 ANO-2 Current TS for Laboratory Testina ANO-2 TSs 4.7.6.1.2.b.2 and 4.7.6.1.2.c require that laboratory analyses of carbon samples use the test procedures and meet the acceptance criteria of Regulatory Position C.6.a of RG 1.52, Revision 2. 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 and Components." Test 5.b references the test method from 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 specifies that the test is to be conducted at 80 *C and 95 percent RH with preloading and postloading sweep at 25 *C. This test is referred to as the "25-80-25 test." The essential elements of this test are as follows:

• 95 percent RH, e 5-hour pre-equilibration (pre-sweep) time, with air at 25 *C and 95 percent RH, e 2-hour challenge, with gas at 80 *C and 95 percent RH, and e a 2-hour elution (post-sweep) time, with air at 25 *C and 95 percent RH.

2.5.3. ANO-1 and ANO-2 Proposed TS for I ahoratorv Testina The licensee proposes to relocate the requirements of TSs 3.9.1.b and 4.10.3.a to TSs 4.10.2.b.2 and 4.10.2.c for ANO-1, and to revise existing TSs 4.7.6.1.2.b.2 and 4.7.6.1.2.c for ANO-2. The proposed surveillance requirement also requires that samples be obtained as aescribed in RG 1.52, Revision 2, but specifies that the samples be tested in accordance with American Society for Testing and Materials (ASTM) D3803-1989, " Standard Test Method for Nuclear-Grade Activated Carbon," at 30 *C and 95 percent RH. ASTM D3803-1989 is updated guidance based on an NRC verification and validation effort on ASTM D3803-1979, which is updated guidance based on RDT M16-1T. The essential elements of the proposed TS j

changes for testing per ASTM D3803-1989 are:

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• 95 percent RH, e 2-hour thermal stabilization, at 30 *C, e 16-hour pre-equilibration (pre-sweep) time, with air at 30 *C and 95 percent RH, e 2-hour equilibration time, with air at 30 *C and 95 percent RH, e 1-hour challenge, with gas at 30 *C and 95 percent RH, and e a 1-hour elution (post-sweep) time, with air at 30 *C and 95 percent RH.

The major differences between the current and proposed TS requirements for carbon testing are:

Current TS MAJOR DIFFERENCES Proposed TS Unit 1 Unit 2 Pre-Equilibration (Pre Sweep) 30 *C 52 *C 25 *C Temperature Challenge Temperature 30 *C 52 *C 80 *C Elution (Post-Sweep) Temperature 30 *C 52 *C 25 *C Relative Humidity 95 %

95%

70 %

Total Pre-Test Equilibration 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 5 hours 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Tolerances of Test Parameters Smaller Larger Larger The following discussion demonstrates that these differences make the proposed TS more conservative than the current TS requirements.

ASTM D3803-1989 challenges the representative charcoal samples at 30 *C rather than at 52 *C for ANO-1. In addition, ASTM D3803-1989 specifies a test temperature of 30 *C for both the pre-test and post-test sweeps rather than 52 *C for ANO-1. The quantity of water retained by charcoal is dependent on temperature, with less water being retained as the temperature rises. The water retained by the charcoal decreases its efficiency in adsorbing other contaminants. Because most charcoalis anticipated to be challenged at a temperature closer to 30 *C rather than 52 *C, the lower temperature test condition of ASTM D3803-1989 will yield more realistic results than a test performed at 52 *C.

ASTM D3803-1989 challenges the representative charcoal samples at 30 *C rather than at 80 *C for ANO-2. ASTM D3803-1989 specifies a td temperature of 30 *C for both the pre-and post-test sweeps rather than 25 *C for ANO-2. There is little difference in the adsorption l

behavior of charcoal at the 25 *C and 30 *C temperatures. A temperature of 25 *C is more I

conservative; however, the increase from 25 *C to 30 *C does not represent a significant variation in the test results. As previously stated, the quantity of water retained by charcoal is l

deperident on temperature, with less water being retained as the temperature rises. The water retaiaed by the charcoal decreases its efficiency in adsorbing other contaminants. Because most charcoal is anticipated to be challenged at a temperature closer to 30 *C rather than 80 *C, the lower temperature test condition of ASTM D3803-1989 will yield more realistic results than a test performed at 80 *C.

ASTM D3803-1989 provides results that are reproducible compared to RDT M16-1T 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. During the pre-equilibration, the charcoalis exposed to a flow of air controlled at the test temperature and RH before the challenge gas is fed through the charcoal.

The purpose of the pre-equilibration phase of the test is to ensure that the charcoal has stabilized at the specified test temperature and RH for a period of time that results in the charcoal adsorbing all the available moisture before the charcoal is challenged with methyl iodide. Hence, the proposed testing in accordance with ASTM D-3803-1989 standard would result in a more realistic prediction of the capability of the charcoal.

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in addition, proposed ANO-1 TSs 4.10.2.b.2 and 4.10.E.c and ANO-2 TSs 4.7.6.1.2.b.2 and j

4.7.6.1.2.c require that the laboratory testing of charcoal samples show an acceptable methyl iodide penetration. In the licensee's dose analysis, the ANO-1 charcoal beds (each with a depth of 2 inches) and the ANO-2 charcoal bed (with a depth of 4 inches) are credited with a filter efficiency of 95 percent and 99 percent, respectively. The licensee's proposed acceptance criterion is a methyl lodide penetration of less than 2.5 percent for ANO-1 and less than 0.5 percent for ANO-2. The proposed acceptance criterion includes a safety factor of two which provides the staff with a degree of assurance that, at the end of the operating cycle, the charcoal will be capable of performing at a level at least as good as that assumed in the licensee's dose analysis. This factor of safety is acceptable based on the accuracy of test results obtained using the ASTM D3803-1989 standard.

On the basis of the preceding discussion, the proposed test methods and acceptance criteria for the laboratory testing of a representative carbon sample in TSs 4.10.2.b.2 and 4.10.2.c for ANO-1 and TSs 4.7.6.1.2.b.2 and 4.7.6.1.2.c for ANO-2 are acceptable to the staff.

2.6 Evaluation Summary The proposed changes in the Table of Contents for both ANO-1 and ANO 2 and in ANO-1 TSs 3.9 and 4.10 are administrative changes and are acceptable. The proposed change to ANO-1 TS 3.8.18 is consistent with the fuel handling accident analysis and results in a more restrictive requirement than previously specified and is acceptable. The proposed change to ANO-1 TS 3.9.1 and ANO-2 TS 3.7.6.1 to extend the AOT for one inoperable train of i

emerger.cy air conditioning system from 7 to 30 days is consistent with the 30-day completion time approved in NUREG-1430 and NUREG-1432 and is acceptable.

The proposed change to ANO-1 TS 4.10.2 conceming the inplace filter testing is a more conserve.fve test requirement and is acceptable. Specifically, it conforms with the guidance of RG 1.52 and requirements of ANSI N510-1975, and is consistent with ANO-2 TS requirements.

The proposed change to ANO-1 TS 4.10.2 and ANO-2 TS 4.7.6.1.2 conceming the laboratory

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12-testing of a representative carbon sample testing, is in accordance with ASTM D-3803-1989 standard, would result in a more realistic prediction of the capability of the charcoal, and is acceptable.

On the basis of the preceding evaluation, the staff has concluded that the proposed TS changes are acceptable.

3.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Arkansas State official was notified of the 1

proposed issuance of the amendment. The State official had no comment.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility j

component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (62 FR 4348, January 29,1997). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

J. Raval C.Lyon Date: May 19, 1999 i

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