ML18109A039
| ML18109A039 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 04/17/2018 |
| From: | Meffert B Univ of Missouri - Columbia |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18109A039 (17) | |
Text
UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER April17, 2018 ATTN: Document Control Desk U.S . Nuclear Regulatory Commission Washington, DC 20555-0001
REFERENCE:
Docket No. 50-186 University of Missouri-Columbia Research Reactor Renewed Facility Operating License No. R-103
SUBJECT:
Written communication as specified by 10 CFR § 50.4(b)(l) requesting U.S .
Nuclear Regulatory Commission approval to revise the Technical Specifications appended to Renewed Facility Operating License No. R-103 pursuant to 10 CFR § 50.90 Enclosed is an application to amend Renewed Facility Operating License No. R-103 by revising University of Missouri Research Reactor (MURR) Technical Specification (TS) 3.7, "Radiation Monitoring Systems and Airborne Effluents," and TS 6.2, "Review and Audit," pursuant to 10 CFR § 50.90. The proposed, requested changes should be considered permanent changes to the MURR TSs. Additionally, the proposed, requested changes have been reviewed by the Reactor Safety Subcommittee (RSS), a subcommittee of the Reactor Advisory Committee (RAC), m accordance with MURR TS 6.2.a(4).
Enclosure 1 provides the basis for revising TS 3.7.b; whereas, Enclosure 2 provides the basis for revising TS 6.2.b. Enclosure 3 contains the proposed, revised TS pages with track changes.
Enclosure 4 contains the proposed, revised TS pages with changes accepted and revision bars.
MURR requests that the proposed license amendment be reviewed within 180 days from the date ENDORSEMENT:
Sincerely, Reviewed and Approved
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Matthew R. Sanford Interim Reactor Facility Director
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cc: Reactor Advisory Committee Reactor Safety Subcommittee Isotope Use Subcommittee Dr. Mark McIntosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Geoffrey Wertz, U.S. Nuclear Regulatory Commission Mr. William Schuster, U .S. Nuclear Regulatory Commission
Enclosures:
I. Basis for the Requested Change to Technical Specification 3.7
- 2. Basis for the Requested Change to Technical Specification 6.2
- 3. Proposed, revised Technical Specification pages - A-30, A-31 and A-68 (with track changes)
- 4. Proposed, revised Technical Specification pages - A-30, A-31 and A-68 (with accepted changes and revision bars)
Page 2 of 2
Enclosure 1 - Basis for the Requested Change to Technical Specification 3. 7 1.0 Introduction The University of Missouri Research Reactor (MURR) is requesting a change to Technical Specification (TS) 3.7, "Radiation Monitoring Systems and Airborne Effluents." This change would remove the air effluent Maximum Controlled Instantaneous Release Concentration limits, thus affording MURR a greater capacity to meet its mission and vision, which are aligned with that of the larger University of Missouri System, to improve the quality of life for all through nuclear science and technology. The following license amendment request (LAR) provides considerable justification that the air effluent instantaneous release concentration limit portion of TS 3.7.b is not needed to ensure the health and safety of the public.
2.0 Background The MURR TSs have contained a maximum controlled instantaneous release concentration limit since initial licensing in 1966. In 1974, the air effluent release TS was revised to increase the release multipliers to coincide with the facility power level upgrade from 5 to IO Megawatts. Since such time, the conservatism contained within this Specification has not adversely affected MURRs ability to fulfil its mission and vision; however, several recent and potential future projects or experiments targeted to fill a national and global need for the production of medical isotopes have been overly constrained by the conservative limitations of the maximum controlled instantaneous release concentration limit contained within TS 3.7.b.
