ML20071E736

Application for Amend to Licenses NPF-2 & NPF-8 Clarifying & Updating Charcoal Filter Tech Specs

ML20071E736
Person / Time
Site:	Farley
Issue date:	03/04/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20071E739	List: ML20071E736 ML20071E754
References
NUDOCS 8303140312
Download: ML20071E736 (7)

Text

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Malling Address Alib:ma PowIr Comp:ny .

600 North 18th Street Post Offica Box 2641 Birmingttim, Alabama 35291 Telephone 205 7834081 F. L Clayton, Jr.

=l'g;27"' AlabamaPower the SouthtYn E4ectfC System March 4, 1983 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Charcoal Filter Technical Specifications 4

Gentlemen:

The current Farley Nuclear Plant Technical Specifications on charcoal filters have been determined to be difficult to interpret and contain references to testing standards that have been superseded by later editions. In an effort to clarify and update the technical specifications, Alabama Power Company proposes the changes as described in Attachment 1 and contained in Attachment 2.

The proposed changes can be generally categorized as follows:

1. Incorporate Specific Efficiency Requirements. The current technical specifications reference Regulatory Guide 1.52, Revision 2, rather that state specific filter efficiency requirements. Since Regulatory Guide 1.52, Revision 2, is difficult to interpret, the proposed technical specification change is to remove the regulatory guide reference and replace it with specific efficiency values based on FSAR values. This change will ensure that the appropriate requirements are preoerly incorporated into the Farley Nuclear Plant testing procedures.

2. Eliminate Penalty for Non-Existent Farley Design Features. The current technical specifications are based on a filter system designed with filter bypass capability. Since the Farley Nuclear Plant design does not include filter bypass capability, the proposed qg change eliminates reference to bypass and removes the leakage limit penalty associated with a filter design Dk that includes bypass. b B303140312 830304 sb N l PDR ADOCK 05000348 P

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March 4, 1983 U. S. Nuclear Regulatory Commission Page 2

3. Update References to ANSI Standards. The current technical specificatiors reference ANSI N509-1976,

" Nuclear Power Plant Air Cleaning Units and Components,"

ano h510-1975, " Testing of Nuclear Air-Cleaning Systems." The NRC has endorsed the use of ANSI N509-1980 and ANSI N510-1980 in the Standard Review Plan (NUREG-0800). Since the 1980 versions of these ANSI standards are NRC approved updates of the charcoal filter testing procedures, the proposed change is to reference the 1980 standards. This change will update charcoal filter testing methods to the latest guidance.

Based on the above and the detailed safety evaluation contained in Attachment 1, Alabama Power Company proposes to make changes to the Farley Nuclear Plant Technical Specifications 3/4.7.7, 3/4.7.8 and 3/4.9.14 as contained in Attachment 2. Alabama Power Company's Plant Operations Review Board has reviewed these proposed changes and has determined ; hat no unreviewed safety question is involved as shown in Attachment 1. The Nuclear Operations Review Board will review these proposed changes at a future meeting.

The class of this proposed change is designated as Class III for l Unit 1 and Class 1 for Unit 2 in accordance with 10 CFR 170.22 requirements. Enclosed is a check for $4,400 to cover the total amount of fees required.

In accordance with 10 CFR 50.30(c)(1)(i), three signed originals and forty (40) additional copies of this proposed change are enclosed.

Yours very truly, N

F. L. Clayton, Or.

FLCJr/GGY:lsh-D31 Attachments SWORN TO AND SUBSCRIBED BEFORE ME cc: Mr. R. A. Thomas THIS LlO DAY OF /bcb ,1983 Mr. G. F. Trowbridge Mr. J. P. O'Reilly cMtv kM Notary' Public Mr. E. A. Reeves Mr. W. H. Bradford My Commission Expires: 1-10-87

l 1

ATTACHMENT 1 j SAFETY EVALUATION FOR PROPOSED CHANGES TO FNP-1 AND 2 TECHNICAL SPECIFICATIONS SECTIONS 4.7.7, 4.7.8, AND 4.9.14  :

Background:

