ML20245F038
| ML20245F038 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/03/1989 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.052, RTR-REGGD-01.140, RTR-REGGD-1.052, RTR-REGGD-1.140 TXX-89551, NUDOCS 8908140112 | |
| Download: ML20245F038 (12) | |
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1UELECTRIC Reg Guide 1.140
- D,7, hic,Y,',',jI, August 3, 1989
.I s
U. S. Nuclear Regulatory Commission Attn: Document Control Desk 4
Washington, D. C.
20555 l
SUBJECT:
COMANCHE PEAK' STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 and 50 446 ADVANCE FSAR SUBMITTAL LABORATORY TESTING CRITERIA FOR ACTIVATED CARBON Gentlemen:
This letter provides an advance copy of changes to be included in a future FSAR amendment. These changes revise the exception taken to Regulatory Guides 1.52 (Part C.6) and 1.140 (Part C.6) concerning laboratory testing criteria for activated carbon.
In order to. facilitate NRC Staff review of these changes, the attachment is organized as'follows:
1.
Draft revised FSAR pages, with changed portions indicated by a bar in the margin, as they are to appear in a future amendment.
2.
A' detailed description / justification for the changes.
3.
A copy of a related SER section.
4.
A page containing the title of a " bullet" which consolidates and categorizes similar individual changes by subject and related SER section.
1 I
Q 8908140112 890803 g
gDR ADOCK0500g5 400 North Olive Street LB 81 Dallas, Texas 75201
______________________.______________________..____________.___J
TXX-89551 August 3, 1989 Page '1 of 2 5.
The bold / overstrike version of the revised FSAR pages referenced by the detailed description / justification for the changes identified above. The bold / overstrike version facilitates review of the revision by highlighting each addition of new text ir bold type font and overstriking with a slash (/) the portion of the text that is deleted.
Sincerely, 9
Jh.
p William J. Cahill, Jr.
By:
@D c
4 Roger D. Walker Manager. Nuclear Licensing JLR/ mas Attachment c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES '3)
L____.._____.__.____._.
Attachment to TXX-89551 August 3, 1989 Advance FSAR Submittal Concerning Laboratory Testing Criteria for Activated Carbon Item 1 Draft Revised FSAR Pages 2 and 3 Item 2 Detailed Description / Justification for 4 and 5 Changes Item 3 Related SER Section 6 and 7 Item 4 Bullet Title 8
Item 5 Bold /0verstrike Version of Revised FSAR 9 and 10 Pages Page 1 of 10 l
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s
!TXXh89551..
1 Attachment-CPSES/FSAR'-
Page. 2 of 10 -
7)
Parts C.S.c.and C.5.d. In-Place Testing Criteria:
76-h l
' ANSI /ASME N509-1980 and ANSI /ASME N510-1980'will be issued for 59 field testing activities in place of the older versions of these codes referenced-in this Regulatory Guide.
Atmospheric cleanup trains installed at CPSES have two high 59 efficiency filter banks in series.
In-place testing of only 76 upstream HEPA bank will be performed.
l l
In-place testing of the HEPA filter banks and adsorber will not 76 be required following painting, fire and chemical release described in position C.5.c and C.S.d of this guide. Only laboratory testing will be performed for carbon efficiencies.
59 This design conforms to the intent of NRC Regulatory Guide 1.52 66 Revision 2 (03/78).
8)
Part C.6. Laboratory Testing Criteria for Activated Carbon:
76 Laboratory testing of activated carbon will be in accordance with DRAFT ANSI N509'and N510-1980 (which refers to ASTM D3803-79), except for the determination of the efficiency of charcoal to remove radioiodine.
The parameters applicable to new and used charcoal at CPSES shall be applied in the-lab test as follows:
New Charcoal Used Charcoal 76 4" Beds 4" Beds DRAFT 40 ft/ min 40 ft/ min DRAFT 3000 & 95% RH 300C & 70% RH DRAFT Pre-equilibrated Non-pre-equilibrated DRAFT DRAFT The allowable methyl iodide penetration for 99% efficient units 76 shall be 0.2% instead of 0.175% as shown in Table 2 of the Regulatory Guide.
