ULNRC-03402, Application for Amend to License NPF-30,changing TS 3/4.7.7,3/4.9.13 & Corresponding Bases Re Charcoal Test Methodology for Emergency Exhaust Sys

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Application for Amend to License NPF-30,changing TS 3/4.7.7,3/4.9.13 & Corresponding Bases Re Charcoal Test Methodology for Emergency Exhaust Sys
ML20115J004
Person / Time
Site: Callaway Ameren icon.png
Issue date: 07/18/1996
From: Schnell D
UNION ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115J007 List:
References
ULNRC-03402, ULNRC-3402, NUDOCS 9607230411
Download: ML20115J004 (16)
v • d • e


Text

. I901 Chouteau Avenue

. Post Othw Scx 149 St lours. Missoun 63!E6

..- nuurao UNION DonaldF. Schnell Etscnuc ty;;;~~

ddh July 18, 1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555 Gentlemen: ULNRC-0 34 02 l l

l DOCKET NUMBER 50-483 '

CALLAWAY PLANT CHARCOAL TEST METHODOLOGY - EMERGENCY EXHAUST SYSTEM Union Electric Company herewith transmits an application lor amendment to Facility Operating License No. NPF-30 for the Callaway Plant.

This ame.'dment application includes changes to the Surveillance 3equirements c of Technical Specifications 3/4.7.7, 3/4.9.13 and corresponding Bases. The changes implement an updated charcoal test methodology for the emergency exhaust system. The updated methodology, ASTM D-3803-1989, is consistent with that used for the control room ventilation system approved in Callaway License Amendments 96 and 106.

The Callaway Plant Onsite Review Committee and the Nuclear Safety Review Board have reviewed this amendment application. Attachments 1 through 4 provide the Safety Evaluation, Significant Hazards Evaluation, Environmental Consideration, and proposed Technical Specification revisions, respectively, in support of this request. It has been determined that this amendment application does not involve an unreviewed i safety question as determined per 10CFR50.59 nor a l

significant hazard consideration as determined per 10CFR50.92. Pursuant to 10CFR51.22 (b) , no environmental assessmant need be prepared in connection with the issuance of this amendment.

l 9607230411 960718 PDR ADOCK 05000483 N

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U.S. Nuclear Regulatory Commission l . Page 2 It is requested that when this amendment is i l issued, an additional 30 days be allowed for l implementation. If you have any questions on this request, please contact us.

1 Very truly yours, 5

Donald F. Schnell DES /plr l

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i l ._ STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

  • Alan C.-Passwater, of lawful age, being first duly sworn i l upon' oath says that-he is Manager, Licensing and Fuels l (Nuclear) for Union Electric Company; that he has read the i' foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein j stated are true and correct co the best of his knowledge, i

t information and belief.

By L

Alan C. Passwater .

Manager, Licensing and Fuels j Nuclear l

SUB ED and sworn to before me this M NM day of -

, 1996. 8

/ e 0bM e av BARBARA J. PFAFY.

NOTARY PUBLIC-STATE OF MISSOURI MY COMMISSION EXPIRES APRIL 22,199Z SL LOUIS COUN1%

l g yw --'p+7 e -

. __ - _ _ . _ _ = . _ _ . . _ . _ _ . - - _

cc: T. A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 L. Joe' Callan Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Kristine M. Thomas (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Don Woodlan TU Electric 1601 Bryan Street Dallas, TX 75201-3411 Pat Nugent Pacific Gas & Electric Regulatory Services P.O. Box 56

( Avila Beach, CA 93424 d

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ATTACHMENT 1 1

SAFETY EVALUATION i

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  • ULNRC-0 34 0 2

. Attachment 1

, , Page 1 of 4 Safety Evaluation Eronosed Chance This license amendment request proposes to revise surveillance requirements 4.7.7.b.2, 4.7.7.c, and 4.9.13.b.2 and 4.9.13.c to reflect a proposed change to the acceptance criteria for the testing of carbon samples from the auxiliary / fuel building emergency exhaust system charcoal adsorbers. This proposed change would adopt ASTM D-3803-1989 as the laboratory testing standard for charcoal samples from the charcoal adsorbers (FGG02 A,B) in the auxiliary / fuel building emergency exhaust system.

