ML110490279
| ML110490279 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 03/24/2011 |
| From: | Alexander Adams Division of Policy and Rulemaking |
| To: | Miller S US Dept of Defense, Armed Forces Radiobiology Research Institute |
| ADAMS A, NRC/NRR/ADRA/DPR/PRTA 415-1127 | |
| References | |
| TAC ME4117 | |
| Download: ML110490279 (6) | |
Text
March 24, 2011 Mr. Stephen I. Miller, Reactor Facility Director Armed Forces Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603
SUBJECT:
ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE C REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT, SEPARATION OF BYPRODUCT MATERIAL (TAC NO. ME4117)
Dear Mr. Miller:
We are continuing our review of your amendment request for Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute Reactor Facility which you submitted on June 16, 2010, as supplemented on December 15, 2010. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 60 days of the date of this letter.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications.
Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.
Following receipt of the additional information, we will continue our evaluation of your amendment request. If you have any questions regarding this review, please contact me at (301) 415-1127.
Sincerely,
/RA/
Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-170
Enclosure:
As stated cc: See next page
March 24, 2011 Mr. Stephen I. Miller, Reactor Facility Director Armed Forces Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603
SUBJECT:
ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE C REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT, SEPARATION OF BYPRODUCT MATERIAL (TAC NO. ME4117)
Dear Mr. Miller:
We are continuing our review of your amendment request for Facility Operating License No. R-84 for the Armed Forces Radiobiology Research Institute Reactor Facility which you submitted on June 16, 2010, as supplemented on December 15, 2010. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information within 60 days of the date of this letter.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications.
Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.
Following receipt of the additional information, we will continue our evaluation of your amendment request. If you have any questions regarding this review, please contact me at (301) 415-1127.
Sincerely,
/RA/
Alexander Adams, Jr., Senior Project Manager Research and Test Reactors Licensing Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-170
Enclosure:
As stated cc: See next page DISTRIBUTION:
Public RidsNrrDpr RidsNrrDprPrta AAdams WMeyer RTR r/f GLappert RidsNrrDprPrtb ADAMS Accession No: ML110490279 *concurrence via e-mail NRR-088 OFFICE PRLB:PM*
PRLB:LA PRLB:BC PRLB:PM NAME AAdams GLappert JQuichocho AAdams DATE 2/28/2011 2/23/2011 3/23/11 3/24/11 Official Record Copy
OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR THE ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE LICENSE NO. R-84; DOCKET NO. 50-170 We are continuing our review of your amendment request for Facility Operating License No.
R-84 for the Armed Forces Radiobiology Research Institute (AFRRI) TRIGA Mark F Research Reactor which you submitted on June 16, 2010, as supplemented by letter on December 15, 2010. During our review of your amendment request, questions have arisen for which we require additional information and clarification. Please provide responses to the enclosed request for additional information (RAI) within 60 days of the date of this letter.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.30(b), you must execute your response in a signed original document under oath or affirmation. Your response must be submitted in accordance with 10 CFR 50.4, Written Communications.
Information included in your response that is considered security, sensitive, or proprietary, that you seek to have withheld from the public, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding.
- 1. These questions are related to your reply to RAI 4 dated December 15, 2010.
Please provide doses to the AFRRI staff and members of the public from the failure of a fueled experiment in the reactor room to support the isotope limits of technical specification (TS) 3.6. b. The NRC staff has reviewed your current Safety Analysis Report (SAR) and application for license renewal and did not find a discussion that supports the basis of TS 3.6. b. Please provide a discussion including an analysis of the bases for TS 3.6.b.
Please provide doses to the AFFRI staff and members of the public from the failure of a fueled experiment in the Radiation Chemistry Laboratory. Any assumptions that are more restrictive than the bases for TS 3.6. b. may need to be TS with corresponding bases and analyses identified in the SAR.
Your RAI response refers to limiting I-131 activity in the fueled experiment. However, TS 3.6. b. refers to the activity of I-131 through I-135. Please clarify which isotopes will be included in the TS and confirm that the analysis in the SAR supports the TS.
In your RAI response, it appears that the source term calculations using ORIGIN does not agree with your measurements. Please describe in detail the methodology and basis for your source term calculations including the apparent discrepancy between the ORIGIN calculations and measurements. The source term and basis for dose calculations should agree and support your technical specification limits for fueled experiments.
Please describe in detail the ventilation for the Radiation Chemistry Laboratory and Laboratory fume hoods. Figure 3-5 of your license renewal SAR and the January 2000 SAR
does not appear to match your description in the RAI response (e.g., the high efficiency gas filter appears not to be shown). Provide complete descriptions (e.g., locations, monitor type, alarm location, readout location, set points, bases for set points, etc.) of the radiation monitoring equipment associated with the Radiation Chemistry Laboratory to include:
a) What automatic or staff-initiated actions occur if a radiation monitor alarms?
b) Does the ventilation system shut down?
c) If the ventilation system shuts down, what impact does that have on the dose calculations? For example, do fission products then have a different release path?
- 2. These questions are related to your reply to RAI 5 dated December 15, 2010.
The RAI response states that irradiated solutions will be doubly contained at all times.
