ML20217H298

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Comment Opposing Proposed GL, Laboratory Testing of Nuclear Grade Activated Charcoal, Issued for Comment on 970225. Requests That NRC Consider Impact & Feasibility for Industry to Implement Requirements of GL
ML20217H298
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 03/27/1998
From: Feigenbaum T
NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR9581 63FR9581-00011, 63FR9581-11, NYN-98046, NUDOCS 9804030263
Download: ML20217H298 (2)


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March 27,1998

? E 9ffff Docket No. 50 443 NYN-98046 AR#98004733 United States Nuclear Regulatory Commission l'

Chief, Rules and Direc'ives Branch l

Division of Administrative Services I

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. Office of Administration Mail Stop T6-D69 Washington, DC 20555-0001 l'

Seabrook Station Comments on Proposed Generic Letter j

Laboratory Testing of Nuclear. Grade Activated Charcoal l

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On February 25, 1997, the NRC issued for comment, a proposed generic letter " Laboratory Testing of Nuclear-Grade Activated Charcoal," which would alert licensees that the NRC has determined that testing nuclear-grade activated charcoal to standards other than American Society for Testing and 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 dose limits.

North Atlantic Energy Service Corporation (North Atlantic), the operator of Seabrook Station, has reviewed the material within the proposed generic letter. North Atlantic would fall into category 2 of this generic letter as a plant in compliance with Technical Specifications that tests in accordance with a standard other than ASTM D3803-1989. North Atlantic has contacted our current test laboratory / supplier (NUCON) to discuss testing in service charcoal samples to ASTM D3803-1989. NUCON has indicated that they may not be able to meet the sixty day demand for testing services and supply new charcoal should existing charcoal fail to meet the requirements of ASTM D3803-1989, if this generic letter is issued as written to all licensees.

North Atlantic has discussed this issue with representatives of the Nuclear Energy Institute (NEI) and has learned this is a common concern among the two major test laboratory / suppliers. The 60-day ' implementation schedule requested by the proposed generic letter does not permit sufficient time for licensees to test and submit results to the NRC.

t 10 9804030263 980327

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PDR I&E MISC PDR ADM

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U.S. Nuclear Regulatory Commission Division of Administrative Services NYN-98046 / Page 2 i

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North Atlantic requests the NRC consider the impact and the feasibility for the industry to

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. implement the requirements of this generic letter. An alternate approach may.be to seek a 1

phased in approach or expand the response period beyond 60 days. Either approach should be coordinated as a joint NRC-industry initiative to allow for a comprehensive discussion of NRC l

and industry concerns as they relate to charcoal test methodologies.

North Atlantic has reviewed the comments proposed by NEl and endorses those comments.

If you have questions regarding our comments, please contact Mr. Anthony M. Callendrello, Licensing Manager at (603) 773-7751.

Very truly yours, l

NORTIl ATLANTIC ENERGY SERVICE CORP.

Why JT-Ted C. Feigenbaum #

Executive Vice President and Chief Nuclear Officer cc: Mr. Kurt Cozens Nuclear Energy Institute 17761 Street, NW i

Suite 400 Washington, DC.20006-3708

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