TSTF-24-08, Transmittal of TSTF-602, Revision 0, Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents
| ML24177A043 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force, 99902042 |
| Issue date: | 06/25/2024 |
| From: | Jurek S, Lueshen K, Richards A, Sparkman W, Vaughan J PWR Owners Group, Technical Specifications Task Force |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| TSTF-24-08 | |
| Download: ML24177A043 (1) | |
Text
11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 804-339-7034 Administration by EXCEL Services Corporation TECHNICAL SPECIFICATIONS TASK FORCE A JOINT OWNERS GROUP ACTIVITY TSTF June 25, 2024 TSTF-24-08 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Transmittal of TSTF-602, Revision 0, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents" Enclosed for NRC review is TSTF-602, Revision 0, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents" The following information is provided to assist the NRC staff in prioritizing their review of TSTF-602:
Applicability: TSTF-602 is applicable to all plant types except the AP1000.
Classification: TSTF-602 revises the Ventilation Filter Testing Program to permit the use of alternative challenge agents when testing filters and charcoal adsorber beds.
Specialized Resource Availability: TSTF-602 is a normal priority change. The TSTF requests that TSTF-602 be reviewed within 18 months and be made available for adoption under the Consolidated Line Item Improvement Process (CLIIP).
The Technical Specifications Task Force should be billed for the review of the traveler.
TSTF 24-06 June 25, 2024 Page 2 Should you have any questions, please do not hesitate to contact us.
Jordan L. Vaughan (PWROG/B&W)
Shane M. Jurek (BWROG)
Andrew M. Richards, Jr. (PWROG/W)
Kevin Lueshen (PWROG/CE)
Wesley A. Sparkman (PWROG/AP1000) cc:
Michelle Honcharik, Technical Specifications Branch Shivani Mehta, Technical Specifications Branch
TSTF-602, Rev. 0 PWROG-19, Rev. 0 NUREGs Affected:
Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:
Improvement NRC Fee Status:
Not Exempt Benefit:
Allows Less Stringent Testing Changes Marked on ISTS Rev: 5.0 2194 PWROG RISD & PA (if applicable): LSC-1994 See attached.
Revision History Affected Technical Specifications OG Revision 0 Revision Status: Active Original Issue Revision
Description:
Revision Proposed by:
PWROG Owners Group Review Information Date Originated by OG:
30-Jan-24 Owners Group Comments (No Comments)
Date: 04-Mar-24 Owners Group Resolution:
Approved TSTF Review Information TSTF Received Date:
10-Jun-24 Date Distributed for Review 10-Jun-24 TSTF Comments:
(No Comments)
Date: 24-Jun-24 TSTF Resolution:
Approved NRC Review Information NRC Received Date:
25-Jun-24 NRC provided comments on the draft on June 6, 2024. The traveler justificaiton was revised to explain why Regulatory Guide 1.52, Revision 3, was referenced instead of Revision 4.
NRC Comments:
5.5.10 NUREG(s)- 1430 1431 1432 Only Ventilation Filter Testing Program 25-Jun-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-602, Rev. 0 PWROG-19, Rev. 0 5.5.7 NUREG(s)- 1433 1434 Only Ventilation Filter Testing Program 25-Jun-24 Copyright(C) 2024, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-602, Rev. 0 Page 1 Table of Contents
- 1.
SUMMARY
DESCRIPTION............................................................................................ 2
- 2.
DETAILED DESCRIPTION............................................................................................ 2 2.1.
Background.............................................................................................................. 2 2.2.
Current Technical Specifications Requirements...................................................... 3 2.3.
Reason for the Proposed Change.............................................................................. 3 2.4.
Description of the Proposed Change........................................................................ 4
- 3.
TECHNICAL EVALUATION.......................................................................................... 5 3.1.
Regulatory Guide 1.52, Revision 3.......................................................................... 5 3.2.
HEPA Filter Penetration and Bypass Testing.......................................................... 6 3.3.
Adsorber Inplace Testing......................................................................................... 7 3.4.
Plant-Specific Variations.......................................................................................... 8
- 4.
REGULATORY EVALUATION..................................................................................... 8
- 5.
REFERENCES................................................................................................................... 9 Model Application
TSTF-602, Rev. 0 Page 2
- 1.
