ML20098G676

Responds to NRC Re Violations Noted in Emergency Preparedness Insp Rept 50-020/84-01.Corrective Actions:Nrc Guidance Re Revs to Emergency Plan Requested.Emergency Operating Procedures Revised

ML20098G676
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	07/25/1984
From:	Bernard J, Lisa Clark MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20098G669	List: ML20098G676 ML20098G679
References
NUDOCS 8410050318
Download: ML20098G676 (11)

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NUCLEAR REACTOR LABORATORY d AN INTERDEPARTMENTAL CENTER OF MASSACHUSETTS INSTITUTE OF TECHNOLOGY

%T O.K. HA8 LING 138 Albany Street Cambridge, Mass. 02139 L. CLARK, JR.

Director. (617) 253- Director of Reactor Operations July 25, 1984 Regional Administrator, Region I Division of Engineering and Technical Programs United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 ATTN: Thomas T. Martin, Director Gentlemen:

Subject:

Appraisal Report No. 50-20/84-01 The Massachusetts Institute of Technology hereby submits this reply to the findings contained in appraisal report #50-20/84-01 which was issued by your staff on 15 June 1984 following an on-site emergen-cy prepsredness appraisal during the period 3-6 April 1984. It should be noted that MIT had by its letter of 12 July 1984 requested an ex-tension of the 30 day reply requirement to 25 July 1984.

Responses to the specific findings noted on the appraisal are contained in Appendix A and B to this letter.

MIT requests further guidance from the Connission with regard to the Appraisal Report's significant finding concerning the need to develop emergency action levels (EALs) based on specific instrument

• readings for each of the four classification levels specified in the Emergency Plan. The presently approved MIT Emergency Plan and its implementing procedures are conservatively based on nuclides with low MPC's, as described in the plan and in Appendix A to this letter. In order to comply with the Appraisal Report's finding, we believe that it will be necessary to revise not only the procedures but also the basis for the plan by assuming an emergency where nuclides with higher MPC's are released, such as fission product gases. It appears that EALs for specific instruments could then be developed. However, before MIT undertakes to revise its Emergency Plan in this manner and, subsequently, to resubmit it to the Commission for reapproval, guidance is requested concerning the desirability of this approach.

It should be noted that basing the Plan on low MPC nuclides does not preclude reassessment of the emergency clessification once the necessary evidence has been obtained, e.g. absence of alpha-emitters or identification of the airborne nuclides in a release (please see Section 4.7.2.6, Reassessment Actions, in the Emergency Plan and also Appendix A of this letter).

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. , . :s r . It should further be noted, as explained in Section 4.6 of the

- Emergency Plan, that _ the design basis accident for the MITR-II predicts off-site doses that are less than the general emergency

" action levels (Standard ANSI /ANS-15.16) and, hence, consideration is being given to dropping that classification from the Emergency Plan.

However, the .former MIT Reactor Emergency Plan, which postulated

general emergency dose levels off-site, did-stipulate corresponding arrangements. for protective actions off-site. Hence, those features and' an energency planning zone (100 meter radius) have been retained in the present plan, but consideration is being given to changing the

._ name from general' emergency to a sub-category of site area emergency.

The . purpose of this change would be to emphasize that a general emergency. is not credible for the MIT Reactor while, at the sane' time, retaining conservative- preparatory features that were built into the .

. MITR Emergency Plan when it was first'~ developed prior to startup of I

-the MITR and that have subsequently been reviewed and approved by City l of' Cambridge authorities.

Sincerely, 6 ({

gohn A. Bernard Superintendent MIT Research Reactor

f. r Lincoln Clark, Jr.

Director of Reactor Operations

Enclosures:

(1) Appendix A (2) Appendix B cc: USNRC-0MIPC USNRC-DMB Chief, Emergency Preparedness Licensing Branch MITRSC (With Appraisal Report)

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Appendix A

Significant Emergency Preparedness Findings 1.. REALS'for Each Classification Level MIT has had a radiological emergency plan. in effect since the inception of the MIT Research Reactor in the late 1950s. It has

'always been MIT's policy to (1) base that plan's implementing criteria on very conservative assumptions and (2) provide procedural approval

.for relaxing those _ conservative assumptions, if, during the course of

.an ' emergency,' physical evidence to the contrary were obtained. For example, if an implementing criterion were . based on an alpha emitting isotope and actual measurements showed that no alpha radiation was present,-that criterion ~would be re1 axed. In accordance with thia

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. policy, the . EALs for the present MITR~ Emergency Plan (the one approved in its entirety' by - the USNRC on 06/24/83) were based on particulate releases with MPCs of 6+10-14 pCi/ml and gaseous releases with MPCs lof 1+10-10 pCi/ml. These MPCs correspond to the most limiting

' s it'uati ons listed in 10 CFR 20 for isotopes ' that could be 2 reactor produced. s EALs for a general emergency were then derived