Laboratory testing of the carbon samples taken from the charcoal adsorbers will be performed at 30 degrees Centigrade ( C) and 70% relative humidity for a methyl iodide penetration of 2%, instead of a 1% limit at 80 C and 70% relative humidity.

EvaluatioD The fuel building heating ventilation and air conditioning (HVAC) system and the auxiliary building HVAC system are discussed in Callaway Final Safety Analysis Report (FSAR)

Sections 9.4.2 and 9.4.3. These sections describe the l interrelationship of the emergency exhaust system for these  ;

two buildings. l f'

The emergency exhaust system collects and processes the fuel building atmosphere in the event of a fuel handling

, accident. During operation of the emergency exhaust system, .

' I the nonessential fuel building HVAC air paths are isolated i

and the building exhausted to assure that fission products l and particulate matter are collected and processed. The fuel building intake air system is provided with two motor-operated dampers in a series arrangement. Indication of high radiation levels in the fuel building will initiate automatic transfer to the emergency exhaust system. In this

! lineup, the emergency exhaust system will maintain the fuel l building at a negative pressure of 0.25 in. w.g. relative to the outside atmosphere.

The emergency exhaust system serves the auxiliary building l only following a loss of coolant accident (LOCA) to assure that all emergency core cooling system (ECCS) leakage to the auxiliary building atmosphere and the containment air purged

, via.the hydrogen purge system are processed. All ductwork

! which is not required for operation of the emergency exhaust

{ system and penetrates the auxiliary building boundary is automatically isolated. These nonessential systems are l

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i ULNRC-0 3 4 0 2

. Attachment 1 )

. Page 2 of 4 I

provided with two motor-operated dampers in a series j arrangement at the boundary penetrations. These will clos <3 l automatically following receipt of an SIS. In this lineup, I the emergency exhaust system will maintain a negative ]

pressure of 1/4 in. w.g. to assure that all leakage is into the auxiliary building. Charcoal samples are routinely l

tested to verify filter efficiency: every eighteen months; upon achieving total run time of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />; and following a significant event or activity, such as painting, welding, or fire, which could potentially create fumes in an amount that could affect charcoal filter efficiency. Technical Specification Surveillance Requirements 4.7.7 and 4.9.13 specify that charcoal is to be tested per the guidance of Regulatory Guide 1.52, Rev. 2, March 1978, position C.6.a.3.

The Regulatory Guide, in turn, specifies the testing is to be performed in accordance with ANSI N509-1976. ANSI N509-1976 specifies that testing is to be performed in accordance with Military Specification RDT M-16-1T, with no year specified. An issue has been identified with regard to the te1 ting conditions specified by RDT M-16-1T and ANSI N509-l '. 7 6 . The RDT M-16-1T test consists of three stages, with the air flow in each stage at 25 C, whereas ANSI N509-1976 specifies that the air used in the second stage be at 80 C.

Technically, this test cannot be completed by injecting 80 C and 70% relative humidity air into a test specimen that has been stabilized at 25 C. Doing this causes condensation to form in the charcoal sample, which disqualifies the test.

Callaway charcoal samples are analyzed by an outside testing laboratory, which recognized the problem described above and changed their test method to the latest version of RDT M16-1T (the 1977 version), as allowed by ANSI N509-1976.

RDT M-16-1T-1977 specifies that 80 C air be used for all three stages of the test, which eliminates the condensation problem. In order to remove the confusion in the current Technical Specifications concerning the correct testing protocol required, the referenced testing protocol for these charcoal samples is being revised to ASTM D-3803-1989, which specifies the testing to be performed at 30*C and 70%

relative humidity with the exception that methyl iodide penetration shall not exceed 2%, instead of a 1% limit.