The maximum controlled instantaneous release concentration limit is subdivided into the following two groups : (I) particulate and halogen nuclides with half-lives greater than 8 days, and (2) all other radioactive isotopes. Currently, the particulate and halogen nuclides with half-lives greater than 8 days are limited to the Air Effluent Concentrations (AEC) as listed in Appendix B, Table 2, Column I of IO CFR 20,
" Standards for Protection Against Radiation," for both the maximum instantaneous and one year average discharge rate at the ventilation exhaust stack. Limiting the discharge rate at the ventilation exhaust stack to the air effluent concentrations ignores reduction factors afforded by atmospheric dilution between the ventilation exhaust stack and the boundary of the unrestricted area or receptor site. Additionally, the potential reconcentration of the halogen I-131 - the main isotope of concern - is expected to be minimal and of little consequence to offsite dose due to several reasons. Atmospheric dilution between the end of the exhaust stack release point and receptor sites provides assurance as to minimal radioiodine concentrations at the receptor sites; inventories of radio iodines during normal operations are low and there is no legitimate forage/cow/milk pathway within 2 to 3 miles of MURR. Additionally, the neglect of atmospheric dilution is an area of conservatism currently contained within TS 3. 7 .b; however, this LAR is not requesting a change to the release limits or multipliers for either (I) particulates or halogens with half-lives greater than 8 days or (2) any other radioactive isotopes at this time.
Additionally, AEC values correspond to a 50 mrem per year total effective dose equivalent (TEDE) for particulate and halogen nuclides. The intent of the 50 mrem per year basis is to allow for an additional 50 mrem per year of liquid effluent releases such that the aggregate of liquid and air effluent releases will total to less than or equal to 100 mrem per year. This corresponds to the public exposure limit contained within 10 CFR 20 Subpart D. MURR historically has not discharged liquid effluent directly to the environment as part of routine operation; it normally discharges liquid effluents via the sanitary sewer system subject to the limitations contained within 10 CFR 20, Appendix B, Table 3.
Page I of 5
Enclosure I - Basis for the Requested Change to Technical Specification 3.7 Noble gas and short lived nuclides (nuclides with half-lives less than 8 days) are currently limited to the AEC values contained within IO CFR 20, Appendix B, Table 2 along with an instantaneous multiplier and a one year average multiplier to allow for a reduction in concentration due to dilution from the point of discharge to the boundary of the unrestricted area. Additionally, noble gas nuclide AEC values are derived based on a submersion dose corresponding to 100 mrem per year and do not reconcentrate after being discharged.
3.0 Justification for Removal of Release Limit Per the current MURR TSs, the objective of Specification 3.7, " Radiation Monitoring Systems and Airborne Effluents," is to assure that sufficient radiation monitoring information is available to the reactor operator during reactor operations. This assures that doses to the public resulting from the routine radioactivity released from the reactor facility to the unrestricted environment will not exceed the limits of 10 CFR 20.
It also assures that, in the event of an emergency, reactor operations staff can terminate any activity that is producing elevated effluents, thus maintaining public exposure below the limits of IO CFR § 20.1301.
Consequently, a comprehensive review of 10 CFR 20 and thirty other currently licensed Research and Test Reactor air effluent release TSs was performed to appropriately identify the regulatory limitations and constraints. During review of the thirty other Research and Test Reactor Licensee TSs, it was noted that only five licensees currently have a daily or instantaneous air effluent release limit. Of the three (3) highest-powered licensees, only MURR has TSs containing an instantaneous or daily release limit. The applicable limitations and constraints contained within 10 CFR 20 are further discussed and addressed below under each 10 CFR 20 Subpart heading.
3.1 Compliance with 10 CFR 20 Subpart D MURR will continue to comply with the limitations imposed within 10 CFR 20, Subpart D, after the elimination of the maximum controlled instantaneous release concentration limits contained in MURR TS 3.7.b. The limitation that corresponds to the maximum concentration over one year is derived directly from the AEC limitation contained within 10 CFR 20, Appendix B, which ensures that annual doses to the public fall within the 100 mrem per year limit. A 350 multiplier will continue to be applied toward the release of nuclides with half-lives less than 8 days in the proposed revision to TS 3.7.b.
