NRC-93-0077, Application for Amend to License NPF-43.Amend Provides Updated Lab Testng Standard for Surveillance Testing of Activated Charcoal Samples from Control Room Emergency Filtration Sys

Application for Amend to License NPF-43.Amend Provides Updated Lab Testng Standard for Surveillance Testing of Activated Charcoal Samples from Control Room Emergency Filtration Sys

ML20046B749
Person / Time
Site:	Fermi
Issue date:	07/29/1993
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046B750	List: ML20046B757 NRC-93-0077, Application for Amend to License NPF-43.Amend Provides Updated Lab Testng Standard for Surveillance Testing of Activated Charcoal Samples from Control Room Emergency Filtration Sys
References
CON-NRC-93-0077, CON-NRC-93-77 NUDOCS 9308060146
Download: ML20046B749 (8)

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Ed' tewport. Moigan 46106 com*4m July 29,1993 NRC-93-007 7

'U. S. Nuclear Regulatory Cmmission Attn: Document Control Desk Washingtan, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NFF-43

2) Detroit Edison letter to NRC, NRC-91-0160, dated January 29, 1992

3) NRC letter from Mr. William Gammill to Mr. Fred Lakie Nuclear Containment Systems, Inc.,

dated September 24, 1981

Subject:

' Proposed Technical Specification Change (License Amendment) - Charcoal Testing Standards for Control Room Emergency Filtrction System and Standby Gas Treatment Systm Pursuant to 10CFR50.90, Detroit Edison Company hereby proposes to amend Operating License NPF-43 for the Fermi 2 plant by incorporating the enclosed changes into the Plant Technical Specifications. The proposed change provides an updated laboratory testing standard for-  :

surveillance testing of representative ' activated , charcoal samples from  !

the Control Rom Emergency Filtration System and the Standby Gas ,

Treatment System. Additionally, the Cor. trol Room Emergency Filtration System Action Requirements is proposed to be. changed to allow for greater scheduling flexibility in rcrueling outages. ,

This proposal supercedes the Reference 2 proposal on the same subject. ';

In Reference 2, the charcoal testing standards were' to be updated it.  ?

the 1979 version of ASTM D3803. ' At the time Detroit Edison believed:  !

that a more recent 1989 procedure had not been sufficiently proven by .l industry experience to be adopted.

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Following discussions with NRC staf f reviewers Detroit E41 son undertock a review of the industry experience with the 1989 standard ,

and determined that it should be adopted. Adoption of the 1989 j standard is scheduled for Fermi 2's fourth refueling outage scheduled -r i for March'1994. ' Approval is requested with provisions allowing for l i

implementation with the next surveillance' performance during the fourth refueling.

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1 USNRC l July 29,1993 i NRC-93-0077  ;

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i Detroit Edison has evaluated the proposed Technical Specifications against the criteria of 10CFR50.92 and determined that no significant hazards consideration is involved. The Fermi 2 Onsite Review .

Organitation has approved and the Nuclear Safety Review Group has  !

reviewed the proposed Technical Specificttions and concurs with the enclosed determinations. In accordance with 10CFR50.91, Detroit Edison has provided a copy of this letter to the State of Michigan. -].

If you have any questions, please contact Mr. Glen D. Ohlemacher at-(313) 586-4275. 1 Since rely, h

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Enclosure cc: T. G. Colburn '

W. J. Kropp J . B . Ma rt in ,

M. P. Phillip, Supervisor., Electric Operators, Michigan -,

i Public Service Commission - J. R. Padgett 6

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-USNRC .i July 29, 1993 NRC-93-0077 Page 3 $

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.j I, DOUGLAS R. GIPSON, do hereby af firm that the foregoing  !

statements are based on f acts and circumstances which are true and'  !

accurate to the best of my knowledge and belief. ,

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DOUGLAS W. GIPSON i Senior Vice President t

On this day of /tI[ , 1993, before me i personally appeared Douglas R.' Gifson,0>eing first duly. sworn and  !

says that he execut ed the foregoihg as his free act and deed. .  ;

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.i dblL Notary Public

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stCWJ.fE A AfslETIA .