SUMMARY
DESCRIPTION The proposed change revises the Ventilation Filter Testing Program (VFTP) to permit the use of alternate challenge agents when performing inplace testing of Engineered Safety Feature (ESF) ventilation system high efficiency particulate air (HEPA) filters and charcoal adsorbers. The alternative challenge agents are permitted by industry standards and Nuclear Regulatory Commission (NRC) Regulatory Guides (RGs). The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-14341.
- 2. DETAILED DESCRIPTION 2.1. Background NUREG-1430, NUREG-1431, and NUREG-1432, Specification 5.5.10, and NUREG-1433 and NUREG-1434, Specification 5.5.7, all titled "Ventilation Filter Testing Program (VFTP),"
require establishment of a program to test the ESF ventilation filter systems. Various industry and NRC standards are referenced in the STS and plant-specific Technical Specifications (TS),
such as NRC RG 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revisions 1, 2, 3 and 4, American National Standards Institute (ANSI) N510-1975 and -1980, "Testing of Nuclear Air-Cleaning Systems,"
American Society of Mechanical Engineers (ASME) N510-1989 and -2007, "Testing of Nuclear Air Treatment Systems," and ASME AG-1-2009, "Code on Nuclear Air and Gas Treatment."
The VFTP is invoked by various ESF ventilation filter system specifications, such as the Control Room Emergency Filtration System, Fuel Building Air Cleanup System, Iodine Cleanup System, Shield Building Air Cleanup System, Emergency Core Cooling System Pump Room Exhaust Air Cleanup System, Penetration Room Exhaust Air Cleanup System, and the Standby Gas Treatment System. These system names vary by plant. The ESF ventilation systems associated with the control room protect the operators from radiation, smoke, and hazardous chemicals. The remainder of the ESF ventilation filter systems reduce, via filtration and adsorption, the radioactive material released to the environment following an accident.
The TS ESF ventilation filter system specifications contain a Surveillance Requirement that requires filter testing in accordance with the VFTP at a Frequency in accordance with the VFTP.
The Surveillance Requirements and their associated TS Bases do not describe the VFTP testing or testing standards.
1 NUREG-1430 provides the STS for Babcock & Wilcox plant designs.
NUREG-1431 provides the STS for Westinghouse plant designs.
NUREG-1432 provides the STS for Combustion Engineering plant designs.
NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.
NUREG-1434 provides the STS for BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.
TSTF-602, Rev. 0 Page 3 2.2. Current Technical Specifications Requirements NUREG-1430 through NUREG-1432, Specification 5.5.10, and NUREG-1433 and NUREG-1434, Specification 5.5.7, states:
5.5.[10/7] Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].
ESF Ventilation System Flowrate
[ ]
[ ]
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].
ESF Ventilation System Flowrate
[ ]
[ ]
Paragraph c of the VFTP requires laboratory testing of charcoal adsorbers, Paragraph d requires pressure drop testing, and Paragraph e requires heater testing. These requirements are not affected by the proposed change.
The STS program references RG 1.52, Revision 2, and ASME N510-1989, but plant-specific TS may reference different standards. All of the standards require testing the HEPA filter penetration and system bypass using a challenge aerosol. The older standards require using dioctylphthalate (DOP) and some plant TS also state that DOP is used. All of the standards require testing the charcoal adsorber penetration and system bypass using a challenge gas. The older standards require using Trichloro(mono)fluoromethane refrigerant (R-11) or similar compounds, and some plant TS also state that halogenated hydrocarbon refrigerant is used.
2.3. Reason for the Proposed Change The current challenge agents (DOP and R-11) impose challenges to licensees. DOP is a suspected carcinogen. R-11 production was phased out in 1995. Reclaimed R-11 is available
TSTF-602, Rev. 0 Page 4 but at increasing cost and difficulty. Revision 3 of RG 1.52 permits alternative challenge agents which have advantages over DOP and R-11. The proposed change will permit the use of those alternatives in accordance with NRC-endorsed industry standards. No other changes to the testing methods, testing requirements, acceptance criteria, or accident analysis assumptions are proposed.
2.4. Description of the Proposed Change Paragraphs a and b of the VFTP are revised as shown below. Added words are in italics.
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%]. An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
The TS Bases are not affected by the proposed change.