3.2 Compliance with 10 CFR 20 Subpart B Elimination of the maximum controlled instantaneous release concentration limit on air emissions is independent of the air effluent constraint contained within 10 CFR § 20.1101 ( d). Subpart B requires the Licensee (MURR) to establish a constraint on air emissions to ensure that the individual member of the public likely to receive the highest dose will not be expected to receive a TEDE in excess of IO mrem per year from air emissions. Compliance with this constraint will continue to be established within MURR' s Radiation Protection Program, which conforms to the guidance contained within Regulatory Guide 8.37, "ALARA Levels for Effluents from Materials Facilities," and is demonstrated in Appendix B of MURR' s relicensing Safety Analysis Report.
Page 2 of 5
Enclosure 1 - Basis for the Requested Change to Technical Specification 3.7 Furthermore, MURR Management and the Isotope Use Subcommittee (fUS), a subcommittee of the Reactor Advisory Committee (RAC), are routinely engaged in monitoring the aggregate of effluents released from MURR. Historically, a MURR Staff Health Physicist has prepared a monthly effluent release summary report that is distributed through the MURR Senior Leadership Team for review and then reviewed by the fUS. This process ensures continual engagement by MURR management to properly oversee and manage effluents as needed and to maintain MURR effluents ALARA.
Historically, MURR has not been challenged by the constraint contained within 10 CFR 20 Subpart B.
Table 1 contains MURR's calculated dose to the maximally exposed individual member of the public for the previous five (5) years of routine operation at MURR.
Table 1 Calculated Dose to the Maximally Exposed Member of the Public Year TEDE (mrem) 2013 4.0 2014 3.8 2015 2.4 2016 1.7 2017 3.1 3.3 Compliance with 10 CFR 20 Subpart C Elimination of the maximum controlled instantaneous release concentration limit on air emissions does not affect the annual dose to the public which results from the limits as contained within 10 CFR 20, Appendix B.
4.0 Conclusion In effect, TS 3.7.b as currently written constrains effluent release limits such that momentary periods of elevated releases are not afforded the ability to be offset with periods of little to no effluent releases consistent with annual dose limitations as contained within 10 CFR 20. For example, it is most common for research projects to take place on only a few occasions for any given project over the course of a calendar year. Currently, with TS 3.7 written to include a maximum controlled instantaneous concentration release limit, a research project is limited to 1/365 111 of the air effluent concentration limits contained within 10 CFR 20 or an equivalent of 0.14 mrem regardless of the expected frequency of the experiment. Consequently, MURR feels that the maximum controlled instantaneous release concentration limit is overly conservative and in fact restrictive and does not increase public health and safety as the annual dose limit to members of the public must still be met. Furthermore, elimination of maximum controlled instantaneous release concentration limit will not constitute a hazard to the health and safety of the public as MURR will continue to control effluents and public doses per the requirements of 10 CFR 20 . Therefore, MURR requests approval for the below revised Specification 3.7.b.
Page 3 of 5
Enclosure 1 - Basis for the Requested Change to Technical Specification 3. 7 5.0 Proposed Revision to Technical Specification 3.7.b Specification 3.7.b currently states:
"b. The maximum discharge rate through the ventilation exhaust stack shall not exceed the following:
Max. Concentration Max. Controlled Type of Averaged Over Instantaneous Release Radioactivity One Year Concentration Particulates and halogens with AEC AEC half-lives greater than 8 days All other radioactive isotopes 350 AEC 3,500 AEC AEC = Air Effluent Concentration as listed in Appendix B, Table 2, Column 1 of 10 CFR 20, "Standards for Protection Against Radiation.""
Specification 3.7.b will be revised as follows:
"b. The maximum discharge rate through the ventilation exhaust stack shall not exceed the following:
Max. Concentration Type of Averaged Over Radioactivity One Year Particulates and halogens with AEC half-lives greater than 8 days All other radioactive isotopes 350 AEC AEC = Air Effluent Concentration as listed in Appendix B, Table 2, Column 1 of 10 CFR 20, "Standards for Protection Against Radiation.""
