ML20212B483
| ML20212B483 | |
| Person / Time | |
|---|---|
| Site: | Waltz Mill |
| Issue date: | 09/15/1999 |
| From: | Rich Smith CBS, INC./CBS NEWS |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9909200122 | |
| Download: ML20212B483 (9) | |
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' CBS Corporation Richard K, smith Director . Environmental Remediation 1i stanwix street. Room 383 Pittsburgh. PA 15222 Phone: 412-642 3285 September 15,1999 rax: 4:2 642-3957 E-mail: smithrk@ westinghouse com Document Control Center U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Request For Technical Specification Amendment to USNRC License Number TR-2, Docket No. 50-22 to Clarify Facility Boundaries
References:
- 1. USNRC Letter to R. K. Smith dated March 25,1999
- 2. USNRC Letter to A.J. Nardi dated September 30,1998
- 3. Westinghouse Letter to USNRC dated July 31,1997
- 4. USNRC Letter to K.R. Schendel dated April 22,1970
Dear Sirs:
CBS Corporation (CBS), successor by corporate name change to Westinghouse Electric Corporation (Reference 1), hereby submits this application for an amendment to Technical Specification 3.1.3.2, " Limiting Conditions for Maintaining Confinement During Restricted Activities" of Westinghouse Test Reactor (WTR) Technical Specification issued as a part of amendment 8 (Reference 2) to the possession only license for the Westinghouse Test Reactor ,
License Number TR-2, Docket Number 50-022.
The specific Technical Specifications to be amended are:
Technical Specification 3.1.3.2(1) states "Either the inner or outer door (s) in each air lock and '
in the truck lock shall be kept closed except during personnel ingress or egress, or while equipment is being passed throug!, the doorways." ,
Technical Specification 3.1.3.2.(3) states "While containment openings are open for removal of materials or equipment from the containment building, the ventilation exhaust fans shall be operating (supply fans, if any, shall be turned off), and all other Restricted Activities shall be suspended.
Technical Specification 3.1.3.2 (4) states " The outer doors in the air lock and the truck lock !
outer doors shall be locked or blocked closed to prevent unauthorized entry except when authorized personnel are inside the containment building or outside with the door in view." g 9909200122 990915 'j PDR ADOCK 05000022 P PDR l
i
U. S. Nucle:r Regulatory Commission September 15,1999 Page 2 0'f 4 1
1These' requirements should be amended to more accurately reflect the containment boundaries and to allow decommissioning activities to proceed in a manner that is safe and ALARA.
Technical Specification 3.1.3.2(1) should be revised as follows: (See Exhibit A)
" Access doors between the Truck Lock and containment shall be kept closed except during personnel ingress or egress or while equipment is being passed through the doonvays. In addition, the outer personnel access doors to containment shall also be kept closed except during personnel ingress or egress or while equipment is being passed through the doonvays."
Bases for Change:
This change is consistent with the original intent of the Tech Specs to " maintain confinement during Restricted Activities" to " prevent the uncontrolled spread of contamination"(Reference the Tech Spec. 3.1.4 Bases).
In the case of the Truck Lock outer doors, the boundary should be more accurately defined as the interior access doors between the Truck Lock and containment. The Truck Lock facility was transferred to the SNM -770 license in April of 1970 (Reference 4); therefore, its outer doors are controlled under the SNM-770 license.
The normal personnel access into containment is through one of two airlocks in the G-Building basement. Fire doors with an interior crash bar have been installed at the entrance to each airlock as a safety feature to minimize the risk of personnel being trapped in containment during an emergency. The airlock doors do not allow quick and efficient egress during a postulated fire in containment; therefore, the original air lock doors have been removed and confinement is maintained by the newly installed fire doors. These fire doors or outer personnel access doors more accurately reflect the containment boundary.
Technical Specification 3.1.3.2.(3) should be revised as follows: (See Exhibit A)
"While containment openings are open for removal of materials or equipment from the containment building, either these openings will be isolated from the outside environment or all other Restricted Activities shall be suspended and Ventilation will be configured to maintain a negative pressure in containment (airflow into containment)."