NRC Regulatory Guide 1.52, Revision 2, dated March 1978, provides recommended guidelines for testing requirements and acceptance criteria of safety-related filters. Testing of the Control Room Emergency Ventilation System and the Penetration Room Filtration System is performed in accordance with Technical Specifications 4.7.7 and 4.7.8 respectively. Testing of the Containment Purge Exhaust Filter is performed in accordance with Technical Specification 4.9.14. As written, these technical specifications do not fully reflect the appropriate testing requirements that should be implemented based on actual plant design. In addition, clarification of the requirements of Regulatory Guide 1.52, Revision 2, is necessary in order to assure proper implementation of the regulatory guide recommendations. Also, Regulatory Guide 1.52, Revision 2, references ANSI N509-1976 and ANSI N510-1975 for standards for testing nuclear air-cleaning systems, which have been superseded by ANSI N509-1980 and ANSI N510-1980, respectively, which have been endorsed by the NRC in the Standard Review Plan (NUREG-0800). The reference to ANSI N509 in Regulatory Guide 1.52 for testing used charcoal absorbers has been replaced with specific charcoal testing requirements (i.e., 80 C and 70% relative humidity) and reference to Section 13 of ANSI N510. The 1980 version of ANSI N510 has incorporated improvements in these testing standards and should be incorporated into the Farley Plant Technical Specifications with specific sections of the ANSI identified. Therefore, a change to FNP Unit 1 and 2 Technical Specifications 4.7.7, 4.7.8 and 4.9.14 is necessary to incorporate these improvements.

References:

(1) FNP Unit 1 and 2 Technical Specifications 4.7.7, 4.7.8 and 4.9.14 (2) Standard Technical Specifications for Westinghouse PWR's, NUREG-0452 (3) Regulatory Guide 1.52, Revision 2, March 1978 (4) ANSI N509-1980, Nuclear Power Plant Air Cleaning Units and Components (5) ANSI N510-1980, Testing of Nuclear Air-Cleaning Systems Bases:

The following provides the bases for the proposed technical specification changes by paragraphs.

Technical Specification 4.7.7 Paragraph c.1: The Standard Technical Specifications (NUREG-0452) allow up to one percent leakage through a filter system if bypass piping is installed around the filters. FNP does not have filter bypass provisions, and therefore, total system leakage is equal to the leakage through the HEPA and charcoal absorbers (i.e., filter penetration). When

Attachment 1 Safety Evaluation Page 2 the filters are tested per the above specifications for filter penetration, Regulatory Guide 1.52, Section C.5.c and C.S.d are applicable. This requires a filter penetration of less than 0.05 percent through the HEPA filters ;nd charcoal absorbers based on an additional bypass leakage of up to 0.95 percent. This criteria is too restrictive for FNP since no bypass path exists around the filters. Thus the testing acceptance criteria for filter penetration in the above specifications should be 99 percent or less than or equal to one percent.. filter penetration.

Reference to Regulatory Guide 1.52, Revision 2, has been replaced with the specific testing requirements applicable to the FNP filters. In addition, reference to ANSI l N510-1975 has also been replaced with ANSI N510-1980, Sections 5,10 and 12 for clarification purposes.

Paragraph c.2: Reference to Regulatory Guide 1.52, Revision 2, has been replaced with specific testing requirements and acceptance criteria from the regulatory guide which is applicable to the FNP filters. Note 2 is proposed to clarify the acceptable efficiencies for the charcoal filters. As stated in FSAR Section 9.4.1.6, the following efficiencies for the charcoal filters were assumed for the Post-LOCA control room doses:

l a) Control Room Recirculation Filter Unit 95.0%

l b) Control Room Filter Unit 95.0%

c) Control Room Pressurization (Inlet)

Filter Unit 99.0%

In accordance with Regulatory Guide 1.52, Revision 2, in order to assume the above efficiencies, laboratory analyses must demonstrate the following efficiencies for the charcoal filters.

a) Control Room Recirculation Filter Unit 99.0%

(2 inch sample ',1ze) b) Control Room Filter Unit 99.0%

(2 inch sample size) c) Control Room Pressurization (Inlet) 99.825%

Filter Unit (4 inch or greater sample size)

Paragraph c.3: Reference to ANSI N510-1975 has been replaced with ANSI N510-1980, Section 8 for clarification purposes.

Paragraph d: Same justification as provided in Bases for changes to Paragraph 4.7.7.C.2.

Attachment 1 Safety Evaluation Page 3 *

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Paragraph e.4: Reference to ANSI N510-1975 has been replaced with ANSI N510-1980 Section 14 for clarification purposes.

