ML20210F312

Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal,

ML20210F312
Person / Time
Site:	Comanche Peak
Issue date:	07/26/1999
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-99-02, TXX-99155, NUDOCS 9907300012
Download: ML20210F312 (5)

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Log # TXX-99155 File # 10010 10035 7UELECTRIC Ref. # 10CFR50.54(f)

GL 99-02 c.tama nerr Senior Mce PresWew

& Pri=i PelNwlear OAlcer July 26,1999 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC GL 99-02, " LABORATORY TESTING OF NUCLEAR-GRADE ACTIVATED CHARCOAL" REF: NRC Generic Letter 99-02," Laboratory Testing of Nuclear-Grade Activated Charcoal", dated June 3,1999 Gentlemen:

The following is the TXU Electric

• response to the required actions of NRC Letter 99-02, regarding, " Laboratory Testing of Nuclear-Grade Activated Charcoal", dated June 3,1999:

GL 99-002 Reauested Action 1:

Within 180 days of the date of this generic letter, submit a written response to the NRC

' describing your current TS requirements for the laboratory testing of charcoal samples for each ESF ventilation system including the specific test protocol, temperature, RH, charcoal bed thickness, total residence time per bed depth, and penetration at which the TS require the test to be performed. If your current TS specifically require laboratory testing of charcoal samples in accordance with the ASTM D3803-1989 protocol at 30 C [86 *F], and you have been testing in accordance with this standard, then you only need to address this requested action (i.e. no TS amendment or additional testing is required).

g 9907300012 990726' PDR P

ADOCK 05000445 PDR O M L

• TXU Electric was formerly TU Electric. A license amendment request (LAR 99-003) was submitted per TXX-99122, dated May 14,1999, to revise the company name contained in the CPSES operating licenses.

COMANCHE PEAK SILAM ELECTRIC STATION 4

gq} P.O. Box 1002 Glen Rose, Texas 76043 1002

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TXX-99155 Page 2 of 5 CPSES Resnonse to Action 1:

TXU Electric will provide current Technical Specification requirements for the laboratory testing of charcoal samples for each ESF Ventilation System, within 180 days from the issuance of Generic Letter (GL) 99-02.

GL 99-002 Requested Action 2:

If you choose to adopt the ASTM D3803-1989 protocol, submit a TS amendment request to require testing to this protocol within 180 days of the date of this generic letter. The q 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.)

CPSES Response to Action 2:

TXU Electric intenrts to adopt the ASTM D3803-1989 protocol, for charcoal testing of the ESF Ventilation Units, and submit the proposed Technical Specification License Amendment Request (LAR) within 180 days from the issuance of Generic Letter 99-02.

GL 99-002 Reauested Action 3:

If you are proposing an alternate test protocol, address the attributes discussed below and submit a TS amendment request to require testin; to this alternate protocol within 180 days of the date of this generic letter. 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 fVmin], 1 then the revised TS should specify the face velocity. Also, indicate when the next laboratory test is scheduled to be performed.

The following information should be submitted for staff review to determine the acceptability of the alternate protocol:

1. summary of the test method

2. precision of the method

3. descript! uf the test apparatus along with tolerances I

4. parai acations i

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5. _ material requirements

6. hazards

7. preparation of the apparatus before initiation of the test

8. calibration requirements of the test equipment

9. - test procedure

10. manner of calculating penetration and error

11. repeatability and reproducibility of the results for 1 percent and 10 percent penetration

- and the penetration at a 95 percent confidence interval for charcoal tested at 70 percent RH and at 95 percent.

12. bias associated with the method

13. results from at least two laboratories which demonstrate that the alternate test pn > tocol achieves results that are consistent with, or more conservative than, results associated with ASTM D3803-1989.

The demonstration identified in Item 13 above should be based upon a series of tests comparing the altemate test protocol and ASTM D3803-1989, and it should apply to both new and used charcoal tested at 70 percent RH and at 95 percent RH. If an addressee chooses to test its charcoal samples at actual accident conditions which are different from the test conditions specified in ASTM D3803-1989, then that test should be treated as an altemate protocol. At least two laboratories should be used in

, determining the acceptability of the alternate protocol. One laboratory should be used to develop the alternate protocol and the other to demonstrate the repeatability and reproducibility of the attemate protocol. The two laboratories 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 results CPSES Response to Action 3:

f CPSES Response to Action 3:

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TXU Electric is not proposing an attemate protocol, other than ASTM D3803-1989. Hence this action is not applicable to CPSES Unit I and 2.

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TXX$99155 Page 4 of 5 GL 99-002 Requested Action 4:

At the next required laboratory surveillance test of a charcoal sample that is 60 or more days after the date of this generic letter, test your charcoal samples in accordance with 1 ASTM D3803-1989 or replace all of the charcoal with new charcoal that has been tested in I accordance with ASTM D3803-1989. In all cases, the results should meet the acceptance criterion that is derived from applying a safety factor as low as 2 (see the note in Enclosure 2) to the charcoal filter efficiency assumed in your design-basis dose analysis and the charcoal samples should continue to be tested in accordance with ASTM D3803-1989, in lieu of the current TS-required laboratory testing, until the TS j

. amendment is approved by the NRC. l CPSES Response to Action _41 TXU Electric will perform the next required laboratory surveillance of a charcoal sample in accordance with ASTM D3803-1989, and continue to test charcoal samples until the license amendment request (LAR) is approved by the NRC. The test will be to the acceptance criterion that is derived from applying a safety factor of 2 to the charcoal filter efficiency assumed in the plant design-basis dose analysis.

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GL 99-002 Reauested Actionji Addressees who choose not to do the above actions are requested to notify the NRC in writing of their decision, as soon as a decision is reached but no later than 60 days from the date of this generic letter. The 60 day written response should also discuss (1) addressee plans to pursue a proposed alternative course of action (including the basis for establishing its acceptability), (2) the schedule for submitting that proposal for NRC staff review (that proposal should be submitted to the NRC no later than 180 days from the date of this generic letter), and (3) the basis for continued operability of affected systems and components until such time that the proposed alternative course of action is approved by the NRC.

CPSES Resnonse to Action 5:

As in the response to requested action item 2, CPSES is adopting ASTM 3803-1989 protocol, and hence, this item is not applicable to CPSES.

This communication contains the following new licensing basis commitment regarding CPSES Units 1 and 2, which will be completed as noted. The Action Correspondence List (ACL) is used by TXU Electric for the intemal tracking of CPSES commitments, which are a one time action requirement.

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TXX I99155 Page 5 of 5 ACL Number Commitment 99-069 TXU Electric will provide current as well as proposed Technical -

Specifications for ESF Ventilation Systems Charcoal testing as per ASTM D3803-1989, on or before November 30,1999.

Sincerely, e.B. ' %

C. L. Terry By. M Rogr D. Walker Regulatory Affairs Manager i

c- E. W. Merschoff, Region IV J. l. Tapia, Region IV D. H. Jaffe, NRR Resident inspectors, CPSES I

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