NUREG-2194, "Standard Technical Specifications - Westinghouse Advanced Passive 1000 (AP1000) Plants," contains a Ventilation Filter Testing Program. However, that program references RG 1.52, Revision 3, as the standard for testing. Therefore, the proposed change is not necessary.
Two corrections are made to the STS. In NUREG-1432, VFTP paragraph b, the placeholder table for the ESF ventilation system name and flowrate was missing and is added. In NUREG-1434, VFTP paragraphs a and b end with a colon instead of with a period as in the other STS. The colon is replaced with a period.
There is a discrepancy between the STS and the referenced Regulatory Guides. The STS uses the term "inplace", but the Regulatory Guides uses the term "in-place." For consistency with the STS, the term "inplace" is used except in quoted material.
TSTF-602, Rev. 0 Page 5 A model application is attached. The model should be used by licensees desiring to adopt the traveler following NRC approval. Plant-specific variations are discussed below and will be described by licensees following the model application.
- 3. TECHNICAL EVALUATION The STS and many plant TS require ventilation filter testing to be performed in accordance with RG 1.52, Revision 2, dated March 1978. In the Value/Impact Statement published October 2000 with the draft of RG 1.52, Revision 32, the NRC concluded that:
The guide would be useful to industry because it would notify them in a consistent manner of changes in ESF filter system testing and inspection provisions and would thus promote understanding of current NRC positions and prevent any unnecessary costs being applied to meet a provision no longer recommended by the NRC staff. None of the changes is expected to impose significant additional burdens on applicants or licensees.
Some of the changes may relax certain guide positions but without compromise to safety, thereby reducing cost and effort. There would be no costs associated with the revised positions related to testing and inspection of new and used charcoal because the revised positions are in accordance with GL 99-02.
This Traveler proposes to revise the STS to prevent any unnecessary costs being applied to meet a provision no longer recommended by the NRC staff'; specifically, the exclusive use of DOP and R-11 challenge agents for ESF ventilation filter testing.
3.1. Regulatory Guide 1.52, Revision 3 RG 1.52, Revision 3, permits the use of alternative challenge agents. Section C.6.3 discusses HEPA filter testing and states:
In accordance with ASME N510-19893 and Article TA-1000 of ASME AG-1-19974, the standard challenge aerosol used in the in-place leak testing of HEPA filters is polydisperse droplets of dioctyl phthalate (DOP), also known as di-2-ethylhexyl-phthalate (DEHP). The 0.3 micrometer monodisperse DOP aerosol is used for efficiency testing of individual HEPA filters by manufacturers and Filter Test stations. Alternative challenge agents may be used to perform in-place leak-testing of HEPA filters when their selection is based on the following.
- 1. The challenge aerosol has the approximate light scattering droplet size specified in Article TA-1130 of ASME AG-1-1997.
- 2. The challenge aerosol has the same in-place leak test results as DOP.
- 3. The challenge aerosol has a similar lower detection limit, sensitivity, and precision as DOP.
2 Value/Impact Statement attached to Draft RG DG-1102 (Proposed Revision 3 to RG 1.52), issued October 2000, ADAMS Accession No. ML003756180.
3 American Society of Mechanical Engineers, "Testing of Nuclear Air-Treatment Systems," ASME N510-1989.
Reaffirmed 1995.
4 American Society of Mechanical Engineers, "Code on Nuclear Air and Gas Treatment," ASME/ANSI AG-1-1997.
TSTF-602, Rev. 0 Page 6
- 4. The challenge aerosol causes no degradation of the HEPA filter or the other ESF air cleaning system components under test conditions.
- 5. The challenge aerosol is listed in the Environmental Protection Agencys "Toxic Substance Control Act" (TSCA) inventory for commercial use.
The RG also cautions users that care should be taken to ensure that the aerosol generator is compatible with the selected alternative challenge agent (see NRC Information Notice 99-34, "Potential Fire Hazards in the Use of Polyalphaolefin in Testing of Air Filters," December 28, 1999.)
RG 1.52, Revision 3, Section C.6.4 discusses charcoal adsorber testing and states:
In accordance with ASME N510-1989 and Section TA of ASME AG-1-1997, the standard challenge gas used in the in-place leak testing of adsorbers is Refrigerant-11 (trichloromonofluoromethane). Alternative challenge gases may be used to perform in-place leak testing of adsorbers, when their selection is based on meeting the characteristics specified in Appendix TA-C of ASME AG-1-1997.