The 30*C at 70% relative humidity ASTM D-3803-1989 test to be performed on charcoal samples from FGG02A,B is representative of the postulated conditions for the auxiliary building or fuel building following a design basis

! accident. The current specification 3/4.7.7 and 3/4.9.13 penetration limit of 1% for testing at 80*C and 70% relative l humidity per test standard RDT M-16-1T is less conservative t than a 2% penetration limit for testing at 30'C and 70%

relative humidity, due to the more stringent tolerances

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ULNRC-03402 l

, Attachment 1 l l , Page 3 of 4 l

placed upon temperature and humidity in ASTM D-3803-1989, as ]

well as the test being performed at the lower temperature of  ;

30'C. Thus, testing the charcoal using the new protocol I will provide greater assurance that the charcoal filters will perform at an efficiency of at least 90%.

This change in test protocol is consistent with that approved in callaway License Amendments 96 and 106.

Amendment 96 eliminated the containment spray additive system and replaced it with a passive Recirculation Fluid pH Control (RFPC) system. Amendment 96 as supplemented by Amendment 106 revised the control room dose charcoal filter assumption from 90% to 95% efficiency. The updating of the test protocol to ASTM D-3803-1989 at 30 C, 70% relative humidity and a methyl iodide penetration not to exceed 2%

supported this revised assumption. This amendment request does not involve a change in assumption of the efficiency for the emergency exhaust system units FGG02A,B. The current analysis for the fuel handling accident and the LOCA ,

assume a 90% efficiency. This change in test protocol and j the design residence time of 20.25 seconds would allow '

future changes to the charcoal filter efficiency of up to 95%. Any changes would be done under the criteria of 10CFR50.59. i Unreviewed Safety Ouestion Evaluation l

The changes to the technical specifications discussed above  !

do not involve an unreviewed safety question because i operation of Callaway Plant with these changes would not:  !

1. Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.

The requested change to the charcoal sample j surveillance acceptance criteria for the fuel building and auxiliary building emergency exhaust system will not affect the method of operation of the system. The testing of the charcoal filter samples will continue to be performed in accordance with NRC-accepted methods and acceptance criteria, and the new test protocol will still ensure filter efficiency is maintained equal to or greater than 90%. There are no changes to the I emergency exhaust system and it will continue to l function in a manner consistent with the safety analysis assumptions and the plant design basis. There

, will be no degradation in the performance of or an increase in the number of challenges to equipment assumed to function during an accident. Therefore, the proposed changes will not increase the probability or

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ULNRC-03402 Attachment 1 Page 4 of 4 consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR.

2. Create a possibility for an accident or malfunction of a different type than previously evaluated in the safety analysis report.

The changes to the surveillance requirements are being made to adopt current NRC-accepted methods of testing charcoal samples. These changes will not affect the method of operation of the applienble systems and the laboratory testing will continue to demonstrate the required adsorber performance after a design-basis LOCA or fuel handling accident. Therefore, the changes will not create the possibility for an accident or malfunction of a different type than previously evaluated.

3. Reduce the margin of safety as defined in the bases for any Technical Specification.

The new charcoal adsorber sample laboratory testing protocol is more stringent than the current testing practice and meets current NRC-approved test methods.

The new testing criteria will continue to demonstrate the required adsorber performance after a design-basis LOCA or fuel handling accident and will not affect the filter system performance. Therefore, this change will not reduce the margin of safety of the emergency exha'at system filter operation.

Based on the above discussions and the no significant hazards consideration determination presented in Attachment 2, the proposed changes do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously eduluated in the safety analysis report; or reduce the margin of safety as defined in the basis for any technical specification. Therefore, the proposed changes do not adversely affect or endanger the health or safety of the general public or involve an unreviewed safety question.