Paragraph f: The Standard Technical Specifications (NUREG-0452) allow up to one percent leakage through a filter system if bypass piping is installed around the filters. FNP does not have filter bypass provisions, and therefore, total system leakage is equal to the leakage through the HEPA and charcoa! absorbers (i.e., filter penetration). When the filters are tested per the above specifications for filter penetration, Regulatory Guide 1.52, Section C.S.c and C.5.d are applicable. This requires a filter penetration of less than 0.05 percent through the HEPA filters and charcoal absorbers based on an additional bypass leakage of up to 0.95 percent. This criteria is too restrictive for FNP since no bypass path exists around the filters. Thus the testing acceptance criteria for filter penetration in the above specifications should be 99 percent or less than or equal to one percent filter penetration.

Reference to ANSI N510-1975 has been replaced with ANSI N510-1980, Section 10 for clarification purposes.

Paragraph g: The Standard Technical Specifications (NUREG-0452) allow up to one percent leakage through a filter system if bypass piping is installed around the filters. FNP does not _ have filter bypass provisions, and therefore, total system leakage is equal to the leakage through the HEPA and charcoal absorbers (i.e. , filter penetration). When the filters are tested per the above specifications for filter penetration, Regulatory Guide 1.52, Section C.S.c and C.S.d are applicable. This requires a filter penetration of less than 0.05 percent through the HEPA filters and charcoal absorbers based on an additional bypass leakage of up to 0.95 percent. This criteria is too restrictive for FNP since no bypass path exists around the filters. Thus the testing acceptance criteria for filter penetration in the above specifications should be 99 percent or less than or equal to one percent filter penetration.

Reference to ANSI N510-1975 has been replaced with ANSI N510-1980, Section 12 for clarification pruposes.

Technical Specification 4.7.8 Paragraph b.1: Same justification as provided in Bases for changes to Paragraph 4.7.7.c.1.

Attachment 1 Safety Evaluation Page 4 Paragraph b.2: Reference to Regulatory Guide 1.52, Revision 2, has been replaced with specific testing requirements and acceptance criteria from the regulatory guide which is applicable to the FNP filters. Accordingly, Section 13 of ANSI N510-1980 has been referenced for the testing require-ments. With respect to the acceptance criteria, an efficiency of 95% was assumed for the charcoal filter in the spent fuel pool fuel handling accident as stated in FSAR Section 15.4.5.2. In accordance with the regulatory guide, in order to assume this efficiency the laboratory analysis must demonstrate a charcoal efficiency of 99% (2 inch sample size).

Paragraph b.3: Reference to ANSI N510-1975 has been replaced with ANSI N510-1980, Section 8 for clarification.

Paragraph c: Same justification as provided in Bases for changes to Paragraph 4.7.8.b.2.

Parsgraph d.3: Reference to ANSI N510-1975 has been replaced with ANSI N510-1980, Section 14 for clarification.

Paragraph e: Same justification as provided in Bases for changes to Paragraph 4.7.7.f.

Paragraph f: Same justification as provided in Bases for changes to Paragraph 4.7.7.g.

Technical Specification 4.9.14 Paragraph a.1: This specification should be deleted because the Farley Nuclear Plant does not have any bypass piping installed l around the containment purge exhaust filters.

Paragraph a.2: Same justification as provided in Bases for changes to Paragraph 4.7.7.c.1.

I Paragraph a.3: Reference to Regulatory Guide 1.52, Revision 2, has been replaced with ANSI N510-1980, Section 13 for clarification l 1

purposes. The laboratory testing criteria of greater than I or equal to 75% efficiency has been stated for clarification purposes. A 75% efficiency acceptance criteria is required because the fuel handling accident inside containment analysis assumed a 70% efficiency as stated in FSAR Section 15.4.5.2.

Paragraph b: Same justification as provided in Bases for changes to Paragraph 4.9.14.a.3.

Paragraph d: Same justification as provided in Bases for changes to Paragraph 4.7.7.f.

q Attachment 1 Safety Evaluation Page 5 Paragraph e: Same justification as provided in Bases for changes to Paragraph 4.7.7.g.

Conclusion:

The proposed changes to_ Technical Specifications 4.7.7, 4.7.8 and 4.9.14 do not involve an unreviewed safety question as defined by 10CFR50.59.

GGY:jc-D31

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