ML20210G490

Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, Issued 990603.Ltr Contains NRC License Commitment to Utilize ASTM D3803-1989 with Efficiency Acceptance Criteria Utilizing Safety Factor of 2

ML20210G490
Person / Time
Site:	Farley
Issue date:	07/30/1999
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-99-02, NEL-99-0280, NUDOCS 9908030108
Download: ML20210G490 (6)

Text

m

. ~ .

Dave Mor:y S:uth:rn Nucl:ar Vice President Op:rati1g C:mpany. Inc.

Farley Project Post Office Box 1295 Birmingham, Alabama 35201

. , Tel 205 992.5131 SOUTHERN COMPANY 3 July 30, 1999 Energy to Serve Your %rld" Docket Nos.: '50-348 NEL-99-0280 .

50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant Response to Generic Letter 99-02 Laboratory Testina of Nuclear-Grade Activated Charcoal Ladies and Gentlemen:

On June 3,1999, The Nuclear Regulatory Commission (NRC) issued Generic Letter 99-02,

" Laboratory Testing of Nuclear-Grade Activated Charcoal." The generic letter addresses the NRC staff's concerns regarding the adequacy oflaboratory testing techniques to determine the acceptability of radiological filtration system charcoal. Specifically, licensees were required to determine if their Technical Specifications (TS) reference ASTM D3803-1989 for charcoal filter laboratory testing. Addressees whose TS do not reference ASTM D3803-1989 were requested to amend their TS to reference ASTM D3803-1989 or propose an alternative test protocol.

SNC submitted a TS amendment request on June 30,1997 that updates the charcoal laboratory testing protocol to ASTM D3803-1989. The proposed TS amendment changes are in agreement with the guidance provided in Generic Letter 99-02 with regard to applying a safety factor of 2 to credited tiltration efficiency, residence time, temperature and relative humidity control in laboratory testing. This TS amendment was revised on February 23,1999 to incorporate NRC Staff review comments and approval was requested by July 1,1999. Upon approval of this amendment request FNP will be in full compliance with the requirements of Generic Letter 99-02.

. His letter and attachment contains an NRC license commitment to utilize ASTM D3803-1989

. with the efficiency acceptance criteria utilizing a safety factor of 2 for TS charcoal laboratory testing, with one exception. He filter testing requirements for the containment purge exhaust filter units will continue to adhere to the current TS requirements and utilize ASTM D3803-1979. Upon approval of the previously referenced amendment requests these filter units will be removed from the TS.

pygg ;*g P

CO[f

Page 2 U. S. Nuclear Regulatory Commission The attachment provides the required 60-day response for Plant Farley Unit I and Unit 2.

If you have any questions, please advise.

Respoetfully submitted, i SOUTHERN NUCLEAR OPERATING COMPANY Dave Morey SFB/maf: gl 99-02. doc 1

Attachment:

1. Response to Generic Letter 99-02 l

i

Page 3 U. S. Nuclear Regulatory Commission ec: Southern Nuclear Ooeratinn Comoany Mr. L. M. Stinson, General Manager - Plant Farley

. U. S. F.uclear Renulatory Commission. Washington. D. C.

Mr. L. M. Padovan, Licensing Project Manager - Farley (

l U. S. Nuclear Regulatory Commission. Region 11 Mr. L. A. Reyes, Regional Administrator Mr. T. P. Johnson, Senior Resident Inspector - Farley I I I

l

~

l 1

l J

ATTACHMENT

! Response to Generic Letter 99-02 l

1 l

F ATTACHMENT Joseph M. Farley Nuclear Plant SNC Response to NRC Generic Letter 99-02

" Laboratory Testing of Nuclear Grade Activated Charcoal" Licensees were required to submit a written response to include the informrion outlined below:

In accordance with Generic Letter (GL) 99-02 Requested Action number 1 Southern Nuclear Operating Company (SNC) has conducted a review of the Farley Nuclear Plant (FNP) TS surveillance requirements for laboratory testing of charcoal used in nuclear filtration systems and determined that ASTM D3803-1989 is not currently applied. The current FNP TS surveillance