As discussed below, the alternative challenge agents are sufficient to verify that the safety function of the ESF filters is met and, thus, these changes do not reduce the safety of the ventilation systems.
The VFTP in most plant's TS reference RG 1.52, Revision 2, which was issued in 1978.
RG 1.52 describes both design and testing requirements acceptable to the NRC and references various design standards that were applicable at the time, such as ANSI N509-1976, "Nuclear Power Plant Air-Cleaning Units and Components. " However, Revision 3 of RG 1.52 references more recent design standards which are not applicable to most operating plants, such as ASME N509-1989, and ASME AG-1-1997, "Code on Nuclear Air and Gas Treatment."
Replacing all VFTP references to RG 1.52, Revision 2, with a reference to Revision 3 would not be consistent with the licensing and design basis for most plants. Therefore, the proposed change limits the use of RG 1.52, Revision 3, to only the selection of the challenge agents.
The latest revision of RG 1.52 is Revision 4. The proposed change references RG 1.52, Revision 3, which endorses ASME N510-1989. The existing STS VFTP contains multiple bracketed references to ASME N510-1989. Many plant TS also reference ASME N510-1989.
While both Revision 3 and Revision 4 permit the use of alternative challenge agents, Revision 4 references ASME N510-2007, and there are no existing references to ASME N510-2007 in the STS. Therefore, for consistency within the STS, Regulatory Guide 1.52, Revision 3, is referenced in the proposed change. Note that for licensees whose TS already reference RG 1.52, Revision 3 or Revision 4, the proposed change is not needed to use alternative challenge agents.
3.2. HEPA Filter Penetration and Bypass Testing The STS requires demonstration for each of the ESF systems that an inplace test of HEPA filters shows a penetration and system bypass < [0.05]% when tested in accordance with [RG 1.52, Revision 2, and ASME N510-1989] at the specified system flowrate [+/- 10%]. The bracketed-values are typical but plant-specific. A penetration of less than 0.05% is indication of a 99%
removal efficiency for particulates in accident dose evaluations.
TSTF-602, Rev. 0 Page 7 RG 1.52, Revision 2, Section 5, "In-Place Testing Criteria," requires testing in accordance with ANSI N510-1975. Section 10 of ANSI N510-1975 describes the inplace test of HEPA filter banks. With the system fan or an auxiliary blower operating, DOP aerosol is injected upstream of the filters. Concentration measurements are made upstream and downstream of the filters and percent penetration is calculated from the ratio of DOP concentrations in the filtered air (downstream reading) and the unfiltered air (upstream reading). The 1980 version of N510 describes the test in a similar manner. The 1989 version of ASME N510 describes a similar test, but refers to "DOP aerosol (or suitable alternate.)" The 1975, 1980, and 1989 standards define the DOP aerosol in the same manner and require the same mean droplet size distribution.
RG 1.52, Revision 3, Section 6, "In-Place Testing Criteria," Section 6.3, describes inplace testing of HEPA filters and requires the testing to be in accordance with ANSI N510-1989. However, RG 1.52, Revision 3, permits the use of alternative test agents provided specified selection criteria are met. Therefore, the only proposed change is the allowance to use an alternative challenge agent that meets the RG 1.52, Revision 3, selection criteria. The use of the alternative challenge agent is acceptable regardless of the testing standard referenced in the STS or a plant's TS, such as RG 1.52, Revision 2, ANSI N510-1975, -1980, or ASME N510-1989.
3.3. Adsorber Inplace Testing The STS requires demonstration for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [RG 1.52, Revision 2, and ASME N510-1989] at the specified system flowrate [+/- 10%].
RG 1.52, Revision 2, Section 5, "In-Place Testing Criteria," requires testing in accordance with ANSI N510-1975. Section 12 of ANSI N510-1975 describes the inplace test of adsorber banks.
A refrigerant tracer gas is injected into the air stream upstream of the adsorber bank, tracer concentrations are determined downstream and upstream of the bank, and penetration (percent leakage) is determined from the ratio of downstream to upstream concentration. The standard states that tracer gas R-11 is preferred, but R-112 is an acceptable alternate. The 1980 version of N510 describes the test in a similar manner. The 1989 version of ASME N510 describes a similar test, and also states that R-11 is preferred but R-112 or R-112A is an acceptable alternative.