The second and third paragraphs of the basis for Specification 3.7.b currently state:
I.
"For Argon-41, the primary air effluent from MURR, dispersion calculations are based on standard reference material and experimental data obtained at the reactor showing that concentrations under average conditions wi ll be 0.008 of the AEC limits in the unrestricted area surrounding the reactor faci lity. Also, dilution factors under conservative conditions are in the range of 5 x 104 under both average and stable conditions at ground level from the facility building. For normal short burst releases at the facility which are five to ten seconds in duration and occur on an average of ten times per day five days per week the effect on the average concentration is less than 1% when averaged over a one-day period.
Page 4 of 5
Enclosure 1 - Basis for the Requested Change to Technical Specification 3.7 It is concluded that these concentrations as specified will not constitute a hazard to the health and safety of the public."
The second and third paragraphs (third paragraph is de leted) of the basis for Specification 3.7.b wi ll be revised as follows:
"For Argon-41, the primary air effluent from MURR, dispersion calculations are based on standard reference material and experimental data obtained at the reactor showing that concentrations under average conditions will be 0.008 of the AEC limits in the unrestricted area surrounding the reactor facility. Also, dilution factors under conservative conditions are in the range of 5 x 104 under both average and stable conditions at ground level from the fac il ity building."
Page 5 of 5
Enclosure 2 - Basis for the Requested Change to Technical Specification 6.2 1.0 Introduction The University of Missouri Research Reactor (MURR) is requesting a change to Technical Specification (TS) 6.2, "Review and Audit." This change would revise the requirement for the dissemination of meeting minutes of the Reactor Advisory Committee (RAC) and its subcommittees to the Office of the Chancellor, and to the RAC and its subcommittees from three (3) to four (4) months after the meetings, in addition to the requirement for the RAC to meet at least once each "calendar" quarter.
2.0 Background MURR received its renewed facility operating license on January 4, 2017. Significant changes to the TSs were made as a part of relicensing. Prior to relicensing, the second paragraph of MURR TS 6.1.d stated:
"The Reactor Advisory Committee and its subcommittees are to maintain minutes of meetings in which the items considered and the committees recommendations are recorded. Independent actions of the subcommittees are to be reviewed by the parent committee at the next regular meeting. A quorum of committee or subcommittees consisting of at least fifty percent of the appointed members must be present at any meeting to conduct the business of the committee, or subcommittee."
The second paragraph of current MURR TS 6.2. b states:
"The RAC and its subcommittees shall maintain minutes of meetings in which the items considered and the committees' recommendations are recorded . Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within three (3) months after the meetings. Independent actions of the subcommittees shall be reviewed by the parent committee at the next regular meeting. A quorum of the committee or the subcommittees consisting of at least fifty percent of the appointed members shall be present at any meeting to conduct the business of the committee or subcommittee. Additionally, reactor fac ility staff shall not constitute greater than fifty percent of the quorum for a meeting of the RAC. Reactor facility staff shall not constitute a
. majority of the RAC. The RAC shall meet at least quarterly."
During relicensing, the TS requirement for the dissemination of meeting minutes changed from:
"Independent actions of the subcommittees are to be reviewed by the parent committee at the next regular meeting."
To:
"Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within three (3) months after the meetings."
Page I of 4
Enclosure 2 - Basis for the Requested Change to Technical Specification 6.2 Section 6.2.2 of American National Standard ANSI/ANS-15 .1-2007, "The Development of Technical Specifications for Research Reactors," states:
"(4) dissemination, review, and approval of minutes in a timely manner."
Prior to relicensing, the third paragraph of MURR TS 6.1.d stated:
"The Reactor Advisory Committee shall meet at least once during each calendar quaiter."
The third paragraph of current MURR TS 6.2 .b states:
"A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet at least once during each calendar quarter."
