ML20058Q106

Forwards Revs to Oregon State Univ Radiation Ctr & Triga Reactor Emergency Response Plan, Per 10CFR50.54(q).Revs Needed as Result of NRC Rev of 10CFR20 & Will Be Effective 940101

ML20058Q106
Person / Time
Site:	Oregon State University
Issue date:	12/16/1993
From:	Johnsoon A Oregon State University, CORVALLIS, OR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058Q109	List: ML20058Q106
References
NUDOCS 9312280078
Download: ML20058Q106 (9)

Text

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Oarcos Smt Usivrasirr Radiation Center A100 Corva!!is, Oregon 97331 5903 Telephone 503 737 2341I'as 503 737 0480 December 16,1993 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Reference:

Oregon State University TRIGA Reactor (OSTR),

Docket No. 50-243, License No. R-106 l

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Subject:

10 CFR 50.54(q) Report of Changes to the OSTR Emergency Response Plan Which Do Not Decrease the Effectiveness of the Plan Gentlemen:

The OSTR Emergency Response Plan was recently reviewed to determine whether any changes to the plan were necessary in conjunction with our implementation of the j revisions to 10 CFR Part 20. It was concluded that a number of changes would be j required and this letter represents our formal report of those changes in accordance with i 10 CFR 50.54(q). Based on our evaluation of the revisions, which was conducted under the provisions of 10 CFR 50.59, we have concluded that none of the changes reduce the plan's emergency response effectiveness. A copy of the 50.59 evaluation is enclosed, and in Attachment A to the 50.59 document we have listed all of the revisions to the Emergency Response Plan.

All of the changes to the plan, and the 10 CFR 50.59 evaluation supporting the changes, have been reviewed and approved by the OSTR Reactor Operations Committee.

As you can see from the information provided, most of the changes were made to ensure compliance with the revised 10 CFR Part 20. In addition to the plan itself, a number of conforming changes were made to the Emergency Response Plan implementing Procedures '

(ERIPs) in order to keep them up to date.

To make it convenient to update your copy (s) of our plan, At'achment B includes all of the current replacement pages for the plan. If you have any concerns or questions about the reported changes to the OSTR Emergency Response Plan, please let me know.

l Yours sincerely, l

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A.d . Johnson Dire r i nworki,coffscested SO54alut.194 cc: See Page 2

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i__________-.

l cc: Mr. Al Adams, Project Manager, Non-Power Reactor, Decommissioning, and Environmental Projects Directorate, U.S. Nuclear Regulatory Commission, M.S. OWFN 11-B-20, Washington, D. C. 20555 Regional Administrator, USNRC, Region V Mr. Lawrence Cohen, USNRC, Emergency Preparedness Branch, Washington, D.C. 20555 Oregon Department of Energy, Salem. Oregon ATTN: Mr. David Stewart-Smith Prof. S. E. Binney, Chairman, Reactor Operations Committee Prof. B. Dodd, Reactor Administrator l Prof. J. F. Higginbotham, Senior Health Physicist l

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l Rev.11/90 OSU TRIGA Reactor (OSTR)

Changes, Tests and Experiments Evaluated Under the Provisions of 10 CFR 50.59 NUMBER: 93-4 DATE: November 19,1993 TITLE: Revisions to the Radiation Center and OSTR Emergency Response Plan made under the provisions of 10 CFR 50.54 (q).

DESCRIPTION A number of changes to the emergency response plan are needed as a result of the NRC's revision of 10 CFR 20. The effective date for these revisions will be January 1,1994, when the OSU Radiation Center implements the revised Part 20. During the review of the emergency plan, it was recognized that a number of other minor changes were also needed and, therefore, these changes are being made at this time. All changes are detailed in Attachment A. All changes are being made under the provisions of 10 CFR 50.59 (q) and inerefore do not reduce the emergency response effectiveness of the plan.