RG 1.52, Revision 3, Section 6, "In-Place Testing Criteria," Section 6.4, describes inplace testing of adsorber banks and requires the testing to be in accordance with ANSI N510-1989. However, RG 1.52, Revision 3, permits the use of alternative challenge gases when their selection is based on meeting the characteristics specified in ASME AG-1-1997, Appendix TA-C, "Challenge Gas and Aerosol Substitute Selection Criteria." Therefore, the only proposed change is the allowance to use an alternative challenge gas that meets the RG 1.52, Revision 3, selection criteria. The use of the alternative challenge gas is acceptable regardless of the testing standard referenced in the STS or a plant's TS, such as RG 1.52, Revision 2, ANSI N510-1975, -1980, or ASME N510-1989.
TSTF-602, Rev. 0 Page 8 3.4. Plant-Specific Variations Plant TS not based on the STS typically include ESF ventilation filter testing requirements in Surveillance Requirements for each ESF ventilation system instead of in a single Ventilation Filter Testing Program. Such an organization does not affect the testing requirements and the proposed change is equally applicable to this arrangement.
Plant TS may reference testing standards that are different from those listed in the STS (RG 1.52, Revision 2, and ASME N510-1989), such as ANSI N510-1975 and ANSI N510-1980, or may not reference RG 1.52 or N510. These references do not need to be changed in order to adopt the proposed challenge agent exception. All of the references describe similar testing techniques which are compatible with the alternative challenge agents permitted under RG 1.52, Revision 3.
Plant TS may explicitly reference the use of DOP, halogenated hydrocarbon refrigerant test gas, or Freon (a commercial name for R-11). Removal of these challenge agent descriptions and addition of the proposed challenge agent exception is within the scope of the proposed change.
- 4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.
Regulation 10 CFR 50.36(c) states that technical specifications will include items in several categories, which include Paragraph (3), "Surveillance requirements." It defines surveillance requirements as, "requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The proposed change revises the Ventilation Filter Testing Program, which is referenced in surveillance requirements.
Regulation 10 CFR 50.36(c) states that technical specifications will include items in several categories, which include Paragraph (5), "Administrative controls," which includes "the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The Ventilation Filter Testing Program is in the Administrative controls section of the TS.
Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
TSTF-602, Rev. 0 Page 9 Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.
Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications. The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.
The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." Since the administrative controls do not include bases, the proposed traveler does not revise the Bases, and therefore, complies with 10 CFR 50.36(a)(1).
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.
- 5. REFERENCES None.
TSTF-602, Rev. 0 Model Application
TSTF-602, Rev. 0 Page 1
[DATE]
10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 PLANT NAME DOCKET NO. [50]-[xxx]
SUBJECT:
Application to Revise Technical Specifications to Adopt TSTF-602, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].
[LICENSEE] requests adoption of TSTF-602, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-602 revises the Ventilation Filter Testing Program (VFTP) to permit the use of alternate challenge agents when performing inplace testing of Engineered Safety Feature (ESF) ventilation system high efficiency particulate air (HEPA) filters and charcoal adsorbers. The alternative challenge agents are permitted by industry standards and Nuclear Regulatory Commission (NRC) Regulatory Guides (RGs).
The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. [Attachment 2 provides revised (clean) TS pages.]
[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.
There are no regulatory commitments in this letter.
[In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] official.]
[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.
Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]
TSTF-602, Rev. 0 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Enclosure:
Description and Assessment Attachments: 1.
Proposed Technical Specification Changes (Mark-Up)
- 2.
[Revised Technical Specification Pages]
[The attachments are to be provided by the licensee and are not included in the model application.]
cc:
NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact
TSTF-602, Rev. 0 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
[LICENSEE] requests adoption of TSTF-602, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-602 revises the Ventilation Filter Testing Program (VFTP) to permit the use of alternate challenge agents when performing inplace testing of Engineered Safety Feature (ESF) ventilation system high efficiency particulate air (HEPA) filters and charcoal adsorbers. The alternative challenge agents are permitted by industry standards and Nuclear Regulatory Commission (NRC) Regulatory Guides (RGs).