During relicensing, the TS requirement for the RAC meeting frequency changed from:
"The Reactor Advisory Committee shall meet at least once during each calendar quarter."
To:
"A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet at least once during each calendar quarter."
Section 6.2.2 of American National Standard ANSI/ANS-15 .1-2007, "The Development of Technical Specifications for Research Reactors," states:
"( 1) meeting frequency: not less than once per calendar year and more frequently as circumstances warrant, consistent with effective monitoring of facility activities;"
3.0 Justification for Change The MURR RAC meets four (4) times a year - each calendar quarter per TS 6.2.b. Additionally, there are four (4) active subcommittees of the RAC - Reactor Safety Subcommittee, Isotope Use Subcommittee, Reactor Safety Procedure Review Subcommittee, and Isotope Use Procedure Review Subcommittee - that all meet at least quarterly. Since instituting the new TSs at the beginning of last year, it has been an extreme burden to reactor facility staff to disseminate meeting minutes of five (5) committees within three (3) months after the meetings. The previous meeting minutes are always presented to the RAC at the next regular meeting, but the next meeting might not fall within that three (3) month window. Changing the requirement from three (3) to four (4) months would lessen this burden and still allow the meeting minutes to be distributed at the next scheduled meeting. This change would also meet the intent of ANSI/ANS-15 .1-2007 such that the minutes are distributed " in a timely manner."
As mentioned above, the RAC meets at least once each calendar quarter, as do all four (4) subcommittees.
Two (2) of the subcommittees consist partly of non-MURR personnel - knowledgeable members of the public, University of Missouri (MU) faculty, and MU staff. Scheduling these quarterly subcommittee Page 2 of 4
Enclosure 2 - Basis for the Requested Change to Technical Specification 6.2 meetings can be difficult at times in order to accommodate the MU academic calendar, and it has proven best to schedule these meetings in the months of March, June, September, and December of each year.
However, there are still times in which it is difficult to schedule a quorum of members even within these regular months. Removing the word "calendar" from the existing TS will allow for greater scheduling flexibility, thus ensuring as many RAC members as possible can attend each meeting. Though TS 1.41 does not apply to Administrative Controls, MURR would still abide by this same frequency requirement -
TS 1.41 .d, "Quarterly - interval not to exceed 4 months" - for the quarterly meeting requirement of TS 6.2.b. This change would also meet the intent of ANSI/ANS- 15.1-2007 such that the RAC will meet "not less than once per calendar year ... consistent with effective monitoring of facility activities."
4.0 Conclusion MURR feels that the requested change to TS 6.2.b is consistent with the guidance of ANSI/ANS-15.1-2007, does not decrease facility safety, relieves a large burden of disseminating minutes of five (5) committees in a short timeframe, and provides greater flexibility in scheduling RAC meetings, thus increasing the average attendance at the RAC meetings.
5.0 Proposed Revision to Technical Specification 6.2 The second paragraph of Specification 6.2.b currently states:
"The RAC and its subcommittees shall maintain minutes of meetings in which the items considered and the committees' recommendations are recorded. Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within three (3) months after the meetings. Independent actions of the subcommittees shall be reviewed by the parent committee at the next regular meeting. A quorum of the committee or the subcommittees consisting of at least fifty percent of the appointed members shall be present at any meeting to conduct the business of the committee or subcommittee. Additionally, reactor facility staff shall not constitute greater than fifty percent of the quorum for a meeting of the RAC. Reactor facility staff shall not constitute a majority of the RAC. The RAC shall meet at least quarterly."
The second paragraph of Specification 6.2.b will be revised as follows:
"The RAC and its subcommittees shall maintain minutes of meetings in which the items considered and the committees ' recommendations are recorded. Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within four (4) months after the meetings. Independent actions of the subcommittees shall be reviewed by the parent committee at the next regular meeting. A quorum of the committee or the subcommittees consisting of at least fifty percent of the appointed members shall be present at any meeting to conduct the business of the committee or subcommittee. Additionally, reactor facility staff shall not constitute greater than fifty percent of the quorum for a meeting of the RAC. Reactor facility staff shall not constitute a majority of the RAC. The RAC shall meet at least quarterly- not to exceed four (4) months ."
