ML20107K071

Submits Response to RAI Re TS Change Request 57 Which Addresses Proposed Expansion of Permissible Work Scope at Facility

ML20107K071
Person / Time
Site:	Saxton File:GPU Nuclear icon.png
Issue date:	04/24/1996
From:	Kuehn G SAXTON NUCLEAR EXPERIMENTAL CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20107K074	List: ML20107K071 ML20107K080
References
C301-96-2022, NUDOCS 9604250405
Download: ML20107K071 (5)

Text

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SAXTON NUCLEAR EXPERIMENTAL CORPORATION GENERAL PUBLIC UTILITIES SYSTEM l

M Jersey Central Power & Light MAILING ADDRESS:

General Public Utilities Nuclear Corporation One Upper Pond Road l g g .

Metropolitan Edison Company Parsippany, NJ 07054 s .

'{ Pennsylvania Electric Company G

April 24,1996 C301-96-2022 l

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 l

Gentlemen,

Subject:

Saxton Nuclear Experimental Corporation Operating License No. DPR-4 Docket No. 50-146 Response to the Request for Additional Information Regarding Technical Specification Change Request No. 57 dated March 25,1996.

The purpose of this letter is to submit the response to the Request for Additional Information regarding Technical Specification Change Request No. 57, which addresses the proposed expansion of pennissible work scope at the SNEC facility.

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Sincerely,

///

- . A. Kuehn Jr.

Vice President SNEC WGH Attachment

1) Response to the Request for AdditionalInformation  !

2) Procedum 6575-ADM-4500.40, " Control of Hotwork"

3) Environmental Report for the Constniction of the Decommissioning Support Facilities

4) Revised Proposed Technical Specification page la

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cc: Administrator, NRC Region I NRC Project Manager NRR '

NRC Project Scientist, Region I fp 250053 /p i l

9604250405 960424 l PDR ADOCK 05000146 , ,

p PDR  ;

Attachm:nt 1 C301-96-2022 Page 1 of 3 Ouestion 1: In the analysis of proposed changes to the Technical Specifications (TSs), you state that the requested changes have no effect on flooding and radioactive hazard. Please provide your bases for this statement.

Ecsponse: The constniction of the SNEC facility decommissioning support systems and stnictures will have no impact on the hazard posed by flooding or mdioactive hazard for the following reasons:

< With regard to flooding, records kept by the U. S. Geologic Survey from 1889 to the present identify the maximum observed flood level at the facility site was

809.5 feet above mean sea level (MSL) recorded in March 1936. In 1969, the Anny Corps of Engineers performed a study that concluded a flood level of 812 feet above MSL has a recurrence period of 225 years. Both the Federal Emergency Management Agency and Army Corps of Engineers were contacted 4

in March of 1996 to verify the validity of the projections. Both agencies indicated that no additional studies have been perfonned which would update this data nor was there any data to contradict these projections. The flood of record and the 225 year flood recurrence projection are referenced in the 1972 1 Saxton Decommissioning Plan and Safety Analysis Report, s

The predominant grade elevation for the decommissioning support stnictures is approximately 812.5 feet above MSL. The finished slab elevation of the s Decommissioning Support Building (DSB) will be approximately 813.5 feet l above MSL. This places the main stnicture and that portion subject to the effects of flooding above the 225 year flood mcurrence elevation. Installation of support services for the Containment Vessel will use existing penetrations; all of which are above the referenced flood levels. Additionally, these installations will be made so as to ensure a seal can be made to prevent water intnision into the Containment Vessel. Then: fore, the new stnictures and activities will not affect the ability to cope with the largest recorded flood.

With regard to radioactive hazard, the DSB will be constructed adjacent to the Containment Vessel but will not be internally connected to the Containment i Vessel until the Decommissioning Plan is approved. Therefore, the construction activities pennitted by these changes will not affect the radioactive hazard at the site. In addition, decommissioning activities will not be pennitted within the DSB until approval of the Decommissioning Plan. SNEC will only use the completed structum

Attachm:nt 1

. C301-96-2022  !