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NOTARY PU3UCSTATE OP huGDCAN MCNEDE COUNTY [

LfY (TArM!SSION EXP. NCW. 20.1995  ;

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Enclosure to NRC-93-0077 Page 1 INTit0 DUCT 10N Technical Specification (TS) surveillances for the Standby Gas Treat. ment System (SGTS) and the Control Room Emergency Filtration System (CREFS) require a laboratory analysis of a representative sample of charcoal from the system filter trains. These analyses are required at least once every 18 months, after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation and following specified events which may degrade charcoal performance. The specified events are structural maintenance on the filter or charcoal adsorber housings, and after painting, fire or chemical release in any ventilation zone communicating with the system. These surveillance requirements are detailed in TS 4.6.5 3.b.2 and 4.6.5 3.c for SGTS, and in TS 4.7.2.1.c.2 and 4.7.2.1.d for CREFS.

Each of these surveillances specify that the sa: ple meet the testing criteria of Hegulatory Position C.6.a of Regulatory Guide (HG) 1.52, Revision 2, March 1978. A maximum methyl iodide penetration is also specified for each system. This penetration is based upon the assumed inefficiency of the filter train when evaluated under accident conditions. The testing acceptance criteria includes margins for filter bypass leakage and potential testing inaccuracies.

Hegulatory Position C.6.a of HG 1.52, Revision 2 refers to ANSI N509-1976 for laboratory testing methods. ANSI N509-1976 refers to RDT M16-1T for detailed procedures. More recent procedures exist which give more consistent and accurate results. The purpose of this submittal is to propose changes to reflect the more recent ASTM D3803-1989 procedures. ASTM D3803-1989 is the most recent generally adopted industry test procedure on this subject. In addition, important test parameters are specified to assure proper test conditions are established.

TS changes are also proposed to alleviate scheduling problems involved in performing CREFS duct leak testing in accordance with Surveillance Required 4.7.2.2 and to facilitate charcoal replacement should a CHEFS charcoal sample fail to meet the acceptance criteria during a refueling outage. Due to the single non-redundant ff)ter train design, the current, action statement requires suspension of fuel handling and core alterations in this situation. However, the action statement does not take into account the reduced source term in this situation. The proposed TS action allows greater flexibility in recognition of the capability of the CHEFS to perform its function in these circumstances, t.

. . j Enclosure to NBC-93-0077 Page 2 l EVAL.UATION 1

e The proposed changes modify the laboratory analysis requirements of the SGTS and CREFS TS by specifying a new testing procedure and 3 important test parameters, such as temperature, relative humidity, air velocity and filter bed depth needed to utilize the procedure.

The test procedure specified is ASTM D3803-1989. This procedure is the most recently issued, generally accepted procedure for the purpose  :

of determining the efficiency of charcoal installed in engineered safety feature (ESP) atmosphere cleanup systems. This procedure provides greater consistency and accuracy than the procedure called for by ANSI N509-1976. Use of the new procedure therefore provides greater assurance that the installed charcoal will perform its intended safety function.

In Reference 3, the NRC staff specifically addressed laboratory methyl lodide testing requirements and the issue of how to perform these tests when the standards referenced by RG 1.52, Revision 2 are updated. In this instance, the issue was that ANSI N509-1976 had been updated by ANSI N509-1980. Reference 3 indicated that the utility has an option of literally invoking ANSI N509-1976 or utilizing the updated standard, ANS] N509-1980. Reference 3 indicates that on a technical basis the 1980 standard was preferred. Consistent with this philosophy, Detroit Edison has been using the procedures of ASTM D3803-1979 which is referred to in the 1980 ANSI standard, for charcoal testing.

This proposal removes the option of invoking the technically inferior ANSI N509-1976 standard and requires the use of the most recent industry accepted testing procedure ASTH D3803-1989 This is consistent with the philosophy, expressed in Reference 3, to use the latest industry guidance when standard updates occur.

ASTM D3803-1989 can be applied using either of tuo test temperatures.

In addition, the procedure has default values for relative humidity, air velocity and filter bed depth which are utilized unless otherwise ,

specified. To assure ASTM D3803-1989 is properly applied, this proposal specifies the test temperature, relative humidity and filter bed depth for each surveillance. The temperature and humidity values provided in the proposed TS bound the expected accident conditions at the filter. The proposed filter bed depth values correspond to the installed bed depths for the filter units.

ASTM D3803-1989 provides that testing be performed at an air velocity of 40 ft/ min unless otherwise specified. For the *.wo-inch CREFS emergency make up air filter this velocity is much greater than that I

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normally found during operation. The make up filter train is operated and tested at 1800 cfm i 10%, ubich corresponds to a maximum velocity of slightly less than 27 ft/ min. The charcoal test is proposed to be ,

conducted at 27 ft/ min to more closely match expected conditions during operation.