However, details of the experiment in Attachment 3 to the RAI response indicate that irradiated solutions will be transferred to other experimental apparatus to conduct measurements. Please describe how the irradiated solution is doubly contained during these transfers and measurements.
Your RAI reply describes the sample vial as a glass/plastic vial in double encapsulation.
What is the source of the vials? What quality assurance is applied to help ensure that encapsulation will be maintained during irradiation and subsequent handling? Your RAI reply describes the irradiation of sample vial materials using a Van de Graaff electron accelerator. Please describe any additional sample vial irradiation testing that occurred in the reactor. Did testing duplicate the conditions of actual sample irradiations to the extent possible and exceed actual doses by a sufficient margin to provide confidence of acceptable behavior under sample irradiation conditions? If this testing did not occur, please provide a justification and analyses to confirm acceptable behavior.
The double encapsulation, fission process in the vial and exposure to radiation from the reactor could produce significant heating of the sample vials during irradiation. Please discuss your evaluations of any testing or calculations performed to account for changes in material properties from heating of the sample vials in the irradiation environment.
Your RAI reply states that samples will not be handled until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after irradiation for all irradiated solutions. However, Attachment 3 to the RAI replies states that samples will not be handled 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after irradiation depending on the radioactivity of the samples.
Please address this apparent inconsistency. Is this an assumption used in the calculation of doses? If so, discuss if decay time before handling samples should be a TS requirement.
- 3. These questions are related to your reply to RAI 6 dated December 15, 2010.
Please submit a detailed safety analyses to support your proposed TSs. In most cases, the bases in the TS are a summary of the complete bases which appear in the SAR.
To be consistent with ANSI/ANS-15.1-2007, The Development of Technical Specifications for Research Reactors, please limit TS to shall, should and may statements. Your proposed TSs contain must and will statements.
Although implied, consider clearly stating that these TSs only need to be met when separation experiments are being conducted.
TS 3.7 b., c. and d. as written contain no requirements for the radiation monitoring equipment to be operating during separation experiments. Please discuss whether radiation monitoring equipment will be operating as part of the separation equipment. Additionally, TS 3.7 states, The radioiodine stack monitor samples and measures while the air particulate monitor just samples. Please describe the difference. The TS bases for TS 3.7
- b. and c. discuss evacuation of the facility. Describe any impact that the potential experimental work in the Radiation Chemistry Laboratory has on the facility emergency plan and whether you will provide an update to the emergency plan to the NRC to support this license amendment.
The bases for TS 3.7 d. state the ventilation dampers prevent the release of radioiodines to the atmosphere. Please discuss if the dampers are air tight. And if not, how leakage will affect TS 3.7.d. (Can be addressed as part of RAI 1 above.)
The bases for TS 3.7 e. state that the filter bank ensures that radioactive materials are not released to the atmosphere. Please discuss if the filters are 100 percent efficient. Please discuss the efficiency of the filter bank explaining the design of the filter bank including flow rates and air contact time with filter media. If the filters are not 100% efficient to radioactive materials, describe an analysis to support the bases of TS 3.7.e. (Can be addressed as part of RAI 1 above.)
TS 3.7 f. requires the Radiation Chemistry Laboratory to be under negative pressure while separations are being performed. TS 3.7 d. requires dampers to seal if the radioiodine stack monitor alarms. Where are these sealing dampers located? Please explain if operation of these dampers affects ventilation of the reactor room. Is a negative pressure maintained in the Radiation Chemistry Laboratory after the dampers seal? If yes, how does this occur? If not, what prevents airborne radioactive material that is accidentally released in the Radiation Chemistry Laboratory from leaving the Laboratory? If radioactive material can escape the Laboratory (e.g., into the hallway outside the Laboratory), what are the release pathways and what are potential staff and pubic doses? What is the impact on reactor operation if any of the Radiation Chemistry Laboratory radiation monitors alarm? (Can be addressed as part of RAI 1 above.)
Is the missing period at the end of TS 4.6 d. a typographical error? If so, please correct.
The basis for TS 4.6 d. states that the HEGA filter lifespan is three years. Please provide a reference (e.g., manufacturer information) to support this lifespan under the conditions you are using the filters. The bases to TS 4.6.d. refers to absorbing properties, activated charcoal normally adsorbs. Please address. Please provide details about the testing of gas adsorbing properties of the HEGA including acceptance criteria.
Armed Forces Radiobiology Research Docket No. 50-170 cc:
Director, Maryland Office of Planning 301 West Preston Street Baltimore, MD 21201 Montgomery County Executive 101 Monroe Street, 2nd Floor Rockville, MD 20850 Mr. Stephen I. Miller Reactor Facility Director Armed Force Radiobiology Research Institute 8901 Wisconsin Avenue Bethesda, MD 20889-5603 Environmental Program Manager III Radiological Health Program Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd.,Suite 750 Baltimore, MD 21230-1724 Rich McLean, Manager Nuclear Programs Maryland Department of Natural Resources Tawes B-3 Annapolis, MD 21401 Director Air & Radiation Management Adm.
Maryland Dept of the Environment 1800 Washington Blvd., Suite 710 Baltimore, MD 21230 Test, Research, and Training Reactor Newsletter University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611