ML20037D218

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Requests Waiver from Effluent Limitation Imposed by Tech Spec 3.8-1(a).Storage Pool Must Be Emptied for Repainting
ML20037D218
Person / Time
Site: MIT Nuclear Research Reactor
Issue date: 05/14/1981
From: Lisa Clark
MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To: John Miller
Office of Nuclear Reactor Regulation
References
NUDOCS 8105220296
Download: ML20037D218 (2)


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May 14, 1981 y

Mr. James R. Miller, Chief

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Subject:

Request for Waiver of Effluent Limitation,

\\"h 4'W License No. R-37, Docket 50-20 "s

Dear Mr. Miller:

Massachusetts Institute of Technology requests a waiver from the effluent limitation imposed by MIT Research Reactor Technical Specification 3.8-1(a), which states that "The release of radioactive effluents from the reactor site will comply with all provisions of Part 20, Title 10, Code of Federal Regulations, with the following exemptions:

(a) Alth exception of tritiun from the reactor secondary coolant system, the annual total quantity of radioactive material released to the sanitary sewer shall not exceed one curie."

Discharges to the sanitary sewer for ten and one-half months to date total 0.015 curies, including tritium.

It is our wish to discharge to the facility waste tanks and thence to the sanitary sewer all water in the spent fuel storage pool. This amounts to approximately 7315 gallons containing 1.136 Ci of tritium, 0.004 Ci of Co-60 and 0.001 C1 of Zn-65.

This would make the total discharge 1.156 C1, which slightly exceeds the Technical Specification 1 Ci limit.

The reason for emptying *,he storage pool is to permit repainting.

This must be done as soon as possible, preferably Friday or Saturday, May 15 or 16, l

in order to provide time for cleaning, painting, drying and refilling before the transfer of spent fuel to the pool in June.

Justifications for the waiver are the following:

1) Specification 3.8-1(a) was written to cceply with 10CFR20.303(d) as it i

l existed in 1975. Recently the 1 Ci limit in that paragraph has been changed to allow 5 Ci of tritium.

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2) The discharge of tritium to the sanitary sewer from the cooling towers as opposed to other sources is limited by a specification (3.8-1(b))

based on concentration, because it was recognized that the discharge l

might exceed 1 Ci per year from the towers.

It was expected that it would not exceed 1 Ci per year from other sources.

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Mr. James R. Miller, Chief May 14, 1981 Page 2

3) The MIT Reactor reporting year ends June 30th.

If part of t;.a storage pool could be discharged after June 30th (or if some of the tritium could be charged against the 1 Ci allowed for the year starting next July 1st), we would not anticipate any problems in complying with the Technical Specifications over the two year period.

Storage of 1000 gallons in one of the.two waste tanks.until July 1st can be done, but that does not quite get us below the 1 Ci limit. Using both waste tanks for that purpose would do it but would be unwise from our operational viewpoint.

i Your assistance in providing expeditious relief from what appears to be a simple technica_ity will be most appreciated. Our reason for not seeking relief earlier was a misinterpretation of the' discharge limitation arising from the recent change in 10CFR20.303(d).

Please call if additional information should be required.

Telephone: 617/253-4202 Telex:

921473; answer back MIT-CAM TWX:

710/320-0058; answer back MIT-CAM Telecopier (Xerox 200, automatic machine): 617/253-8000; verifying no. 617/253-3692 Sincerely, i

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Lincoln Clark, Jr.

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