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l ATI'ACHMENT 2 SIGNIFICANT HAZARDS EVALUATION l i

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ULNRC-03402 Attachment 2

, Page 1 of 4 Sionificant Hazards Evaluation This license amendment request proposes to revise surveillance requirements 4.7.7.b.2, 4.7.7.c, and 4.9.13.b.2 and 4.9.13.c to reflect a proposed change to the acceptance criteria for the testing of carbon samples from the auxiliary / fuel building emergency exhaust system charcoal adsorbers. This proposed change would adopt ASTM D-3803-1989 as the laboratory testing standard for charcoal 1 samples from the charcoal adsorbers (FGG02 A,B) in the auxiliary / fuel building emergency exhaust system.

Laboratory testing of the carbon samples taken from the  ;

charcoal adsorbers will be performed at 30 degrees Cent!, grade ( C) and 70% relative humidity for a methyl iodide penetration of 2%, instead of a 1% limit at 80 C and 70% relative humidity.

Evaluation The fuel building heating ver'c ilation and air conditioning (HVAC) system and the auxiliary building HVAC system are discussed in Final Safety Analysis Report (FSAR) Sections 9.4.2 and 9.4.3. These sectiens describe the interrelationship of the emergency exhaust system for these two buildings.

The emergency exhaust system collects and processes the fuel building atmosphere in the event of a fuel handling accident. During operation of the emergency exhaust system, the nonessential fuel building HVAC air paths are isolated and the building exhausted to assure that fission products '

and particulate matter are collected and processed. The fuel building intake air system is provided with two motor-operated dampers in a series arrangement. Indication of high radiation levels in the fuel building will initiate automatic transfer to the emergency exhaust system. In this lineup, the emergency exhaust system will maintain the fuel building at a negative pressure of 0.25 in. w.g. relative to the outside atmosphere.

The emergency exhaust system serves the auxiliary building I only following a loss of coolant accident (LOCA) to assure  !

that all emergency core cooling system (ECCS) leakage to the l auxiliary building atmosphere and the containment air purged  :

via the hydrogen purge system are processed. All ductwork l which is not required for operation of the emergency exhaust l system and penetrates the auxiliary building boundary is  !

automatically isolated. these nonessential systems are j provided with two motor-operated dampers in a series j arrangement at the boundary penetrations. These will close automatically following receipt of an SIS. In this lineup

ULNRC-03402

, Attachment 2

. Page 2 of 4 the emergency exhaust system will maintain a negative pressure of 1/4 in, w.g. to assure that all leakage is into the auxiliary building.

Charcoal samples are routinely tested to verify filter efficiency: every eighteen months; upon achieving total run time of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />; and following a significant event or activity, such as painting, welding, or fire, which could potentially create fumes in an amount that could affect charcoal filter efficiency. Technical Specification Surveillance Requirements 4.7.7 and 4.9.13 specify that charcoal is to be tested per the guidance of Regulatory Guide 1.52, Rev. 2, March 1978, position C.6.a.3. The Regulatory Guide, in turn, specifies the testing is to be performed in accordance with ANSI N509-1976. ANSI N509-1976 specifies that testing is to be performed in accordance with Military Specification RDT M-16-1T, with no year specified.

An issue has been identified with regard to the testing conditions specified by RDT M-16-1T and ANSI N509-1976. In order to remove the confusion in the current Technical Specifications concerning the correct testing protocol required, the referenced testing protocol for these charcoal camples is being revised to ASTM D-3803-1989, which specifies the testing to be performed at 30*C and 70%

relative humidity with the exception that methyl iodide penetration shall not exceed 2%, instead of a 1% limit.

The 30*C at 70% relative humidity ASTM D-3803-1989 test to i be performed on charcoal samples from FGG02A,B is representative of the postulated conditions for the i auxiliary building or fuel building following a design basis i accident. The current specification 3/4.7.7 and 3/4.9.13 penetration limit of 1% for testing at 80*C and 70% relative humidity per test standard RDT M-16-1T is less conservative than a 2% penetration limit for testing at 30*C and 70%

relative humidity, due to the more stringent tolerances placed upon temperature and humidity in ASTM D-3803-1989, as well as the test being performed at the lower temperature of 30*C. Thus, testing the charcoal using the new protocol will provide greater assurance that the charcoal filters will perform at an efficiency of at least 90%.

