ML19289D820

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Requests Addl Info for Review of 780116 Proposed Change to Getr Tech Specs Re Surveillance During Cold Shutdown
ML19289D820
Person / Time
Site: Vallecitos File:GEH Hitachi icon.png
Issue date: 02/14/1979
From: Reid R
Office of Nuclear Reactor Regulation
To: Darmitzel B
GENERAL ELECTRIC CO.
References
NUDOCS 7903140557
Download: ML19289D820 (4)


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February 14, 1979 g,..... f Docket No. 50-70 Mr. R. W. Darmitzel, Manager Irradiation Processing Product Section General Electric Company Vallecitos Nuclear Center P. O. Box 460 Pleasanton, California 94566

Dear Mr. Darmitzel:

We have reviewed your November 1,1978 submittal supporting your January 16, 1978 proposed change to the GETR Technical Specifications and have determined that the additional information identified in the enclosure is necessary to complete our review.

Pl. ease provide your response within 30 days from receipt of this letter.

Sincerely,

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frobert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page 7903140557

^

h General Electric Company cc w/ enclosure (s):

California Department of Health ATTN: Chief. Environmental Radiation Dr. Harry Foreman, Member Control Unit Atomic Safety and Licensing Board Radiologic Health Section Box 395, Mayo 714 P Street, Room 498 University of Minnesota Sacramento, California 95184 Minneapolis, Minnesota 55455 Honorable Ronald V. Dellums Ms. Barbara Shockley ATTN: Ms. Nancy Snow 1890 Bockman Road General Delivery, Civic Center San Lorenzo, California 94580 Station Oakland, California 94604 Advisory Committee on Reactor Safeguards Friends of the Earth U. S. Nuclear Regulatory Commission ATTN:

W. Andrew Baldwin, Esquire Washington, D. C.

20555 Legal Director 124 Spear Street San Francisco, California 94105 Jed Somit, Esquire 100 Bush Street Suite 304 San Francisco, California 94104 Edward Luton, Esquire, Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Mr. Gustave A. Linenberger, Member Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 George Edgar, Esquire Morgan, Lewis & Bockius 1800 M Street, NW Washington, D. C.

20036

ENCLOSURE GETR ADDITIONAL INFORMATION REQUEST 1.

Your proposed change defines cold shutdown as a mode in which certain surveillance requirements need not be performed. Part of your definition of cold shutdown is that there are no fuel elements or experiments in the reactor vessel or pool that could cause a release of radioactive material if loss of coolant from the reactor vessel or pool should occur.

In addition you state that a fuel surface clad temperature of 8000F (or other acceptable surface temperature) is the criterion which must be met prior to declaring cold shutdown.

Please provide the following information:

a.

Describe your method of analyzing fuel temperatures for the determination of surface clad temperature.

b.

What criteria will be used for experiments and what is the method for that determination?

c.

Justify that complete loss of coolant results in more limiting heat transfer characteristics (higher fuel and experiment temperatures) than a partial loss of coolant.

d.

When would a fuel surface temperature criterion other than 8000F be used? Provide your justification.

If temperatures greater than 8000F are to be used as criteria for cold shutdown it will be necessary to modify your existing Section 7.1 or your proposed Section ll.l.j for consistency.

e.

If a coolant, such as air, is necessary to limit fuel temperatures, cemonstrate that adequate coolant would be available under all credible conditions.

2.

Proposed Section ll.la and b.

In order to demonstrate that containment integrity is not necessary, provide a discussion of the physical and administrative controls that will be used to ensure that activities inside the containment building could not lead to a release of radioactive material to the environs.

Include your justification for unrestricted movement of fuel and experiments without Containment integrity.

. 3.

Proposed Specifications ll.lc and d.

Show that there will be no equipment in operation that could cause overpressurization or evacuation of the containment building.

4.

Proposed Specifications ll.la, b, c and d.

Your safety analysis (Section III) states:

"While the reactor is in the cold shutdown condition there are no postulated accidents that would lead to a release of radioactiv.e material while maintaining reactor containment integrity.

Therefore, there is no need to periodically perform the tests referred to in proposed Technical Specifi-cation ll.la, b, c, and d."

This implies that containment integrity is needed during cold shutdown. However, elimination of these surveillance tests decreases the likelihood that containment integrity will be maintained.

Pl ease explain.

5.

Proposed Specifications 11.1g, h, and i.

Show that the control rods and poison injection systems do not contribute to maintaining a cold shutdown condition or that the cold shutdown condition will be maintained by other means under all credible conditions including operator errors.

State the maximum allowable reactivity of the core in the cold shutdown.

6.

Proposed Speci fication ll.lk.

Show what effects the loss of off-site power concurrent with the inoperabil'ty of the emergency generator would have on the monitoring of radioactive effluents during this extended shutdown period.

7.

Proposed Specifications 11.1.1, and m.

Define " experiment exhaust system be secured and isolated."

You state that there is normally no significant radioactive material in the tanks.

Show that the experiment exhaust system hold up tanks do not contain radioactive material during cold shutdown or that this material could not be released and will be adequately monitored for leakage.