When a CREFS charcoal sample fails the surveillance test the required action is to declare the CREFS inoperable until the charcoal is replaced. CREFS duct leakage testing required by Surveillance ,

Requirement 4.7.2.2 also requires the CHEFS to be declared inoperable. In Operational Condition 4,.5, and *, this also requires, in part, suspending Core Alterations and handling of irradiated fuel in secondary containment.

Ilowever, the radiological source term for the fuel handling accident for which this action is meant to preclude is significantly less than the Design Basis Accident source term for which the CREFS charcoal filters are designed.

Detroit Edison has determined that CREFS operation is not necessary for control room radiological protection in accordance with General Design Criteria 19 of 10CFR50 Appendir A in a fuel handling accident provided a SGTS subsystem is operable. Design Calculation 5549 determined that the control room dose from a fuel handling accident with no CREFS filtration is 1 37 rem to the thyroid. This is well below the NHC guideline value of 30 rem to the thyroid used to determine compliance with GDC 19 Calculated whole body dose is unaffected by a non-operational CREFS since the CREFS is only credited with filtering lodine isotopes. Since the SGTS TS (3.6.5 3) assures i one SCTS subsystem is operable while handling fuel or performing Core Alterations, it is not necessary to preclude these activities when the ,

CREFS charcoal filtration capability is lost, charcoal is being replaced or Surveillance Hequirement 4.7.2.2 duct leakage testing is being performed.

The activities under current requirements, affect refueling activities which often form the outage critical path. Providing the proposed exceptions allows necessary activities to be efficiently performed while retaining the added defense provided by the CREFS during other times.

SIGNIFICANT llAZARDS CONSIDEHATION In accordance with 10CFh50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must I

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Enclosure to NRC-93-0077 Page 4 establish that, operation in accordance with the proposed amendment would not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated, or 2) create the possibility of a new or different kind of accident from any accident previously evaluated, or 3) Involve a significant reduction in a margin of safety.

The proposed change provides an updated standard for laboratory analysis of represent.at1ve charcoal samples from filter units in the Standby Gas Treatment System (SGTS) and the Control Room Emergency Filtration System (CHEFS) does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. By providing an improved procedure for charcoal analysis the proposal provides greater assurance that the installed charcoal can perform its design function and, thus, the consequences of evaluated accidents are valid. The method of laboratory analysis has no effect upon how the plant is operated, including the method of sample removal.

Therefore, the probability of any evaluated accident is unchanged.

2) Create t.he possibility of a new or different kind of accident, from any accident previously evaluated. As described in 1) above, the proposal has no effect on the manner of plant operation. The proposal does not involve any change to the plant design. Therefore, the change creates no new accident modes.

3) Involve a significant reduction in a margin of safety. By providing an improved procedure for charcoal analysis the proposal acts to maintain existing safety margins.

The proposed change to modify the action requirements during shutdown conditions to allow fuel handling and core alterations during charcoal replacement and duct leakage surveillance testing does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated. The proposed acilon requirement recognizes that the potential radiological source term due to a fuel handling accident is significantly less than the CREFS design source term. Allowing fuel handling when the CREFS charcoal filtration capability is lost does not result in a significant increase in consequences for the fuel handling accident (Fl!A) since adequate protection is maintained using the required to be operable SGTS subsystem. The evaluation of a FHA under the proposed action requirement determined that a control room thyroid dose of 1 37 rem would result. Tnis is less than I

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. a Enclosure to HRC-93-0077 Page 5 the current evaluation of the Fila which concludes that the FHA is bounded by the more severe loss-of-coolant accident during power [

operation scenario which has an evaluated thyroid dose of 7.1 rem. The change does not afTect system operation and thus does not increase any accident probability. ,

2) Create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not modify the manner of plant operation or the plant design. Thus, no new accident modes are created.

3) involve a significant reduction in a margin of safety. Since adequate protection is maintained by continuing to meet the standards of General Design Criteria 19, safety margins are not significantly reduced.

Based on the above, Detroit Edison has determined that the proposed amendment does not involve a significant hazards consideration.

ENVih0NMENTAL IMPACT L

Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10CFR51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. The allowance to perform charcoal filter media replacement or duct leak testing surveillances while handling fuel would lead to a greater thyroid dose to the control room operator should a fuel handling accident occur. This thyroid dose is calculated at 137 rem which is well below of the NRC guideline of 30 .

mrem to the thyroid for meeting the General Design Criteria 19 of 10 CFR 50 Appendix A. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications do meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement, CONCI.USION Based on the evaluation above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and 2) such activities.will be ,

conducted in compliance with the Commission's regulations and proposed amendments will not be inimical to the common defense and security or to the health and safety of the public.

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