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- using those NPCs and data on the characteristics of the NET Reactor's radiological instruments. (Refer to section 4.7.2 of the emergency splan.). Having established those EALs, it was not possible to extend the correlation of the MITR's effluent . monitor readings - with of fsite dose calculations to the other classes of emergencies because, as

, shown on'p.13 of.section 4.7.2 of the plan, the resulting EALs would

- be many times less than background. After reviewing this problem, it was concluded that the safest, most effective solution would 'be to continue present MITR ' policy which was to maintain written procedures at the AOP (abnormal operating. procedures) level that'(1) required investigation of any abnormal radiation' level and (2) required a

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reactor shutdown prior to levels' indicative of an " unusual event" being attained. These procedures are written, for example, in terms of f the activity of the purge gas that is swept across the surface of thescore tank.

The significant finding reported by appraisal report #50-20/84-01

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is that the MITR does not have EALs corresponding to the event, alert, orisite emergency levels. The only viable method for obtaining such

EALs is to substantially . alter the basis of the MITR emergency plan.

p That is, changing' the procedures to include EALs for the three lesser t emergency classes is contingent .upon first changing the source term

- used in the basis ' 'of ' the plan. Specifically, rather than implement

- the plan on the basis of the most limiting isotopes and then reassess the need for continuing an emergency response once the isotopes

". involved have been identified, it will be necessary to base the plan

! on the isotopes that would be most likely to be released.

Accordingly, it'. is necessary to characterize the source term. It should be noted that no ' guidance was provided on the source term in I

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^, i NUREG-0849. lAlso, given that this will constitute a major change in the plan = that was submitted to the NRCrin Sept. 1982, it will be necessary to resubmit 1 the revised ' plan and obtain approval for the

. revisions.

'A4 : regards source terms, it is-a common arsumption that various

. iodine isotopes are the most likely to be released in significant quantities.. However, recent data has shown that this lis not the case, especially if .a core remains covered with water or is cooled by spray. ' Much of the iodine will then be retained in the form of a salt, cesium iodide.. This result is significant to the MIT Reactor

?because .(1) all ' core tank penetrations are above the core (2) the core

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tank is contained within two other concentric tanks and (3) there is

'an ECCS system available to spray water onto the core. Hence, it is not considered credible that the core would be uncovered and it is unlikely that any iodine would be released from the core tank.

Furthermore, even -if iodine were released from the core tank, any Eventing of - the surrounding containment building would be through charcoal filters that are at least 95% efficient for iodine.

Accordingly, there is no logical reason for basing the MITR plan on iodine's MPC.

A' review of fission product yield data and isotope half-lives

.suggest that xenon-135 is the isotope most likely to be released since it .is an inert gas and, counting all'aethods of production, is pro-

'duced iniquantity. ' Xenon-135 -decays- to cesium-135 which is particu-

-late in nature. . Preliminary calculations have been made to obtain

' EALs for the MIT Reactor based on gaseous releasesJ of xenon-135 and particulate releases of cesium-135. These- calculations .show that the MITR's' effluent instruments would indicate suffi6iently above back-ground but on-scale for the event, alert, and, in some cases, site criteria also.- No instruments would be on-scale 'for the general emergency situation. Mowever, this may not be necessary since, as s noted by the NRC staff during the appraisal, the general emergency 1 category.could be: deleted.. We currently have this under consideration.

If NRC guidance requires revising the emergency plan, MIT proposes to do -the following:

(a) Retain the existing abnormal operating procedures that require a' reactor shutdown before' effluent levels permitted by an ' event have been reached.

(b) ~ Rewrite the basis of the MITR emergency plan with fission product gases and their decay products being the nuclides of concern.

(c) Develop EALs for the event, alert, and site situations based on .the MPCs for the fission product gases and their decay products.

(d) . Retain, but rename, the procedure for a general emergency.

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-i a-(e) Submit the 'ch.inges made tto the plan to the MIT Reactor Safeguards Committee (MITRSC).

(f)- If approved by thetMITRSC, submit the changes to the USNRC (Standardization and Special Projects Branch.)

(g) If. approved- by the USNRC, revise the E0P procedures and train personnel on the revised procedures.

Steps - (b)-(e) will require 180 days once additional guidance is 4

received from NRC. Given that the current plan required almost ten months for review by NRC, step (f) will probably require at least several months. Step (g) will require 180 days following completion

-of step (f).

It should be recognized that a revision of the basis of the emergency plan requires MIT ' Reactor Safeguards Committee approval and such a revision has not yet been discussed with-that committee.

Status of Item: Awaiting NRC guidance.