Page 2 of 3 during performance of activities associated with the expanded work scope 1 addressed by this change. These activities will be limited to those of a nature 4 which have been routinely performed at the site since 1972. These activities )

include the packaging of low level radioactive waste, the prepamtion of containers for shipment and the temporary storage of radwaste packages awaiting shipment. All of these activities have been and will continue to be conducted in accordance with NRC regulations. To date, these activities have largely been performed outdoors or in temporary enclosures. The use of more

- substantial facilities will provide a greater level of protection against offsite release and reduce the overall hazard associated with the activities.

Ouestion 2

Your proposed changes to TS A.3 state in part: I Any action which results in alteration of the Containment Vessel, removal of major radioactive components or results in dismantling of components for shipment that contain greater than class C waste is prohibited.  ;

There is a possibility that the phmse "for shipment that contain greater than class C waste" may be interpreted to allow dismantling of components other than asbestos and defunct electrical services as long as they are not prepared for )

shipment. This would be against section 2.C.(2) of the SNEF license. Please consider removing the phrase "for shipment that contain greater than class C waste" from the proposed TS orjustify the inclusion of this phrase considering the discussion above.

RespoJ11c: The phrase "for shipment that contain greater than class C waste" has been removed from the proposed Technical Specification wording to eliminate the possible misinterpn:tation of the intent of the section. See the revised Technical Specification page, Attachment 4.

Question 3: Your proposed TS has an example list of decommissioning support systems you want to install in the CV. Will any additional systems be installed beyond those on the list? If so, please list all the systems that are planned for installation in the TS.

Resoonse: The list provided is the complete listing of decommissioning support systems that will be installed in the Containment Vessel once such work is permitted by the approval of the proposed revised Technical Specifications. To eliminate the ambiguity, the phrase "for example" has been removed from the proposed n: vised wording. See the revised Technical Specification page, Attachment 4.

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Attachment 2 Procedure 6575-ADM-4500.40, " Control of Hotwork" 9 Pages i

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Attachment 1 C301-96-2022 Page 3 of 3 Ouestion 4: Are the fire protection provisions and procedures discussed in your application the same as those used for characterization activities? Your application discusses the use of fire watches when appropriate. Please elaborate under what conditions fire watches would be used. Please discuss the equipment referred to in your application that the local fire departments will receive. Will the equipment be given to the fire departments before the activities requested in this 4

application stait?

Resoonse: The fire protection provisions and procedures discussed in the application are the same as those used for characterization. Fire watches will be used whenever welding, grinding or other hot work is being performed. These activities are controlled by procedure 6575-ADM-4500.40, " Control of Hotwork" which identifies when and how a fire watch is assigned to a task and the responsibilities of the assignee. The procedure is included as Attachment 2 for your information.

As a result of a verbal agreement between the Lead Fire Protection Engineer and local fire company officials, the fire protection equipment referred to in the application will be kept at the site and made available to the local fire personnel j responding to a fire at the facility; it will not be turned over to them. ,

1 Transportation of specialized equipment (portable lighting and an ambulance kit which contains materials to support transport of contaminated, injured personnel), which is inappropriate for applications other than the SNEC facility, was considered to be undesirable. The equipment will be available on site prior to the start of the activities requested by the Technical Specification Change

Request.

Ouestion 5: Please provide an environmental report that discusses the environmental impact of the constmetion of the decommissioning support facilities. The environmentalimpact of the use of the decommissioning support facilities for decommissioning activities need not be discussed now but should be covered in the environmental report for the decommissioning plan.

Response: An environmental report discussing the environmental impact of the constmetion of the decommissioning support facilities is provided as Attachment 3.

Ouestion 6: How will the area that comprises the exclusion area at any particular point in time be clearly indicated?

Resoonse: The Exclusion Area will be identified by signs posted along the perimeter.

,