SAFETY EVALUATION Deletion of the paragraph in Section 3.1.4 relating to the Fire Department providing training l for Radiation Center personnel reflects the fact that a formalization of this training in the  !

emergency plan is no longer needed. Key Radiation Center personnel have been sufficiently i trained so that they can provide instruction to other Center staff. The OSU Radiation Center maintains a close relationship with the Corvallis Fire Department with various informal training opportunities provided both by and for the Fire Department. Deletion of this paragraph will not reduce the effectiveness of Radiation Center staff response to fires.

Deletion of Section 3.2.2 c)is being made to avoid confusion with respect to who authorizes l emergency doses in excess of the occupational limits. In several other places in the plan it states that the Emergency Director will authorize such doses with the concurrence of the Campus Radiation Safety Officer, if available. This is the correct wording, since there will l always be a person fulfilling the duties of the Emergency Director, whereas the Campus RSO may not always be available.

Changes to Sections 4.1, and 7.4.3, and Table 5.1 are being made to delete reference to quarterly dose limits. With the revised Part 20 there are no quarterly limits. The new wording l

achieves the same result by using the phrase "any applicable occupational dose simit". This takes care of the total effective dose equivalent, shallow dose equivalent and eye dose equivalent limits, as well as allowing for other potential regulatory changes.

Changes to emergency action levels for Class I and Class ll emergencies are being made to make allowance for the fact that the revised Part 20 does not deal with MPCs, but does use the concept of effective dose equivalent. There are two action levels in the existing plan which have MPC criteria as well as whole body dose equivalent criteria. It is now redundant to have both the airborne concentration and whole body dose criteria since the internal and external hazard can now be combined by setting a total effective dose equivalent (TEDE) emergency action level. Since the whole body weighting f actor is unity, the appropriate TEDE action levels are the same numerically as the previous whole body dose values of 15 mrem and 75 mrem for Class I and Class ll, respectively.

A further change in the same emergency action levels involves replacing the words "at the site boundary" with "in the unrestricted area". Under most conditions involving a release of airborne radioactive material, the largest dose will not occur at the site boundary, but at some point further away. This is due to the closeness of the site boundary to the point of release.

The revised action level statement is therefore more conservative than the old one.

Most references to in-vivo whole body counting at the Trojan nuclear power plant were deleted during a previously approved change to the emergency plan. However, one reference which was overlookedd [is now deleted. The previous evaluation applies.

The changes from "MPC" to "DAC" in Sections 7.1.2, 7.2.2, and 7.3.2 are appropriate because they occurin the context of stating that a certain value is a small fraction of the MPC (DAC). Clearly, changing from MPC to DAC does not change such statements at all.

The addition of the license or docket number on the information reported (Sections 7.2.1 and 7.3.1) makes it easier for the USNRC to find the relevant file when they are notified. This may help them provide a quicker response, and therefore, may have a positive implication on safety.

Deleting " Region V" from the phrase " Region V Regional Administrator" in Section 10.3 does not have any safety implications, and prepares the way for planned changes in the USNRC regional structure.

As usual, opportunity is being taken to update the representative emergency equipment inventories in Appendix B during this current plan change.

The changes described above were reviewed and approved by the Reactor Operations Committee (ROC) prior to being implemented. ROC approval included a review of this evaluation and the Committee's conclusion that the changes do not require a change in the OSTR Technical Specifications, do not constitute an unreviewed safety question as defined in 10 CFR 50.59(a)(2) and do not reduce the emergency planning ef fectiveness of the existing plan. This evaluation also included a review of applicable radiation protection aspects, which were found to be consistent with the Radiation Center's commitment to ALARA.

CONFORMING PROCEDURAL CHANGES The above emergency plan revisions require several changes to the Emergency Response Plan implementing Procedures (ERIPs). These changes are also included in Attachment A. In l addition, a few other modifications to the ERIPs have been made to bring them up to date, i

to make them clearer, or to make them more effective. ERIP changes do not require a formal 10 CFR 50.59 safety analysis.

l APPROVALS The following signatures indicate review and approval by the Reactor Operations Committee l and review by licensed operators. If any ROC member does not completely concur with or understand the proposed change / test / experiment then that member should hold this form unsigned and notify the ROC Chairman. The matter will then be discussed at the next meeting of the Committee. If any individual ROC member is unable to sign the sheet due to absence or illness this will be so noted.