Bases for Change:
This change is consistent with the original intent of the Tech Specs to " maintain confinement j during Restricted Activities" to " prevent the uncontrolled spread of contamination" (Reference the Tech Spec. 3.1.4 Bases). " Containment Openings" is construed to mean large openings, not personnel access doors, which allow direct access to the outside environment. This change would allow the use of temporary tenting, and openings to the G-Building Annex and the Truck Lock for transferring equipment and material in out of the containment without stopping e
U. S. Nuclear Regulatory Commission September 15,1999 Page 3 of4 restric'ted activities or securing the supply fans. Ventilation is normally required for all Restricted Activities by Tech Spec 3.1.3.2(2). Also, the Ventilation system was designed such that the supply fans are interlocked and synchronized with the exhaust fans to maintain a specific preset differential pressure between containment and the adjacent areas to maintain air flow into containment.
Technical Specification 3.1.3.2 (4) should be revised as follows: (See Exhibit A)
" Authorized access into containment will be through an H.P. access control point. To prevent unauthorized entry the accesses into and out of containment shall be locked or blocked closed except when this access control point is manned."
Bases for Change:
Work in the WTR containment is only authorized when the H.P. access control point is manned.
Access control maintains the records of personal in containment and is responsible for controlling and securing access to containment. Routine activities during the day may require workers to exit containment (rest, lunch, equipment change out, etc.). Locking or blocking the doors after workers temporarily exit during the working day is not ALARA and reduces worker efficiency.
Normal access to WTR containment is through a door in the G-Building basement. The G-Building basement is a " Radiation Area". Access control is established on the first floor of the G-Building outside of the radiation area. This does not allow personnel to physically view the
- personnel access door into containment. Only authorized workers are allowed access to the G-Building basement. Therefore, the access control point would provide positive control into and out of containment and meets the original intent of the technical Specifications.
In support of this Application for a Technical Specification amendment is an analysis of"No Significant Hazards Consideration." (See Exhibit B)
- If you have any questions conceming this submittal, please contact me at the above address or telephone number.
-Sincerel -
Richard K. Smith Director - Environmental Remediation CBS Corporation Attachment i L- )
U. S. Nuclear Regulatory Commission September 15,1999 Page 4 of 4 l
cc: ' Mr. Theodore S. Michaels, Senior Project Manger
, Non-Power Reactors and Decommissioning Project Directorate l Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington D.C. 20555-0001 James Yusko, Regional Manager Radiation Protection -
Commonwealth of Pennsylvania Department of Environmental Protection Field Operations 400 Waterfront Drive Pittsburgh, Pennsylvania 15222-4745 A. Joseph Nardi, Supervisory Engineer Westinghouse Electric Company Energy Systems, Regulatory Affairs Wayne Vogel, Radiation Safety Officer Westinghouse Electric Company Copies transmitted: 3 notarized and 5 conformed COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY )
Before me, the undersigned notary public, this day personally appeared Richard K. Smith, CBS Corporation. I1 Stanwix Street, Pittsburgh, PA 15222, to me known, who being duly sworn according to law, deposes and says: that the statements sworn to in this letter and attachment are correct and accurate to
' the best of his knowledge.
Signature of affiant Subscribed and sworn to before me thisff dayofSeptember,1999 W Loa . a l</
- otary Public Notarial Seal Mary Colleen Galvin, Notary Publie
- Pittsburgh, Alleg5eny County
!- My Commission Expires Nov. 22, t 999
, %vivania Associationof Notancs
EXHIBIT A REPLACEMENT PAGE FOR TECilNICAL AND ENVIRONMENTAL SPECIFICATIONS l FOR WESTINGHOUSE TEST REACTOR REVISION 1 WESTINGHOUSE ELECTRIC CORPORATIGN ;
WALTZ MILL SITE USNRC LICENSE NUMBER TR-2 DOCKET 50-22 t
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l l 3.0 '
- Limiting Conditions for Operation l ,
3.1 Confinement f
3.1.1 Applicability l This specification applies to the containment building.
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!. 3.1.2 Objective The objective of this specification is to define the activities which require confinement, the conditions necessary for maintaining confinement, and the actions to be taken if confinement is not maintained.