]

requires charcoal laboratory testing per ANSI N510-1980 which invokes the use of ASTM D3803-1979. The following test conditions are utilized for charcoal laboratory tests: 80 *C; 70% RH; bed thickness of 2 inches, except 6 inches for Control Room Emergency Filtration Systems (CREFS) J Pressurization Unit; residence time is 0.25 seconds per 2 inches of bed thickness; and penetration varies from 0.175% CREFS Pressurization Unit,1% CREFS Recirculation Unit,1% CREFS

- '.' Filtration Unit,5% Penetration Filtration System (PRF), and 10% Containment Purge Exhaust Filter System, respectively.

In accordance with GL 99-02 Requested Action number 2, SNC has proposed a change to the TS surveillance tests to utilize ASTM D3803-1989 at a test temperature of 30 C and the appropriate relative humidity. SNC previously submitted a TS amendment addressing GL 99-02 requested I laboratory testing protocon changes and other associated changes to the nuclear filtration test program. The filtration efficiencies required in laboratory testing applied a safety factor of 2 to credited Sitration efficiency. This TS amendment was submitted on June 30,1997 and revised on February 23,1999. Approval of this TS amendment was requested by July 1,1999.

Also in accordance with GL 99-02 Requested Action number 2, the schedule for the next TS surveillance laboratory tests are provided in the following table with the initial ASTM D3803-1989 l test results.  ;

l ASTM D3803- Efficiency Test Tentative Schedule System 1989 Acceptance Result for Next Lab.

Designation Test Conditions Criteria Efficiencies Surveillance Test CREFS Press. A 30 *C & 70% RH 99.5 % 99.98 % 09/20/1999 CREFS Press. B 30 *C & 70% RH 99.5 % 99.98 % 08/07/1999 CREFS Recir. A 30 *C & 10% RH 97.5 % 99.98 % 09/20/1999 CREFS Recir. B 30 *C & 70% RH 97.5 % 99.98 % 08/07/1999 CREFS Filtr. A 30 *C & 70% RH 97.5 % 99.61 % 09/20/1999 CREFS Filtr. B 30 *C & 70% RH 97.5 % 99.61 % 08/07/1999 PRF Unit 1 A 30 *C & 95% RH 97.5 % 99.61 % 11/19/1999 PRF Unit 1 B 30 C & 95% RH 97.5 % 99.61 % 10/05/1999 PRF Unit 2 A 30 *C & 95% RH 97.5 % 99.61 % 09/16/1999 PRF Unit 2 B 30 *C & 95*/,,RH 97.5 % 99.61 % 08/31/1999 A-1

SNC is not proposing an alternate test protocol, therefore no informatica is supplied for GL 99-02 Requested Action number 3.

In response to GL 994)2 Requested Action number 4, SNC has been conducting dual laboratory tests to maintain current TS surveillance requirements and to establish a baseline for ASTM i D3803-1989 testmg Replacement charcoal meetmg both test criteria has been mstalled ia filtration units which are remaming in the TS nuclee.r filtration test program after proposed TS amendment approval. SNC will enntime to test these systems per ASTM D3803-1989.

In accordance with NRC enforcement discretion instructions provided in GL 99-02, SNC will discontinue unnecessary testing which utilizes ASTM D3803-1979, with one exception. The filter testing requirements for the contairenent purge exhaust filter units are proposed for removal from the TS per the aforementioned TS amendment. Supporting design modifications to the containment purge systems were implemented on both units and preliminary NRC reviews have been favorable; therefore, surveillance testing of the contamment purge exhaust filter units will continue to adlere to the current TS requirements until approval of the proposed TS amendment.

In accordance with GL 99-02 Requested Action number 5, this letter contairs an NRC license commitment to utilize ASTM D3803-1989 with the efficiency acceptance criteria listed above in

{

future TS charcoal laboratory test surveillances, with one exception. The filter testing requirements for the containment purge exhaust filter units will continue to adhere to tim current TS requirements and utilize ASTM D3803-1979 until the TS amendment is approved.

I i

l I

i A-2 L a