1A(B)-25 Draft Version
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.TXX-89551 ae of 10 CPSES/FSAR In-place testing of high efficiency filter banks and adsorber 76 will not be required following painting, fire and chemical release described in position C.S.c and C.S.d of this guide.
Only laboratory testing will be performed for carbon efficiencies. This design conforms to the intent of NRC Regulatory Guide 1.140 (03/78).
5)
Part C.6. Laboratory Testing Criteria for Activated Carbon:
l 76 Laboratory testing of activated carbon will be in accordance with DRAFT ANSI N509 and N5:0-1980 (which refers to ASTM D3803-79), except for the determination of the efficiency of charcoal to remove radiciodine. The parameters applicable to new and used charcoal at CPSES shall be applied in the lab test as follows:
New and Used Charcoal DRAFT 4" Beds 76 40 ft/ min 76 300C & 95% RH DRAFT Pre-equilibrated DRAFT DRAFT The allowable methyl iodide penetration for these units shall be 76 10% as shown in Table 2 of the Regulatory Guide.
This design conforms to the intent of NRC Regulatory Guide 1.140 76 (03/78).
Regulatory Guide 1.141 Containment Isolation Provisions for Fluid Systems 8
0400.3 Discussion 8
This regulatory guide is not applicable to CPSES: however, the 8
containment isolation is discussed in Section 6.2.
1A(B)-81 Draft Version
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CPSES FSAR-AMENDMENT 77-TXX-89551 DETAILED DESCRIPTION Page 1 Attachment
' ' Page 4 of -10
- 3-FSAR Page 10s egended)
Group Description 1A(B)-25 2
Revises exception taken to Regulatory Guide 1.52 concerning laboratory testing criteria for activated carbon.
Revision:
TV Electric revised the criteria for the laboratory testing of activated carbon via TXX-89200 dated 5/1/89 (FSAR Amendment 76).
As part of this change, labora-tory testing of activated carbon is per ANSI N509-and and N510-1980, since it was no longer necessary to test the carbon as described in ANSI N509-1976.
(New char-coal was purchased in 1986 and this charcoal could be tested per ANSI N509-and N510-1980 standards.)
It was also noted that CPSES would test the used charcoal to 30 C and 70% RH instead of 80 C and 95% RH; the latter temperature / relative humidity combination is specified in ASTM D3803-79 as one of the methods (Method B) for testing of methyl iodide penetration.
ASTM D3803-79 is referenced in both ANSI N509-and N510-1980.
-NRC Information Notice 87-32, " Deficiencies in the Testing of Nuclear-Grade Activated Carbon," identified deficiencies in ASTM 03803-79. Details of the identi-fied deficiencies are contained in Idaho Nuclear Engi-neering Laboratories (INEL) final report No.
EGG-CS-7653, " Final Technical Evaluation Report for the NRC/INEL Activated Carbon Testing Program," dated April' 1987. ASME/ ANSI AG-la-1989 Addenda to ASME/ ANSI AG-la-1988, " Code on Nuclear Air and Gas Treatment,"
accepted on an interim basis the protocol developed by INEL (and presented in EGG-CS-7653) for determination of the efficiency of charcoal to remove radiciodine.
-The criteria for testing presented in this change, which differs from ASTM D3803-79, is taken from this-i accepted protocol, except for the relative humidity for used charcoal and the fact that the used charcoal will not require a pre-equilibration period.
CPSES will test used charcoal at 70% RH instead of
(
95% RH specified in the protocol.
This is acceptable, j
since all ESF units at CPSES contain safety-related I
(Class IE) heaters designed to ensure a maximum of 70%
RH at all times.
The charcoal in these units is expected to remove radioiodine immediately upon activation: therefore, it is not necessary to expose used charcoal to a 16-hour r e-equilibration period prior to testing efficiency.