S. E. Binney * + A. G. Johnson

• D. L. Amort ' .

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- y J. C. Ringle

• L_h d 6.

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T. V. Anderson' + ., 6 (M A. H. Robinson" bod <3tdthEj-h5 B. Dodd * + _h \ R. A. Schmitt

• gu . N//

A. D. Hall + -

H. Warnes

• Ws J. F. Higginbotham * +

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• Chairman, Reactor Operations Committee (Signs Last)  !

' Member, Reactor Operations Committee

+ Licensed Operator I

Attachment A: Revisions to the OSU Radiation Center and TRIGA Reactor Emergency Response Plan - January 1994

, Cover Page l

Change the last revision date to " January 1994".

i All Changed Pages Add or change the revision date to "1/94".

Page 3-3, Section 3.1.4  ;

Delete the third paragraph which begins: "The Corvallis Fire Department also assists in the training. ".

Page 3-4, Section 3.2.2 Delete item c) and relabel d) and e) to c) and d) respectively.  !

Pages 4-1 and 4-2, Section 4.1 B

Change item c) to:

"Any person receiving an estimated radiation dose equivalent greater than any ,

l occupational dose limit from sources external to the body, including doses caused by skin i contamination."

l Change item d) to:

l l "Any person becoming internally contaminated with radioactive material sufficient to give i a dose equivalent in excess of any applicable occupational dose limit."

Page 4-3, Section 4.2 Change item d) to:

" Actual or projected radiological effluents with concentrations resulting in an unrestricted area total effective dose equiva'ent of 15 mrem accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Change the subsequent note to:

"The stack monitor will have alarmed, shut off the ventilation system and closed the isolation dampers long before this concentration levelis reached. However, the stack i

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monitor will continue to function and would be used to project radiological effluent realeases and direct radiation levels in the unrestricted area. Direct measurements with i portable survey meters would also be used to evaluate radiation levels in the unrestricted area."

Page 4-4, Section 4.3

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Change item c) to:

" Actual or projected radiological effluents with concentrations resulting in an unrestricted area total effective dose equivalent of 75 mrem accumulated in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."

Change the subsequent note to:

"Deterrnination of airborne effluent concentrations will follow the same process as described for a Class ! Emergency. Unrestricted area radiation levels will be determined by ,

j direct radiation measurements with portable survey meters." 3 l

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Pages 5-2, 5-3 and 5-4, Table 5.1 '

Change the emergency action levels and notes for Class 0, Class I and Class 11 Emergencies to read the same as those discussed above in Sections 4.1,4.2 and 4.3.  ;

Page 7-2, Section 7.1.2 {

l Delete item d) "In vivo counting at the Trojan nuclear plant." from the section headed i

" Personnel Contamination" l

Change "MPC" to "DAC" in both a) and b) of the section headed " Continuous Air Monitor or Stack Monitor Alarm".

i Pages 7-6 and 7-11, Sections 7.2.1 and 7.3.1 1

Change f) i) to:

"Name, title and telephone number of caller, location of emergency, and license or docket number."

Pages 7-7 and 7-13, Sections 7.2.2 and 7.3.2 Change "MPC" to "DAC" in both a) and b) of the sections headed " Elevated Radiological Effluent Discharge to the Unrestricted Area".

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f Page 7-16, Sections 7.4.1 and 7.4.2 -

Change "whole body dose equivalent" to " total effective dose equivalent".

I Page 7-16, Section 7.4.3  ;

Delete " quarterly". f Page 10-2, Section 10.3  ;

Delete " Region V" from c).

i Appendix B i

Update the representative emergency equipment inventories with the lists dated 1/94.  ;

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l Attachment B OSTR Emergency Response Plan Replacement Pages t I

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