ML20196J152

Forwards Revised Amend 17 Tech Spec Pages to 870602 Application for Amend,Per 880205 Request.Rev Addresses Areas of Concern Listed in

ML20196J152
Person / Time
Site:	05000083
Issue date:	03/07/1988
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196J154	List: ML20196J152 ML20196J174
References
NUDOCS 8803140170
Download: ML20196J152 (4)

Text

9 .

NUCLEAR ENGINEERIN D SCIENCES DEPARTMENT

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Nuclear Reactor Facility ,

University of Florida -

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• PhorM904 3921429 feies 64330 March 7, 1988 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

Subject:

University of Florida Training Reactor (UFTR)

Facility License: R-56, Docket No. 50-83 Technical Specifications (TS) Proposed Amendment No. 17

Dear Sir:

Per the request in your letter dated February 5, 1988, the proposed UFTR TS Amendment No. 17 pages submitted with our letter dated June 2, 1987 have been revised and are being resubmitted as attached to address the two areas of concern listed in the February 5 letter.

As requested for the first area to be addressed, the word "shall" is used in TS Section 3.3.1 Paragraph 1 (note the letter reference to TS 3.3.2 Para-graph 1 is incorrect) with exceptions to this condition listed within the same Paragraph of Section 3.3.1 Basically the listed conditions for exception in-clude (1) loss of building electrical power, (2) equipment failure, (3) cycl-ing console power to dump primary coolant or to conduct tests and surveil-lances, and (4) initiating the evacuation alam for tests and surveillances including emergency drills. In each case, these are conditions occurring at reactor shutdown e.nd are not limiting conditions for reactor operation which would require or cause a reactor trip or mnual shutdown of the reactor should any of them (such as loss of building electrical power or equipment failure) occur while the reactor is opera ting.

The inclusion of the first two conditions is intended to 1) recognize that these occurrences cannot result in conditions consistent with a report-able TS violation, and 2) to assure that conditions will not occur where the requirements of one set of specifications do not require violating another speci fica t '.on. There is no technical basis for requiring operation of the Reactor Vent System at stack count ra tes grea ter than 10 cps. When the core vent system is secured, any effluent that would be released is contained with-in the core / reactor vent system with the only potential release path being backflow (diffusion driven) into the cell which has not been a problem (see original letter dated June 2, 1987) in the past but which can be monitored to include evacuation (if determined necessary) since backflow would be into a  ;

restricted area. There is also an Air Particulate Detector normally con-tinuously operating and recording in the cell, ggO i( l 8803140170 DR 880307 ADOCK 05000083 k'8 W /^ w e teser* l C*

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9 Nuclear Regulatory Commission March 7, 1988 Page Two The third condition is intended to allow the rapid cycling of the console power switch to effect a dumping of water to the storage tank or to conduct various tests and surveillances (as of interlocks and indicating light func-tions) without having to wait for the stack count rate to fall below 10 cps, which can take a number of hours following an extended full power run. In these cases, the interruption of power to the console and hence securing of the Reactor Vent System is usually only momentary (a few minutes at most). In such a time f rame, there is no cause for concern about back leakage of stack effluents into the cell or control rcom. Such tests and surveillances are ty-pically used as retest requirements to restore component and/or system opera-bility, in addition to routine operability tests.

The fourth condition is included to allow evacuation drills and other tests and surveillances, which involve tripping the Reactor Vent System, to be conducted af ter a reactor run when stack effluent count rate remains above the 10 eps limit. This situation is similar to condition 3 except that in some '

cases, the Reactor Vent System may be secured for several hours. Here the ef-feet is similar to that of condition 1 or 2; again there is no reason to pre-clude required tests and surveillances where the stack count rate is greater than 10 cps.

As requested for the second area to be addressed, provisions have been incorporated into TS Sections 3.3.1 and 3.4.3 allowing the controlled release of radioactive ef fluents to the environment during abnormal operating condi-tiens. We consider it unlikely that situations would occur when such use of the stack vent would be desirable with the vent monitor inoperable. N ever the-less we agree that it is conceivable that venting might be warranted to reduce cell radionuclide concentrations. Therefore, Paragraph (6) has been added to Section 3.3.1 specifying that the Reactor Vent System must have a backup means for quantifying the radioactivity in the effluent in such emergency conditions where venting would be used to reduce cell radionuclide concentrations.

Since the existence of such a backup monitoring capability is specified in Section 3.3.1, Paragraph 6, a new Paragraph 2 is added to Section 3.4.3 to require that radioactivity in the effluent be quantified prior to initiating controlled venting whenever such venting is to be used to reduce cell radionu-clide concentrations in addressing unlikely though possible abnormal or emer-gency conditions involving high concentrations of airborne radioactivity with-in ALARA guidelines.

Implementation of this backup means to quantify the ef fluent will involve installing a sampling connection onto an existing line connected to the Reac-tor Vent System. This modification will be made and a sampling container and means of drawing a sample designated upon approval of this TS requirement; this modification has already been reviewed and approved by the Reactor Safety Review Subcommittee.

This submittal has been reviewed and approved by the UPTR Reactor Safety Review Subcommittee. The entire enclosure consists of one original and ten copies.

Nuclear Regulatory Commission March 7, 1988 Page Three We appreciate your consideration of this resubmission of the requested TS Amendment 17. Aga in , please let us know if additional information is needed.

Sincerely,

/

/ b S William G. Vernetson Director of Nuclear Facilities WGV/ps cc: NRC Region II Reactor Safety Review Subcommittee P.M. Whaley na mJ n%u.]e 1 lhYW

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UFTR TECH SPEC PAGES 10-12 AS AMENDED FOR TS AMENDMENT NO. 17

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