Page 3 of 4
Enclosure 2 - Basis for the Requested Change to Technical Specification 6.2 The third paragraph of Specification 6.2.b currently states:
"A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet at least once during each calendar quarter."
The third paragraph of Specification 6.2.b will be revised as follows:
"A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet quarterly."
Page 4 of 4
Enclosure 3 UNIVERSITY OF MISSOURI RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No. : Docket No. 50-186, License No. R-103
- 3. 7 Radiation Monitoring Systems and Airborne Effluents - Continued
- b. The maximum discharge rate through the ventilation exhaust stack shall not exceed the following:
Max. Concentration MH. GaetFalled Type of Averaged Over lestaetaeeaus Release Radioactivitv One Year GaeeeetFatiae Particulates and halogens with AEC AeG half-lives greater than 8 days All other radioactive isotopes 350 AEC ~.~OQ ABG AEC = Air Effluent Concentration as listed in Appendix B, Table 2, Column 1 of 10 CFR 20, " Standards for Protection Against Radiation."
- c. An environmental monitoring program shall be carried out and shall include, as a mmunum:
(1) Analysis of samples from surface waters from the surrounding areas, and vegetation or soil, AND (2) Placement of film badges, thermoluminescent dosimeters, or other devices at control points.
Bases:
- a. The radiation monitors provide information of an impending or existing danger from radiation so that corrective action can be initiated to prevent the spread of radioactivity to the surroundings and so that there will be sufficient time to evacuate the facility should it be necessary to do so.
Isolation of the reactor containment building at 10 times the normal previously established radiation levels is necessary to allow for sample handling within the reactor pool or when removing samples from the pool. Normal pool surface radiation levels are approximately 20 mR/h while those at the containment building exhaust plenum are around 0.15 mR/h. Operational experience has demonstrated that the 10 times factor provides sufficient margin to minimize inadvertent reactor scrams without allowing for the potential of unacceptable exposure rates to personnel in containment. Ten times the routine dose rates equate to 200 mrem at the bridge monitor and 1.5 mrem at the exhaust plenum. Dose rates at this level do not constitute an unreasonable risk and would not go unidentified for any significant period of time.
A-30
Enclosure 3 UNIVERSITY OF MISSOURI RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No.: Docket No. 50-186, License No. R-103 3.7 Radiation Monitoring Systems and Airborne Effluents - Continued
- b. For the purposes of Specification 3.7.b, air effluents for particulates and halogens with half-lives greater than 8 days are limited to the Air Effluent Concentrations (AEC) without the inclusion of a dilution multiplier to minimize any chance of reconcentration at the receptor site resulting in doses in excess of the direct exposures via air concentrations. Data from Soldat, JD (Health Physics 9, p. 1170, 1963), suggest a reconcentration factor of approximately 400 for the Iodine-131 milk/man pathway; however, dilution of the stack effluent to the nearest residence due north of MURR (760 meters), the prevailing wind direction, is approximately 1900, thus giving a safety factor (ratio) of 4.75 . This value is also conservative in that the wind blows from 360 degrees around MURR throughout the year and thus this value represents a worst case scenario to only the maximally exposed receptor point.
For Argon-41, the primary air effluent from MURR, dispersion calculations are based on standard reference material and experimental data obtained at the reactor showing that concentrations under average conditions will be 0.008 of the AEC limits in the unrestricted area surrounding the reactor facility. Also, dilution factors under conservative conditions are in the range of 5 x 104 under both average and stable conditions at ground level from the facility building. For normal short bUf'st releases at the facility which are five to ten seconds in dUf'ation and ocCUf' on an average of ten times per day five days per week the effect on the average concentration is less than 1% v,hen averaged over a one day period.