FSAR Change Request Number: 89-546.1 Rele'.ed SER Section: 6.5.1 SEP/SSER Impact: Yes The INEL protocol has been deemed an acceptable alter-native to deficiencies found in ASTM D3803-79 re:
determination of the efficiency of charcoal to remove radioiodine. The protocol, dated April 1987, was not l
l-fta CPSES FSAR AMENDMENT 77 ent DETAILED DESCRIPTION Page 2 Page 5. of 10 l-FSAR'Page
.Qg1_st Dtion i
(as amended 1 Group part of the review within SER 6.5.1..
IA(B)-81' 2-Revises exception taken to Regulatory Guide 1.140 concerning laboratory testing criteria for activated carbon.
Revision:
TV Electric revised the criteria for the laboratory testing of activated carbon via TXX-89200 dated 5/1/89 (FSAR Amendment 76). As part of this change, labora-tory testing of activated charcoal is per ANSI N509-and N510-1980, since it was no longer necessary to test the carbon as described in ANSI N509-1976.
(New char-coal was purchased in 1986 and this charcoal could be tested per ANSI N509-and N510-1980 standards.)
It was alsc notad that CPSES would test the used charcoal to 30 C and 95% RH instead of 80 C and 95% RH; the latter temperature / relative humidity combination is specified in ASTM D3803-79. ASTM D3803-79 is referenced in both ANSI N509-and N510-1980.
NRC Information Notice 87-32, " Deficiencies in the Testing of Nuclear Grade Activated Carbon," identified deficiencies in ASTM D3803-79.
Details of the identi-fied deficiencies are contained in Idaho Nuclear Engi-neering Laboratories (INEL) final report No.
EGG-CS-7653, " Final Technical Evaluation Report for the NRC/INEL Activated Carbon Testing Program," dated April 1987. ASME/ ANSI AG-la-1989 Addenda to ASME/ ANSI AG-la-1988, " Code on Nuclear Air and Gas Treatment,"
accepted on an interim basis the protocol developed by INEL (and presented in EGG-CS-7653) for determination of the efficiency of charry-' to remove radiciodine.
The criteria for te, presented in this change, s - 19, is taken from this which differs from ASTH accepted protocol.
The footnote, "CPSES will test the used charcoal to 30 C in lieu of 80 C as specified in ASTM D3803," is being deleted because ASTM D3803-79 includes five (5) testing methodologies. Though the criteria are used, all five (5) methodologies do not specify 30 C.
30 C is recommended for use in the accepted protocol.
FSAR Change Request Number: 89-546.2 Related SER Sectior: 6.5.1 SER/SSER Impact: No
TXX-89551 Attachment Page 6 of 10 The two units at Comanche Peak share a common control room (a divider is available when needed).
However, the control room habitability systems are sufficiently capable, diverse, and redundant so that the ability to perform safety funtions will not be impaired, including, in event of an accident at one unit, an orderly shutdown of the other unit.
Thus, the staff finds that Comanche Peak meets the requirements of GDC 5.
The staff has evaluated the control room doses following a LOCA.
The resultant radiation doses of 10.9 rem thyroid and 1.69 rem whole body are within the guide-lines of GDC 19 and, based on this finding and those above, the staff concludes that the control room habitability system is appropriately designed.
6.5 Fngineered-Safety-Feature Atmosphere Cleanup System The engineered-safety-feature (ESF) atmosphere cleanup systems for Comanche Peak consist of process equipment instrumentation to control the release of radioactive material in gaseous effluents (radiciodine and particulate matter) following a DBA.
In the Comanche Peak application, there are three filtration systems designed for this purpose:
the fuel handling building ventilation system, the auxiliary building and radwaste area ventilation system, and the control
. room area ventilation filtration and pressurization systems.
The Technical Specifications for the operation of these sytems will require testing in accord-ance with the guidelines of Regulatory Guide 1.52 (Revision 2, March 1978).
6.5.1 System Description and Evaluation 6.5.1.1 Fuel Handling Building Ventilation System The function of the fuel handling ouilding ventilation system is to collect and process the leakage of radioactive materials from the spent fuel pool and operating areas in the auxiliary building following a fuel handling accident.
