ML021330134

Washington State University Triga Reactor Facility, Request for Amendment, Amends TSs by Eliminating Phrase at Least Every 2 Years and from Section 4.3.4 on Page 22

ML021330134
Person / Time
Site:	Washington State University
Issue date:	04/26/2002
From:	Hagihara D, Tripard G Washington State Univ
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML021330134 (3)

Text

Washington State University Nuclear Radiation Center P0 Box 641300 Pullman, WA 99164-1300 509-335-8641 FAX 509-335-4433 Friday, April 26, 2002 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ref Docket 50-27

Dear Sir:

In accordance with the provisions of the Code of Federal Regulations section 10 CFR 50.4 and 50.36, Washington State University TRIGA reactor facility (License No. R-76) requests to amend its Technical Specifications.

The first proposed change is to eliminate the phrase "at least every 2 years and" from section 4.3.4 on page 22 of our Technical Specifications. The document including the proposed changes has been reviewed and approved by the Facility Reactor Safeguards Committee.

Discussion:

HEPA filters are very expensive. It serves no purpose to change the HEPA filter in our ventilation system every two years, i.f the filter is fully functional and serving its intended purpose. Therefore we are respectfully requesting that we be permitted to remove the requirement from our Technical Specifications that we change the absolute filter every two years. To serve the safety and protective purpose of this filter, the criterion for changing this filter need be only a noticeable increase in the pressure drop across the filter of 1 inch of water since according to the manufacturer, HEPA filters have an indefinite shelf life when not in use.

In our case the filter is used only for at most a few minutes each month when the ventilation system is switched momentarily to the dilute mode to check for the correct operation of dampers, fans and indicators. Routine, normal ventilation system operation leaves the filter in an isolated, enclosed ductwork with no movement of air through it.

The enclosed letter from the HEPA filter supplier (Airpure Filter Sales & Service, May 8, 2001) is in support of our request even though it would lead to a loss of sales for the company.

We are requesting that the phrase "at least every 2 years and" be removed from section 4.3.4 on page 22 of our Technical Specifications. The current Technical Specification sentence to be changed now reads:

The absolute filter shall be changed atleast every2 years and whenever the pressure drop across the filter increases by 1 in. of water.

After the change it will read:

The absolute filter shall be changed whenever the pressure drop across the filter increases by I in.

of water.

The second proposed change is to remove the item (10)d) from section 3.15 on BNCT because it is redundant with (I0)c) of the same section.

The third and final change is to renumber the document and its index to accommodate the shifts in page numbers caused by printing with a new printer and by the removal of the redundant BNCT item. This would become Amendment #18 which is included as an attachment.

If you have any questions, please contact Dr. Gerald Tripard, Facility Director (509) 335-0172 Sincerely, Gerald E. Tripard Dwight Hagihara Director Chair, Reactor Safeguards Committee

Enclosures:

Jennifer Thomas letter, May .8, 2001, The proposed, compete Amendment #18 document cc: US NRC Headquarters Office

_J5/ 21 081: S 3 c:6 2 062438063 AIRPU PCFILTER SALES PAGE L12 Airpure Ftras &Ses 19034 13" Place South, Bldg. 3 o Seatac, WA 98148 Phone: 20B-243-0635 - Fax: 206-243-0639 May 8, 2001 Mr. Brian Bvnce WashiDgton State University PO Dox 641150 Pullman, WA 99164-1150

Dear JAx. Bunice:

L reply to owt May 3rd phone conversation, the life span on the HEPA fiters that have sat around in theijr original, sealed packaging is indefinite. As long as, there is no water damage or any other visible damage or deterioration that can be seen once the HEPA is removed from the packaging.

HERA filters do not start to capture particulate until their original packaging has been opened. Even if the sea] has been broken on the cases, 1*EPA filters have a long life and should still be in working order.

If you have further questions regarding this mamner, please call toll free at (877) 243-0635. If you wish to contact someone directly at the factory, you may call Hugh Cannon in technical sales at (800) 347-2220.

Sincer'ely,/* /

Jeunife oas Branch Manager Airpure Filter Sales & Service A wholly owned subsidiaryof FRanders - Precisionare