ML17291B323

Forwards Application for Amend to License DPR-34,changing TS to Impose More Restrictive Leak Test Acceptance Criteria for Reactor Bldg Ventilation Sys HEPA Filters to Permit Use of Graphite Handling Alternatives to Minimize Exposures

ML17291B323
Person / Time
Site:	Fort Saint Vrain
Issue date:	05/18/1993
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	Joseph Austin NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML17291B324	List: ML17291B323 ML17291B325 ML17291B326
References
P-93046, NUDOCS 9306010002
Download: ML17291B323 (8)

Text

ACCEI ERAT D DOCUMENT DIST 8VTION SYSTEM REGULA INFORMATION DISTRIBUTIO YSTEM (RIDS)

ACt.'ESSION NBR:9306010002 DOC.DATE: 93/05/18 NOTARIZED: YES DOCKET FQCID. 50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION CRAWFORD,A.C. Public Service Co. of Colorado RECIP.NAME RECIPIENT AFFILIATION AUSTINPJ.H. Decommissioning & Regulatory Issues Branch (Post 901230)

SUBJECT:

Forwards application for amend to License DPR-34,changing TS to impose more restrictive 'leak test acceptance criteria for reactor bldg ventilation sys HEPA filters to permit use of graphite handling alternatives to minimize exposures.

DISTRIBUTION CODE: NL10D TITLE: Part 40 & 70, COPIES RECEIVED:LTR NMSS/LLDR Correspondence:

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PLEASE HELP US TO REDUCE WASTETH CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

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Public Service Public Service Company of Colorado PO BOX840 DENVER CO 80201-0840 May 18, 1993 Fort St. Vrain A. Clegg Crawford Vice President Unit No. 1 Electric Production P-93046 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 ATTN: Mr. John H. Austin, Chief Decommissioning and Regulatory Issues Branch Docket No. 50-267

SUBJECT:

Proposed Amendment to Decommissioning Technical SpeciTications

Dear Mr. Austin:

This letter submits proposed changes to the Fort St, Vrain (FSV) Decommissioning Technical Specifications (DTS), to impose more restrictive leak test acceptance criteria for the Reactor Building ventilation system HEPA filters, and to extend the applicability of requirements for Reactor Building confinement integrity and ventilation system operability. Public Service Company of Colorado (PSC) is proposing these changes to permit use of graphite handling alternatives that would minimize occupational radiation exposures.

PSC and its decommissioning contractor are evaluating various packaging and multiple block handling schemes to determine the most efficient methods for disposing of graphite components that are removed from the FSV prestressed concrete reactor vessel (PCRV).

Occupational radiation exposures can be minimized by packaging more than one graphite block in disposal liners, thus minimizing handling activities by workers. To support alternate packaging schemes, the heavy load drop analysis must take credit for 99 percent Reactor Building ventilation system HEPA filter efficiency, to ensure offsite dose consequences remain a small fraction of the EPA Protective Action Guidelines.

However, the current DTS requirements for testing the HEPA filters are based on only 95 percent efficiency. PSC is proposing to revise SR 3.2.3 to reduce the acceptable HEPA leakage from less than 1 percent to less than 0.05 percent, consistent with use of a 99 percent HEPA efficiency in the accident analyses.

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P-93046 May 18, 1993 Page 2 The evaluation of alternate graphite packaging schemes has also been extended to the graphite core support blocks and core support posts,'hich were previously excluded from the DTS definition of Activated Graphite Blocks, and which therefore could be handled without Reactor Building confinement integrity or ventilation system operability.

To account for various packaging possibilities and to account for the possibility that the core support blocks could be more activated than originally calculated in the Activation Analysis, PSC is proposing to expand the definition of Activated Graphite Blocks to include all activated graphite components that were inside the PCRV when there was irradiated fuel in the core. This will allow credit to be taken for Reactor Building confinement and ventilation filtration in the heavy load drop analyses for these graphite components, to demonstrate that the offsite dose consequences remain a small fraction of the EPA Protective Action Guidelines.

The proposed DTS changes described above are included in the following attachments:

Attachment 1 - Summary of Proposed Changes Attachment 2 - Proposed Changes Attachment 3 - No Significant Hazards Consideration Evaluation PSC has determined that the proposed changes included in this submittal involve No Significant Hazards Consideration, as described in 10 CFR 50.92. Further, PSC considers that approval of this proposed DTS amendment is consistent with PSC's efforts to keep worker radiation exposures As Low As is Reasonably Achievable (ALARA).

PSC requests NRC approval of the attached proposed Decommissioning Technical Specification amendment by August 15, 1993, to support scheduled graphite component disposal activities. If you have any questions concerning this submittal, please contact Mr. M. H. Holmes at (303) 620-1701.

Very truly yours, n,e~

A. Cle c~

Craw ord Vice President Electric Production ACC/SWC Attachments

P-93046 May 18, 1993 Page 3 cc: w/attachment Regional Administrator, Region IV Mr. Ramon E. Hall, Director Uranium Recovery Field Office Mr. Robert M. Quillin, Director Radiation Contxol Division Colorado Department of Health

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