The system is designed to maintain a slight negative pressure in the area follow-ing.an accident.
The ESF standby exhaust sytem for each unit is designed as an alternate to the other, a dual / shared system.
Each train has a design capacity of 15,000 cfm and includes the following components:
demister, heating coil, high efficiency particulate air (HEPA) filter, carbon adsolber (4-in.
deep bed), HEPA filter, and fan.
The equipment and components are designed to Quality Group C and seismic Category I, and are located in a seismic Category I structure.
The staff has determined that the spent fuel pool area standby exhaust system is designed in accordance with the guidelines of Regulatory Guide 1.52 (Rev. 1), July 1976.
The HEPA filters and charcoal adsorbers will be tested in place in conformance with ANSI N.510.
Consequently, they will meet the present guidelines in Regulatory Guide 1.52 (Rev. 2).
In its evaluation, the staff has assigned the system decontamination efficiencies of 994 for elemental and organic iodine and 99% for particulate.
Based on this evaluation, the staff finds that the system is designed to control the releases of radio-active materials in gaseous effluents in accordance with applicable regulations I
following a postulated DBA.
1 6.5.1.2 Auxiliary Buildito and Radwaste Area Ventilation System The auxiliary building c radwaste area ventilation system (controlled access area) is designed as an ESF atmospheric cleanup system utilizing the standby 6-20 l
l t
g
-TXX-89551
-Attachment Page 7 ofl0 ex,haust system trains for. each unit described in Section 6.5.1.1.
This design feature allows the controlled-access area exhaust to be transferred from the plant ventilation system to an ESF filtration system in the event of LOCA
. conditions.
The staff finds that the system is designed to control the releases of radioactive materials in gaseous effluents following a postulated DBA, meets the recommendations of Regulatory Guide 1.52, and therefore is acceptable.
'6.5.1.3 Control Room Area Ventilation Filtration and Pressurization Systems The function of the control room area ventilation (habitability) system is to supply nonradioactive air to the control, cable, and equipment rooms after a DBA and to pressurize the control room.
These systems will permit operating personnel to remain in the control room following a DBA.
The control room area ventilation filtration system is a redundant system, with each system having a filter design capacity of 8000 cfm of air and recirculating design capacity of
'at least 50,000 cfm of air.
Makeup air to pressurize the control room is provided at a maximum of 800 cfm from outside air treated and pressurized through redundant filtration trains.
Each system contains the following components:
prefilter, HEDA filter, carbon adsorber (4-in. deep bed), and fan.
Recirculation air heating and cooling' coils are also provided, together with a humidifier, for relative humidity control.
The equipment and components are designed to Quality Group C and seismic Category I and are located in a seismic Category I structure.
The staff has determined that the control room area ventilation habitability system is designed in accordance with the guidelines of Regulatory Guide 1.52 (Rev. 1).
The HEPA filters and charcoal adsorbers will be inplace tested in conformance with ANSI N510, and therefore meet the present guidelines in Regulatory Guide 1.52 (Rev.' 2).
In its evaluation, the staff has assigned the system decontamination efficiencies of 99% for elemental and organic iodine and 99% for particulate.
Based on this evaluation, the staff finds that the system is designed to maintain a suitable control, cable, and equipment room environment following a DBA.
6.5.2 Containment Spray System The containment spray system has the dual function of removing heat and fission products, especially radioactive iodine, from the postaccident containment atmosphere.
The system, with its chemical additive subsystem, is designed to l
maintain proper water chemistry in the containment spray during the injection phase following a DBA and to ensure that appropriate methods are available to i
raise or maintain the pH of the mixed solution in the containment sump during the recirculation of the containment spray.
The chemical additives are provided to enhance iodine fission product removal (SRP Section 6.5.2) and to reduce the likelihood of stress corrosion cracking of austenitic stainless steel after an accident (SRP Section 6.1.1 and BTP MTEB 6-1).