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation
[LICENSEE] has reviewed the safety evaluation for TSTF-602 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-602. [LICENSEE] has concluded that the justifications presented in TSTF-602 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.
2.2 Variations
[LICENSEE is not proposing any variations from the TS changes described in TSTF-602 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-602 or the applicable parts of the NRC staffs safety evaluation:]
[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-602 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-602 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-602 to the [PLANT] TS.]
[The [PLANT] TS contain requirements that differ from the STS on which TSTF-602 was based but are encompassed in the TSTF-602 justification. [This variation includes plant TS that reference different testing standards or that reference the challenge agent name in the TS.]
Describe the differences and why TSTF-602 is still applicable.]
[The [PLANT] TS are not based on the standard TS on which TSTF-602 is based. (Describe the differences. For example, plant TS without a VFTP and the equivalent testing requirements are in surveillance requirements.)]
TSTF-602, Rev. 0 Page 4
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Analysis
[LICENSEE] requests adoption of TSTF-602, "Revise the Ventilation Filter Testing Program to Permit Alternate Challenge Agents," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-602 revises the Ventilation Filter Testing Program (VFTP) to permit the use of alternate challenge agents when performing inplace testing of Engineered Safety Feature (ESF) ventilation system high efficiency particulate air (HEPA) filters and charcoal adsorbers. The alternative challenge agents are permitted by industry standards and Nuclear Regulatory Commission (NRC) Regulatory Guides (RGs).
[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change permits the use of NRC-approved alternate challenge agents when testing HEPA filters and charcoal adsorbers in ESF ventilation systems. The performance of ventilation system testing is not an initiator to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The results of HEPA filter and charcoal adsorber testing using the alternative challenge agents will continue to determine if the ESF ventilation systems can perform the functions assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change permits the use of NRC-approved alternate challenge agents when testing HEPA filters and charcoal adsorbers in ESF ventilation systems. No new or different accidents result from utilizing the proposed change. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The ESF ventilation system testing methods will not change other than the challenge agent. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
TSTF-602, Rev. 0 Page 5 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change permits the use of NRC-approved alternate challenge agents when testing HEPA filters and charcoal adsorbers in ESF ventilation systems. The proposed change does not negate any existing requirement, and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. The ESF ventilation filter testing acceptance criteria are not changed, and, as a result, the margins of safety are unaffected.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
4.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
TSTF-602, Rev. 0 Technical Specifications Changes
Programs and Manuals 5.5 Babcock & Wilcox STS 5.5-9 Rev. 5.0 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:
- a.
Identification of a sampling schedule for the critical variables and control points for these variables,
- b.
Identification of the procedures used to measure the values of the critical variables,
- c.
Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage,
- d.
Procedures for the recording and management of data,
- e.
Procedures defining corrective actions for all off control point chemistry conditions, and
- f.
A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.
5.5.10 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
TSTF-602, Rev. 0
Programs and Manuals 5.5 Babcock & Wilcox STS 5.5-10 Rev. 5.0 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (VFTP) (continued)
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%]. An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity
[ ]
[See Reviewer's
[See
[See Reviewer's Note]
Reviewer's Note]
Note]
REVIEWER'S NOTE----------------------------------------
The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.
ASTM D 3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period performed at a temperature of 30°C (86°F) and a relative humidity (RH) of 95%
(or 70% RH with humidity control), and it has more stringent tolerances that improve repeatability of the test.
Allowable Penetration = [(100% - Methyl Iodide Efficiently
- for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]
When ASTM D3803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following:
Safety factor 2 for systems with or without humidity control.
Humidity control can be provided by heaters or an NRC-approved analysis that demonstrates that the air entering the charcoal will be maintained less than or equal to 70 percent RH under worst-case design-basis conditions.
TSTF-602, Rev. 0
Programs and Manuals 5.5 Westinghouse STS 5.5-9 Rev. 5.0 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit SG tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:
- a.
Identification of a sampling schedule for the critical variables and control points for these variables,
- b.
Identification of the procedures used to measure the values of the critical variables,
- c.
Identification of process sampling points, which shall include monitoring the discharge of the condensate pumps for evidence of condenser in leakage,
- d.
