ML19282D161
| ML19282D161 | |
| Person / Time | |
|---|---|
| Site: | University of Buffalo |
| Issue date: | 12/29/1978 |
| From: | Orlosky P NEW YORK, STATE UNIV. OF, BUFFALO, NY |
| To: | Diiani D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7905190094 | |
| Download: ML19282D161 (3) | |
Text
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' mi. m.:;ai % ic m.: % :20 December 29, 1978 Mr. D. C.'DiIani Nuclear Regulatory Commission Washington, D. C.
20555 Mail Stop 330
Dear Mr. DiIani:
SU3 JECT - Revision of Technical Specifications In response to our phone conversation of 12/21/78, I am enclosing a draft copy of what we propose to say about effluent monitor operability in our revised Tech-Specs.
All air exhausted from the reactor containment building must follow one of two possible paths. Air from the normally occupied work areas is exhausted out the roof of the building after passing through a filter bank. Air that is drawn through reactor f acilities such as the thermal column, pneumatic conveyor, hot ec11, and several fune hoods, is filtered and then exhausted through a 160 ft stack.
Actual measurements made in 1975 as part of a thesis project indicated that, under normal conditions, the flow rates in the ducts are 6500 cfm to the stack and 4200 cfm to the roof. Both ducts contain continuous air monitors. The stack duct also has a continuously monitored fixed filter and the roof duct has an unmonitored fixed filter.
If there were a significant release of airborn activity to the general containment spaces such as would occur due to fuel failure, all three effluent monitors plus the primary water monitor would sense it.
If a release were to occur in an experimental facility or fume hood, obviously only the stack duct monitors would sense it.
- However, if these facilities were not in use, there is very little probability that a release could occur.
We, therefore, conclude that our proposed limits on system inoperability (sic. -
One out of three inoperative, limited duration, manual filter check, restric tion of facility use, etc.) are reasonable and prudent.
I would like to point out a precedent for our request. The University of Michigan Tech-Specs. (section 3.6) allow their monitors to be out of service for up to 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> with no other restrictions on operation. We would not be disappointed if a similar limit were granted to us.
If you need additional information, please do not hesitate to contact me.
Very truly yours,
/
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fCA0 PMO: maw Philip M. Orlosky bi / /
Enc.
Operations Manager 7 90519 00ff'.
DRAFT EFFLUEST MONITORS AND PRIMARY C00LuT MONITOR Applicability These specifications apply to the permanently installed systems that monitor the airborn radioactivity leaving the facility and also monitor the activity of the primary coolant.
Obiective The purpose of this specification is to es tablish a minimum operability level for the effluent and primary coolant monitor system.
Soecification A.
The normal centingent of operable monitors when the reactor is operating shall be as follows :
Building air continuous monitor Stack air continuous monitor Stack particulate continuous monitor Primary water monitor.
B.
The alarm points for the two gaseous ef fluent monitors sha'.1 be clearly stated in a facility operating procedure. The alarm points for the primary water monitor and stack particulate monitor shall be posted on the radiation monitor panel in the control room.
C.
The outputs of the two air monitors shall be recorded on a strip chart.
D.
Both air monitor sys tems shall provide fixed filters for tvaluating particulate releases.
E.
One of the two gaseous ef fluent monitors may be out of service for up to four hours while the reactor is operating provided that no unusual experiments are being conducted and no radioac tive chemical processing is being done in the hoods. The primary water monitor may be inopera-tive for up to eight hours while the reactor is operating provided both air effluent monitors are operating. The stack particulate monitor may be out of service for extended periods provided that the fixed filter is evaluated daily. The recorder may be out of service for extended periods of time as long as thu effluent monitor values are logged ct nominal 15 minute intervals while the reactor is operating. The primary water monitor need not be operative in eb' natural
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clu.
Basis Specification 3.3.2.a provides assurance that adequate operable instrumentation exis ts to monitor airborn ef fluents and prima ry coolant activity when the reactor is operating.
Specification 3.3.2.b provides for the unambiguous establishment of alarm setting for the effluent and coolant monitors.
a Specification 3.3.2.c assures that a permanent record of effluent releases shall exist.
Specification 3.3.2.d assures that a means shall be available to evaluate particulate releases from the facility.
Specification 3.3.2.e provides for limited inoperability of the monitor equipment in order to permit maintenance and calibration of the systems while reactor is operating.