ML20065S099

Identifies Two Tech Spec Required Items Difficult or Impossible to Perform Due to Transitional Period Between Normal Operations & Decommissioning

ML20065S099
Person / Time
Site:	05000054
Issue date:	12/10/1990
From:	Strack R CINTICHEM, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9012200073
Download: ML20065S099 (4)

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LCINTICHEM, INC, se wholly owned subsidiary of

- Med-Physics, Inc. P.O. BOX B18. TUXEDO, NEW YORK 10987 [914) 351-2131  ;

[0 = $k' December 10, 1990  ;

F U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Mail Stop PA-37 Washington, D.C. 20555

Dear Gentlesen,

Cinlichem is in a transitional period between normal operations ,

which ceased in February, 1990 and decommissioning which is anticipated. l to begin-in February 1991. While in this transitional period ~,.with-the-

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reactor secured (ie. defuelled), it has become difficult or impossible .>

~to perform certain items' required by our technica'l specifications, in accordance w'ith a phone conversation with-Mr. Mike. Austin.

(Radiation Specialist, Effluents ~ Radiation Protection Section) on

. November-27, 1990, this letter serves _

to identify two such items. It is our understanding from- the above conversation that this form of

. identification is sufficient, considering our' current- operational 4 status, to address these matters..

ITEM N1: 'Cintichem's technical specifications, section' 4.5.3 (confinement) (2)- ' indicates that " The operability of the evacuation alarm and containment isolation system shall .be tested,= and negative pressure-verified,aemiannually." This test was scheduled- to.be performed on -7/1/90 via procedure RS-36 and requires that= water seal be present between the

'eactor 111 ding (Bldg.- . N 1) and the Hot Laboratory (Bldg.

1. 2). Shortly after- the February 9th reactor shutdown the-canal, which needs to be fulliof water to provide this sesi, w.is drained and. could not :be refilled- until repairs . were made~and.-Regulatory approval for refilling'obtained. -Once-

-repairs were made and approval'for- . refilling-obtained,-.the-water. level was restored and shortly thereafter,on 10/29/90, the surveillance test:vas performed. When it was' performed. .

thel test passed standards-without=any-problems. The' basis.or' this con (inement system (tech. specs. section 3.5.3)-is:to-

effect controlled release Lof. 9aseous. activity._ associated. .

with a reactor core- accident which- cannot_ occur under 1 current facility (ie core defuelled)-conditions.- Cinti;aem

, plans to perform this. surveillance test in the future on-a semiannual' basis, unless the water seas can no longer be maintained, until our decommissioning plan is . approved.

Toch specs. in the decommissioning plan do not require the

. performance of-this test.

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ITEM #2: A charcoal efficiency test, also in tech. specs. section 4.5.3, is described under (1) of this section as a surveillance being required on an annual basis. Cintichem did not perform this test on it's scheduled date of 11/17/90 and does not plan to perform this test unless the reactor is refuelled for the following reasons: (A) The charcoal filter is present to remove airborne radioactive lodine released from the reactor core in the event of hypothetical reactor accidents as described in our SAR. The reactor is presently defuelled and insufficient radioactive iodine remains (in all irradiated fuel elements currently at our facility) to warrant the use of such a filter; (B) The performance of this test requires that a radioactive iodine be inaected into the system to determine iodine removal efficiency.

Cintichem firstly, no longer produces radioactive lodines ,

and secondly, as we are preparing fer decommissior?ng, introduction of radioactive materials into facility systems as highly undesirable and counterproductive to our decommissicaing goals. na analysis is provided in the attachment to this letter which is intended to justify the statement made in (A) above. The charcoal filt er will remain in place untti removal is authorized urder our decommissioning plan, only it's efficiency test will be discontinued.

Should our direction towards decommissioning change and plans for refuelling the reactor developed, these tests will be performed and original tech, spec, conditions satisfied in advance.

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r.XX.fu h Robert A. Strack Nuclear Project Engineer l /Reactot Supervisor l

l cc: Ted Michaels Tom Dragoun Mike Austin I

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l ATTACHMENT TO 12/10/90 LETTER -

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A hypothetical accident is described in our technical l specifications which postulates that a reactor excurston occurs while j operating at 150% (7.5 MW) of licensed power. The consequences, due to

• l radioactive iodines, of this excursion to an Individual situated at our l site boundary for a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an a REM thyroid exposure.

Other assumptions made were that a 10% meltdown occurs, the mixture of radioactive iodines is consistent with calculational models for our core, and that the charcoal emergency filter is only 95% efficient (ie charcoal filter reduces the lodine level exiting the reactor building by i a factor of 20).

l Our reactor has been shutdown since February 9 1990 and we have 176 spent or partially spent arradiated fuel elements. The minimum l number of elements we ar* allowed to have in a core is 30 so we can assume that 176 elements can represent, at most, 5.87 reactor cores. If we assume (1) That all of *.hese cores were operated at 150% licensed power on February 9, 1990; ,2) That all of the radioactive iodine present in these cores is 1-131 (Tl/2= 8,04 days); (3) That a 100%

meltdown of all these cores occurs today; and (4) That no emergency charcoal filter exists in the emergency exhaust, the resulting thyroid exposure to that same individual would then be:

• " " * * ' ' * ' ' ) x (10 times greater BR/hr x (5.87 cores) x( e I meltdown) x (20 times greater release from the building)

= 5.53 x 10-'R/hr This result is a factor of more tha. a 100 million below that of the SAR postulated accident and inditates that a charcoal filter in our reactor building emergency exhaust system is no longer necessary, l

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