3.1.3 Specifications 3.1.3.1 Activities that Require _ Confinement Restricted Activities require confinement.
3.1.3.2 Limiting Conditions for Maintaining Confinement During restricted activities:
(1) Access doors between the Truck Lock and containment shall be kept closed except during personnel ingress or egress or while equipment is being passed through the doorways. In addition, the outer personnel access doors to containment shall also be kept closed except during personnel ingress or egress or while equipment is being passed through the doorways.
(2) The ventilation system shall be operating.
(3) While containment openings are open for removal of materials or equipment from the containment building, either these openings will be isolated from the outside environment or all other Restricted Activities shall be suspended and Ventilation will be configured to maintain a negative pressure in containment (airflow into containment).
l-L F -(4)~ A'uthorized access into containment will be through an H.P. access control point.
The accesses into and out of containment shall be locked or blocked closed to
, prevent unauthorized entry except when this access control point is manned.
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'(5)
When the ventilation system is not operating, the containment building shall be l maintained in a condition such that there are no airflow pathways open directly to areas external to the containment building except the air lock doorways when the l l doors are open.
3.1.3.3 Actions To Be Taken If Confinement Is Not Maintained If Confinement is not maintained in accordance with Specification 3.1.3.2:
(1) Within I hour, all Restricted Activities shall be suspended.
(2) Other activities that are NOT Restricted Activities may proceed without confinement, provided that ventilation exhaust fan (s) are operating.
3.1.4 Bases i Historical measurements of airborne radioactivity inside the containment building indicate that the containment building in its present condition does not require a confinement system.
Because of the activation and surface contamination levels, dismantlement activities associated with removal of reactor vessel internal contents, the reactor vessel, biological shield, and other i Restricted Activities could cause airborne concentrations in excess of DAC. Maintaining confinement during Restricted Activities prevents the uncontrolled spread ofcontamination during these activities.
The restrictions and limitations in Specification 3.1.3.2 are necessary to provide assurance that an effective confinement system will be established and maintained.
The one hour action time provided in Specification 3.1.3.3 allows an orderly suspension of activities in the event that the conditions specified for maintaining confinement are not met. If confinement is not maintained, other activities are permitted as long as ventilation exhaust fans are operating to minimize the potential for outward air flow; this provision permits activities that would require an opening in the containment building to remove items that have no potential for creating airborne contamination in excess of 10 CFR 20 limits. For example, the reactor vessel could be removed by suspending Restricted Activities that could create airborne contamination, cutting a suitable opening in the containment building, and maintaining the ventilation system operating, while the reactor vessel is removed from the containment building.
1 Exhibit B "No Significant Hazards Consideration For The Amendment to The Technical Specification 3.1.3.2 (2) and (4) for Westinghouse Test Reactor Facility License Number TR-2, Docket 50-022 Decommissioning Project."
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Exhibit B "No Significant Hazards Consideration For The Amendment to The Technical Specification 3.1.3.2 (2) and (4) for Westinghouse Test Reactor Facility License Number TR-2, Docket 50-022 Decommissioning Project."
REFERENCE 10 CFR 50.91(a)
The proposed change that is the subject of the requested amendment has been evaluated against the standards of 10 CFR 50.92(c) and it has been determined to not involve any significant hazards consideration in that licensed activities in accord with the proposed amendment:
- 1) IVould not involve a sigmficant increase in theprobability or consequences ofan accidentpreviously evaluated.
The proposed amendment clarifies the boundaries for the WTR.
The changes are consistent with the original intent of the Tech Specs to " maintain confinement during Restricted Activities" to " prevent the uncontrolled spread of contamination"(Reference the Tech Spec. 3.1.4 Bases).
Since confinement and access control is still being maintained the proposed amendment I does not involve a significant increase in the probability or consequences of an accident !
previously evaluated.
- 2) IVould not create the possibility ofa new or diferent kind ofaccidentfrom any accidentpreviously evaluated.
The proposed amendment does not modify the WTR facility configuration or licensed activities. Thus no new accident initiators are introduced.
Therefore, the proposed amendment does not create the possibility of a new or different !
accident from any accident previously evaluated. l i
- 3) IVould not involve a significant reduction in a margin ofsafety. l The proposed amendment does not modify the WTR facility configuration or licensed activities. Thus no reduction in the margin of safety is introduced.
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