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Appendix B 1 Emergency Preparedness Improvement Items - Responses f.l ' Labeling of Procedure by Title of Responsible Individual

- Operating . Procedures 'for the MIT Reactor are divided into threee categories. .These . are :

- Standard Operating Procedures (SOPS)-

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Abnormal Operating Procedures (AOPs)

TEmergency. Operating Procedures (EOPs)

The SOPS ' were not , to our knowledge, included. in the appraisal.

Furthermore the. SOPS were and are already specific relative to the individual responsible. The AOPs consist of approximately 85 separate Lprocedures each specifying' precise actions to be taken in the event of a particular system malfunction. Each procedure lists "immediate" and

'" follow-up" actions. Section ~5.0 of the AOPs already contained a

- directive that the- console operator is responsible for performing the "immediate" action. A statement has been added ' to the ef fect that the

.shiftEsupervisor is responsible for -(1) verifying that the operator did carry out the "immediate" ~ action and .(2) performing or supervising the " follow-up"' action.. The EOPs are organized. in a manner similar to the . AOPs'. Section'4.4.4 of these procedures already provides guidance on individual' responsibilities - for performing .the actions required by the EOPs. - This guidance-has been made more specific by changing the opening paragraph to read:

The following: procedures provide the specific directions necess'ary for the implementation of the MITR Emergency Plan.

Regarding non-radiological procedures, the console operator is to perform the indicated "immediate action" and the shif t C supervisor is both to verify that the console operator has carried out the "immediate action" and to perform or supervise the " follow-up action". Regarding the radiological emergencies, responsibilities are indicated by title in the procedures. . Also, the senior NRC-licensed staff member on site is responsible for coordinating all actions in an emergency including all on-site and of f-site actions. (Note: This individual may be the shift supervisor.)

As far as the radiological procedures are concerned, these were, with two exceptions, already labeled with the title ' of the individual responsible for performing the action. The ' procedures (PM 4.4.4.14/

PM 4.4.4.15) for dealing with excess radiation at the site boundary ,

and a' release of airborne material were already organized as follows:

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Immediate Action .- Reactor Operator Immediate Action -

Shift Supervi,or Follow-Up Action -

On-Site' Activities Follow-Up. Action -

Off-Site Activities The word " activities" has ~ been changed to " supervisor". The two radiological procedures (PM 4.4.4.11 and 4.4.4.12) that concern building and containment evacuation are similarly organized. All sections of PM 4.4.4.11 and the "immediate action" of PM 4.4.4.12 were already labeled by title. The " follow-up action" of PM 4.4.4.12 has now been labeled as " Follow-Up Action - Shift Supervisor /RP0".

Status of Item: Ali. action to be ~ complete by 15 Aug.1984.

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2. -Incorporation ~of EALs The major ~ radiological emergency procedures are excess radiation at the site boundary resulting from a contained source (PM 4.4.4.14) and escape of airborne radioactive material from the containment building.(PM 4.4.4.15). These procedures each contain a brief section entitled '" Implementing Criteria" which lists the EALs. Specific EALs ,

for the ~ declaration of ' an event, - or an alert, or a site area emergency ,

have been added to PM 4.4.4.14. The same will be done with PM 4.4.4.15 once the significant finding listed in Appendix A of appraisal report #50 20/84-01 is resolved.

Regarding the other radiological procedures (e.g., containment

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evacuation and reactor reentry), EALs are not provided because these procedures. are performed either as a subpart of the major radiological emergencies or other emergency procedures for which EALs exist.

~ EALs identical to those used for PM 4.4.4.14, " Excess Radiation at the Site Boundary Resulting- from a Contained Source" have been incorporated in PM 4.4.4.11, "NW12 Evacuation".

Regarding the non-radiological emergencies, EALs were already

- listed in Table 4.7.3.4-1 of the plan. The information in this table

' has_ now been incorporated in the appropriate procedure.

Status of Item: . All action to be complete by 15 Aug.1984 except for incorporation of EALs in PM 4.4.4.15. This will be accomplished following resolution of the significant finding li'sted in Appendix A.

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3. Review Procedures _to Determine if Reference is Appropriate This discrepancy was the result of several typographical errors.

Several procedures referred to PM 4.4.1 when the proper reference was PM 4.4.4.15. This discrepancy was corrected during the course of the

. appraisal and reported to the appraisal team as having been corrected both-during the appraisal and at the exit interview.

Status of Item: All action complete.

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4. - Provide Several High Range Dosimeters within Containment Two high range (0-100 R) dosimeters have been placed in the emergency locker in the containment building. These have also been added to the inventory list for that locker.

Status of Item: All action to be complete by 15 Aug. 1984.

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5. Provide Guidance on Supplying Dosimetry to Medical Personnel A step has been added to the insediate action for a medical

. emergency to cover _this contingency. Dosimeters will be issued to responding medical personnel if the injury involves radiation exposure or contamination. This is to be accomplished without delaying transport of the injured party.

Status of Item: All action to be complete by Aug. 15 1984.

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