ML20217H439

Comment Opposing Proposed Generic Ltr, Lab Testing of Nuclear Grade Activated Charcoal

ML20217H439
Person / Time
Site:	Calvert Cliffs
Issue date:	03/31/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR9581 63FR9581-00021, 63FR9581-21, NUDOCS 9804030335
Download: ML20217H439 (2)

Text

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7.J k & :X f.-pfy CHARLES II. CHU$E gim o.. S -OW Baltimore Gas and Electric Company 1/

Vice President Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Caivert Ciirrs Parkway 1998 APR -2 b4 o3:495-4455 00 Lusby. Maryiand 20657 y

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March 31,1998 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Rules Review and Directives Branch SUIMECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Proposed Generic Letter: " Laboratory Testing of Nuclear Grade Activated Charcoal" The Baltimore Gas and Electric Company is pleased to provide comments on the proposed Generic Letter. We have reviewed the comments submitted by the Nuclear Energy Institute and the Nuclear Utility Backfitting and Reform Group. We endorse the comments submitted by both groups.

This proposed generic letter would: (1) alert addressees that the Nuclear Regulatory Commission 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, and that ASTM D3803-1989 should be used for both new and used charcoal; (2) request that addressees determine whether their Technical Specifications reference ASTM D3803-1989 for charcoal filter testing and if not, either amend their Technical Specifications to reference the ASTM or propose an alternative test protocol; (3) alert addressees of the Nuclear Regulatory Commission intent to exercise enforcement discretion; and (4) require written responses to the generic letter.

The letter states that: "[T]he staff does not have confidence that the results of those tests will demonstrate compliance with plant's licensing basis as it relates to the dose requirements of GDC

[ General Design Criteria] 19 and Part 100, including resolution of TMI Action Plan item Ill.D.3.4." In the proposed letter, the Staff has concluded that tests which use actual post-accident conditions to demonstrate acceptability of activated charcoal may no longer be acceptable. The new standard is inconsistent with the approved licensing basis and warrants a thorough justification under requirements of the Backfitting Rule.

Calvert Cliffs currently tests all of the nuclear-grade activated charcoal used outside of the containment Buildings in accordance with ASTM D3803-1989, and our Technical Specifications reference g 9804030335 980331 PDft I&E MISC PDR

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Rules Review and Directiv s Branch

!' March 31,1998 Page 2

ASTM D3803-1989. We test the nuclear-grade activated charcoal used in the Containment iodine filter trains in accordance with the.same ASTM, with exceptions for temperature, species of iodine, and pressure to more closely reflect the actual post-accident conditions in our Containment Buildings.

L Testing the containment iodine filter trains using the temperatures, pressures, and species of iodine as required by the ASTM D3803-1989, without exceptions, would require Calvert Cliffs to replace the charcoal currently in the iodine filters at a cost of approximately $300,000.00 for all six filters. The replacement of the charcoal also requires that the unit be offline and shutdown, creating substantial lost resenues. We feel that none of these actions create a commensurate increase in the health and safety of the public. Calvert Cliffs and similarly designed plants should not be subject to the proposed generic letter. We recommend the Nuclear Regulatory Commission further research the appropriate applicability )

,. 'of this concern prior to issuing a generic letter applicable to all nuclear power plants. We feel that the proposed generic letter should not be issued

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, l . aL ,

for C. H. Cruse

Vice President - Nuclear Energy CHC/JKK/bjd cc: Document Control Desk, NRC H. J. Miller, NRC R. S. Fleishman, Esquire Resident inspector, NRC l

J. E. Silberg, Esquire R.1. McLean, DNR Director, Project Directorate I-1, NRC J. H. Walter, PSC A. W. Dromerick, NRC j 1 h