The containment spray system is designed as two independent and redundant trains, either or both of which would be acceptably efficient at fission product removal from the containment atmosphere in the event of a design-basis release.
The containment spray is actuated automatically at 20 psig containment pressure, or it may be actuated by the operator from the control room.
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6-21 L____-_____-_________________
!I TXX-89551 Attachment
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Page 8 of 10 SECTION 6 - ENGINEERED SAFETY FEATURES 6.5.1 System Description and Evaluation SPLB 4.
The exception to Regulatory Guides 1.52 and 1.140 con-(77) cerning laboratory testing criteria for activated carbon has been revised.
TXX-89551 l.
Attachment CPSES/FSAR
}
- Page 9 of 10 '
l 7)
Parts C.S.c and C.S.d. In-Place Testing Criteria:
76 59 ANSI /ASME N509-1980 and ANSI /ASME H510-1980 will be issued for field testing activities in place of the older versions of these codes referenced in this Regulatory Guide.
59 Atmospheric cleanup trains installed at CPSES have two high
-76 efficiency filter banks in series.
In-place testing of only upstream HEPA bank will be performed.
76 In-place testing of the HEPA filter banks and adsorber will not be required following painting, fire and chemical release described in positito C 5.c and C.5.d of this guide.
Only 59 laboratory testing will be performed for carbon efficiencies.
66 This design conforms to the intent of NRC Regulatory Guide 1.51 Revision 2 (03/78).
76 b)
Part C 6. Laboratory Testing Criteria for Activated Carbon:
76 Laboratory testing of activated carbon will be in accordance with ANSI N509 and N510-1980 (which refers to ASTM D3803-79), except for the determination of the efficiency of charcoal to remove radiciodine.
The parameters applicable to new and used charcoal at CPSES shall be applied in the lab test as follows:
l 76 New Charcoal Used Charcoal 76 4" Beds 4" Beds 76 40 ft/ min 40 ft/ min 76 300C & 95% 70% RHf 300C & 70% RH 76 Mdd/ Pre-equilibrated Non-pre-equilibrated 76 f CPZE5 df77 fdst fMd dtid (Mdtt60 16 30 C ddd 70% PH 16 Ildd (f 6
6 80 C ddd 95% VH di ifdtif fdd in 1.57H OLM31 76 The allowable methyl iodide penetration for 99% efficient units shall be 0.2% instead of 0.175% as shown in Table E of the Regulatory Guide.
IA(D)-25 Bold /0verstrike
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Version
TXX-89551 Attachrent-Page 10 of 10 CPSES/FSAR 76' In-place testing of high efficiency filter banks and adsorber will not be required followirs painting, fire and chemical release described in position C 5.c and C.5.d of this guide.
Only laboratory testing will be performed for carbon efficiencies. This design conforms to the intent of NRC Regulatory Guide 1.140 (03/78).
l 5)
Part C.6, Laboratory Testing Criteria for Activated Carbon:
76 76 Laboratory testing of activated carbon will be in accordance with ANSI N509 and N510-1980 (which refers to ASTM D3803-79). except for the determination of the efficiency of charcoal to remove radioiodine. The parameters applicable to new and used charcoal at CPSES shall be applied in the lab test as follows:
76 New and Used Charcoal 76 4" Beds 76 40 ft/ min 76 300C & 95% RHf 76 N66/ Pre-equilibrated d
6 76 f CPEES W171 fdst fHd didd (H6/t6dl f6 30 C id 7fdd 6f 80 g gg l
ifdtifidd in ISTn 038031 76 The allowable methyl iodide penetration for these units shall be 10% as shown in Table 2 of the Regulatory Guide.
76 This design conforms to the intent of NRC Regulatory Guide 1.140 (03/78).
Recul a t ory Guide 1.141 8
Containment Isolation Provisions for Fluid Systems 4400.3 8
plyussion 8
This regulatory guide is not applicable to CPSES: however. the containment isolation is discussed fii Section 6.2, i
Bold /0verstrike 1A(B) 84 Version
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