This change in test protocol is consistent with that approved in Callaway License Amendments 96 and 106.

Amendment 96 eliminated the containment spray additive system and replaced it with a passive Recirculation Fluid pH Control (RFPC) system. Amendment 96 as supplemented by Amendment 106 revised the control room dose charcoal filter assumption from 90% to 95% efficiency. The updating of the test protocol to ASTM D-3803-1989 at 30 C, 70% relative humidity and a methyl iodide penetration not to exceed 2%

supported this revised assumption. This amendment request does not involve a change in assumption of the efficiency

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ULNRC- 03 4 0 2

' Attachment 2 >

, Page 3 of 4 for the emergency exhaust system units FGG02A,B. The current analysis for the fuel handling accident and the LOCA assume a 90% efficiency.

Evaluation The proposed changes do not involve a significant hazards consideration because operation of Callaway Plant in ,

accordance with these changes would not. '

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

I The requested change to the charcoal sample surveillance acceptance criteria for the fuel building and auxiliary building emergency exhaust system will not affect the method of operation of the system. The testing of the charcoal filter samples will continue to be performed in accordance with NRC-accepted methods and acceptance criteria, and the new test protocol will still ensure filter efficiency is maintained equal to or greater than 90%. There are no changes to the emergency exhaust system and it will continue to function in a manner consistent with the safety analysis assumptions and the plant design basis. There will be no degradation in the perfernance of or an increase in the nuniber of challenges to equipment assumed to function during an accident. Therefore, the proposed changes will not increase the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any previously evaluated.

The changes to the surveillance requirements are being made to adopt current NRC-accepted methods of testing charcoal samples. These changes will not affect the method of operation of the applicable systems and the laboratory testing will continue to demonstrate the required adsorber performance after a design-basis LOCA or fuel handling accident. No new or different kind of accident from any previously evaluated will be created.

3. Involve a significanc reduction in a margin of safety.

The new charcoal adsorber sample laboratory testing protocol is more stringent than the current testing practice and meets current NRC-approved test methods.

The new testing criteria will continue to demonstrate the required adsorber performance after a design-basis LOCA or fuel handling accident and will not affect the filter system performance. Therefore, this change will

UUTRC-0 34 0 2

, Attachment 2 l

Page 4 of 4 not reduce the margin of safety of the emergency exhaust system filter operation.

Conclusion Based upon the preceding information, it has been determined that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety. Therefore it is concluded that the proposed changes meet the requirements of 10CFR50.92 (c) and do not involve a significant hazards consideration.

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ATTACHMENT 3

! ENVIRONMENTAL CONSIDERATION !

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ULNRC- 0 340 2 Attachment 3 Page 1 of 1 Environmental Consideration )

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'Dhis license amendment request proposes to revise surveillance j requirements 4.7.7.b.2, 4.7.7.c, and 4.9.13.b.2 and 4.9.13.c to  !

reflect a proposed change to the acceptance criteria for the  !

testing of carbon samples from the auxiliary / fuel building  !

emergency exhaust system charcoal adsorbers. This proposed i change would adopt ASTM D-3803-1989 as the laboratory testing  :

standard for charcoal samples from the charcoal adsorbers (FGG02 l A,B) in the auxiliary / fuel building emergency exhaust system.

l Laboratory testing of the carbon samples taken from the charcoal j adsorbers will be performed at 30 degrees Centigrade ( C) and 70% i relative humidity for a methyl iodide penetration of 2%, instead  !

of a 1% limit at 80'C and 70% relative humidity.

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r The proposed amendment involves changes with respect to the use  ;

of facility components located within the restricted area, as l defined in 10 CFR 20. Union Electric has determined that the proposed amendment does not involve:

(1) A significant hazard consideration, as discussed in  !

Attachment 2 of this. amendment application. l (2) A significant change in the types or significant increase in j the amounts of any effluents that may be related offsite; f

-(3) A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility l criteria for categorical exclusion set forth in 10 CFR 51.22 (c)

( 9 ) '. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in .

connection with the issuance of this amendment.

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