Procedures for the recording and management of data,
- e.
Procedures defining corrective actions for all off control point chemistry conditions, and
- f.
A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.
5.5.10 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
TSTF-602, Rev. 0
Programs and Manuals 5.5 Westinghouse STS 5.5-10 Rev. 5.0 5.5 Programs and Manuals 5.5.10 Ventilation Filter Testing Program (VFTP) (continued)
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%]. An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity (fps)
[ ]
[See Reviewer's
[See
[See Reviewer's Note]
Reviewer's Note]
Note]
REVIEWER'S NOTE----------------------------------------
The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.
ASTM D 3803-1989 is a more stringent testing standard because it does not differentiate between used and new charcoal, it has a longer equilibration period performed at a temperature of 30°C (86°F) and a relative humidity (RH) of 95%
(or 70% RH with humidity control), and it has more stringent tolerances that improve repeatability of the test.
Allowable Penetration = [(100% - Methyl Iodide Efficiency
- for Charcoal Credited in Licensee's Accident Analysis) / Safety Factor]
When ASTM D3803-1989 is used with 30°C (86°F) and 95% RH (or 70% RH with humidity control) is used, the staff will accept the following:
Safety factor 2 for systems with or without humidity control.
Humidity control can be provided by heaters or an NRC-approved analysis that demonstrates that the air entering the charcoal will be maintained less than or equal to 70 percent RH under worst-case design-basis conditions.
TSTF-602, Rev. 0
Programs and Manuals 5.5 Combustion Engineering STS 5.5-9 Rev. 5.0 5.5 Programs and Manuals 5.5.9 Secondary Water Chemistry Program (continued)
- f.
A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events, which is required to initiate corrective action.
5.5.10 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1] at the system flowrate specified below [+/- 10%].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%]. An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity
[ ]
[See Reviewer's
[See
[See Reviewer's Note]
Reviewer's Note]
Note]
TSTF-602, Rev. 0
Programs and Manuals 5.5 General Electric BWR/4 STS 5.5-5 Rev. 5.0 5.5 Programs and Manuals 5.5.6 Pre-Stressed Concrete Containment Tendon Surveillance Program (continued)
The provisions of SR 3.0.3 are applicable to the Tendon Surveillance Program inspection frequencies. ]
5.5.7 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2, ASME N510-1989, and AG-1].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%]. An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%]. An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below.
ESF Ventilation System Penetration RH Face Velocity (fps)
[ ]
[See Reviewer's
[See
[See Reviewer's Note]
Reviewer's Note]
Note]
TSTF-602, Rev. 0
Programs and Manuals 5.5 General Electric BWR/6 STS 5.5-5 Rev. 5.0 5.5 Programs and Manuals 5.5.7 Ventilation Filter Testing Program (VFTP)
A program shall be established to implement the following required testing of Engineered Safety Feature (ESF) filter ventilation systems at the frequencies specified in [Regulatory Guide ], and in accordance with [Regulatory Guide 1.52, Revision 2; ASME N510-1989; and AG-1].
- a.
Demonstrate for each of the ESF systems that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below
[+/- 10%].: An alternative challenge aerosol may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.3.
ESF Ventilation System Flowrate
[ ]
[ ]
- b.
Demonstrate for each of the ESF systems that an inplace test of the charcoal adsorber shows a penetration and system bypass < [0.05]% when tested in accordance with [Regulatory Guide 1.52, Revision 2, and ASME N510-1989] at the system flowrate specified below [+/- 10%].: An alternative challenge gas may be used in accordance with Regulatory Guide 1.52, Revision 3, Section 6.4.
ESF Ventilation System Flowrate
[ ]
[ ]
- c.
Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in [Regulatory Guide 1.52, Revision 2], shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and the relative humidity specified below:
ESF Ventilation System Penetration RH Face Velocity (fps)
[ ]
[See Reviewer's
[See
[See Reviewer's Note]
Reviewer's Note]
Note]
REVIEWER'S NOTE----------------------------------------
The use of any standard other than ASTM D3803-1989 to test the charcoal sample may result in an overestimation of the capability of the charcoal to adsorb radioiodine. As a result, the ability of the charcoal filters to perform in a manner consistent with the licensing basis for the facility is indeterminate.
TSTF-602, Rev. 0