It is concluded that these concentrations as specified will not constitute a hazard to the health and safety of the public.
- c. Collecting and analyzing water, and soil or vegetation samples will provide information that environmental limits are not being exceeded. Film badges, thermoluminescent dosimeters, or other devices placed at control points provide a measurement of radiation. The continuation of the environmental program will verify that operation of the facility presents no significant risk to the health and safety of the general public.
A-31
Enclosure 3 UNIVERSITY OF MISSOURI RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No .: Docket No. 50-186, License No. R-103 6.2 Review and Audit - Continued
- b. The RAC may appoint subcommittees consisting of knowledgeable members of the public, students, faculty, and staff of MU when it deems it necessary in order to effectively discharge its primary responsibilities. When subcommittees are appointed, these subcommittees shall consist of no less than three (3) members with no more than one (1) student appointed to each subcommittee. The subcommittees may be authorized to act on behalf of the RAC .
The RAC and its subcommittees shall maintain minutes of meetings in which the items considered and the committees ' recommendations are recorded.
Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within three-four (~ months after the meetings.
Independent actions of the subcommittees shall be reviewed by the parent committee at the next regular meeting. A quorum of the committee or the subcommittees consisting of at least fifty percent of the appointed members shall be present at any meeting to conduct the business of the committee or subcommittee. Additionally, reactor facility staff shall not constitute greater than fifty percent of the quorum for a meeting of the RAC. Reactor facility staff shall not constitute a majority of the RAC. The RAC shall meet at least quarterly - not to exceed four (4) months.
A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet at least OHee duriHg eaeh ealeHdar quarterguarterly.
- c. Any additions, modifications or maintenance to the systems described in these Specifications shall be made and tested in accordance with the specifications to which the system was originally designed and fabricated or to specifications approved by the NRC.
- d. Following a favorable review by the NRC, the RAC, or the Reactor Facility Management, as appropriate, and prior to conducting any experiment, the Reactor Manager shall sign an authorizing form which contains the basis for the favorable review.
- e. Audits:
(1) Audits of the following functions shall be conducted by an individual or group without immediate responsibility in the area to be audited:
- 1. Facility Operations, for conformance to the Technical Specifications and license conditions, at least annually; 11 . Operator Requalification Program, for compliance with the approved program, at least every two (2) years; A-68
Enclosure 4 UNIVERSITY OF MISSOURI RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No.: Docket No. 50-186, License No. R-103 3.7 Radiation Monitoring Systems and Airborne Effluents - Continued
- b. The maximum discharge rate through the ventilation exhaust stack shall not exceed the following:
Max. Concentration Type of Averaged Over Radioactivitt One Year Particulates and halogens with AEC half-lives greater than 8 days All other radioactive isotopes 350 AEC AEC = Air Effluent Concentration as listed in Appendix B, Table 2, Column 1 of 10 CFR 20, "Standards for Protection Against Radiation ."
- c. An environmental monitoring program shall be carried out and shall include, as a mm1mum:
(1) Analysis of samples from surface waters from the surrounding areas, and vegetation or soil, AND (2) Placement of film badges, thermoluminescent dosimeters, or other devices at control points.
Bases:
- a. The radiation monitors provide information of an impending or existing danger from radiation so that corrective action can be initiated to prevent the spread of radioactivity to the surroundings and so that there will be sufficient time to evacuate the facility should it be necessary to do so.
Isolation of the reactor containment building at 10 times the normal previously established radiation levels is necessary to allow for sample handling within the reactor pool or when removing samples from the pool. Normal pool surface radiation levels are approximately 20 mR/h while those at the containment building exhaust plenum are around 0.15 mR/h. Operational experience has demonstrated that the 10 times factor provides sufficient margin to minimize inadvertent reactor scrams without allowing for the potential of unacceptable exposure rates to personnel in containment. Ten times the routine dose rates equate to 200 mrem at the bridge monitor and 1.5 mrem at the exhaust plenum. Dose rates at this level do not constitute an unreasonable risk and would not go unidentified for any significant period of time.
A-30
Enclosure 4 UNIVERSITY OF MISSOURJ RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No.: Docket No. 50-186, License No. R-103 3.7 Radiation Monitoring Systems and Airborne Effluents - Continued
- b. For the purposes of Specification 3.7.b, air effluents for pru1iculates and halogens with half-lives greater than 8 days are limited to the Air Effluent Concentrations (AEC) without the inclusion of a dilution multiplier to minimize any chance of reconcentration at the receptor site resulting in doses in excess of the direct exposures via air concentrations. Data from Soldat, JD (Health Physics 9, p. 1170, 1963), suggest a reconcentration factor of approximately 400 for the Iodine-131 milk/man pathway; however, dilution of the stack effluent to the nearest residence due north of MURR (760 meters), the prevailing wind direction, is approximately 1900, thus giving a safety factor (ratio) of 4.75. This value is also conservative in that the wind blows from 360 degrees around MURR throughout the year and thus this value represents a worst case scenario to only the maximally exposed receptor point.
For Argon-41, the primary air effluent from MURR, dispersion calculations are based on standard reference material and experimental data obtained at the reactor showing that concentrations under average conditions will be 0.008 of the AEC limits in the unrestricted area surrounding the reactor facility. Also, dilution factors under conservative conditions are in the range of 5 x 104 under both average and stable conditions at ground level from the facility building.
- c. Collecting and analyzing water, and soil or vegetation samples will provide information that environmental limits are not being exceeded. Film badges, thermoluminescent dosimeters, or other devices placed at control points provide a measurement of radiation. The continuation of the environmental program will ve1ify that operation of the facility presents no significant risk to the health and safety of the general public.
A-31
Enclosure 4 UNIVERSITY OF MISSOURI RESEARCH REACTOR Date: TECHNICAL SPECIFICATIONS Amendment No .: Docket No. 50-186, License No. R-103 6.2 Review and Audit - Continued
- b. The RAC may appoint subcommittees consisting of knowledgeable members of the public, students, faculty, and staff of MU when it deems it necessary in order to effectively discharge its primary responsibilities. When subcommittees are appointed, these subcommittees shall consist of no less than three (3) members with no more than one (1) student appointed to each subcommittee. The subcommittees may be authorized to act on behalf of the RAC.
The RAC and its subcommittees shall maintain minutes of meetings in which the items considered and the committees' recommendations are recorded .
Dissemination of the minutes to the Office of the Chancellor, the RAC and its subcommittees shall be done within four (4) months after the meetings.
Independent actions of the subcommittees shall be reviewed by the parent committee at the next regular meeting. A quorum of the committee or the subcommittees consisting of at least fifty percent of the appointed members shall be present at any meeting to conduct the business of the committee or subcommittee. Additionally, reactor facility staff shall not constitute greater than fifty percent of the quorum for a meeting of the RAC. Reactor facility staff shall not constitute a majority of the RAC. The RAC shall meet at least quarterly - not to exceed four (4) months.
A meeting of a subcommittee shall not be deemed to satisfy the requirement of the parent committee to meet quarterly.
- c. Any additions, modifications or maintenance to the systems described in these Specifications shall be made and tested in accordance with the specifications to which the system was originally designed and fabricated or to specifications approved by the NRC.
- d. Following a favorable review by the NRC, the RAC, or the Reactor Facility Management, as appropriate, and prior to conducting any experiment, the Reactor Manager shall sign an authorizing form which contains the basis for the favorable review.
- e. Audits:
(1) Audits of the following functions shall be conducted by an individual or group without immediate responsibility in the area to be audited:
- 1. Facility Operations, for conformance to the Technical Specifications and license conditions, at least annually;
- 11. Operator Requalification Program, for compliance with the approved program, at least every two (2) years; A-68