ML20108D805

Forwards Responses to Request for Addl Info, , Requesting Clarification to Evaluate Emergency Plan Revs Submitted on 951220

ML20108D805
Person / Time
Site:	University of Missouri-Columbia
Issue date:	05/01/1996
From:	Mckibben J MISSOURI, UNIV. OF, ROLLA, MO
To:	NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9605090050
Download: ML20108D805 (4)

Text

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Research Reactor Center

, Research Park Columbia, Missouri 6.5211 Telephone (573) 882-4211 FAX (5731882=3443 UNIVERSITY OF MISSOURI-COLUMBIA l

May 1,1996 Director of Nuclear Reactor Regulation ATrN: Document Control Desk Mail Station PI-37 U. S. Nuclear Regulatory Commission l Washington,DC 20555 l

REFERENCE:

Docket 50-186 University of Missouri Research Reactor License R-103 l SUBJECF: Responses to Request for Additional Information dated April 2,1996 The University of Missouri Research Reactor (MURR) provides the following responses to the Nuclear Regulatory Commission letter of April 2,1996, requesting additional information and clarification to evaluate the Emergency Plan revisions submitted by MURR on December 20,1995.

The two requests for information and our responses are attached. If you have any questions l concerning our responses, please contact me at (573) 882-5203 or Charlie McKibben at l

(573) 882-5204. i Sincerely, ENDORSEMENT

Reviewed and Approve

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Walt A. Meyer Jr. J. Charles McKibben j Reactor Manager Associate Director l bjb xc: Mr. Alexander Adams,Jr.

Sr. Project Manager, NRR/PDNP y1 Attachment SLA h4lth$ }{;

l CHRISTINEM.ERRANTE' '

Notary Public-Notan Seal STATE OFMISSOURI Boone County

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information Reauest #1:

1. Demonstrate that the EAL in the revised Emergency Plan meets the intent of the Commission.  !

l Response-  !

In our letter of December 20,1995, regarding notification of changes to the MURR Emergency a i

Plan, we submitted the following Emergency Action Level (EAL) for the Site Area Emergency

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classification involving TRUMP-S materials: j

" Fire in which more than 3 grams of TRUMP-S materials (americium, neptunium, plutonium) are involved." j The following paragraphs will demonstrate that this EAL meets the intent of the Commission i order to clarify that "either a prolonged fire or explosion within the facility that can result in a release of radioactivity that could cause exposures of the public or staff approaching I rem whole body " or a "significant release possibly approaching EPA PAG levels" of such materials would constitute a Site Area Emergency (CLI-95-01 as modified by CLI-95-08).

The i?AL was developed using the rationale described in NUREG-0849, Standard Review Plan for Review and Evaluation of Emergency Plans for Research and Test Reactors (p. I1). This mference indicates that EALs should be based on actual or potential radiological exposures and should 1 describe specific instrument readings, observations, orjudgements that will be used to initiate enwrgency measures. The technical basis for the EAL, the projected exposure at the nearest site j boundary for a fire involving 3 grams of americium-241, is described in the response to information I request #2.

The EAL describes the specific observation and judgment that is requimd to classify an event involving TRUMP-S materials as a Site Area Emergency, specifically if more than 3 grams of l TRUMP-S materials are involved in a fire.

The MURR materials license which controls the TRUMP-S experiment requires a very strict inventory control of the TRUMP-S materials. The locations of these materials in inventoriable quantities is limited to the Alpha Laboratory, storage in the fuel vault, or infrequently in transit between these two material balance areas. The mass of TRUMP-S materials at each location is the most readily available information one could access in the event of a fire to determine a potential source term for projected radiological exposures.

If more than 3 grams of TRUMP-S materials were involved in a fire a Site Area Emergency would be initiated based on the potential projected exposure its dispersal could present at the site boundary. If less than 3 grams of TRUMP-S materials were involved in a fire an Alen classification would be initiated. If no TRUMP-S materials were involved in a fire, the appropriate emergency classification

would be detemiined by other EAL's. The Site Area Emergency EAL is consistent with the Commission's statement in CLI-95-08, p. 5: " Site area emergencies are declared on the basis of predictive judgments based ou site conditions."

NUREG-1140, Regulatarv Analysis on Emergency Prenaredness for Fuel Cvele and Other Radinactive Materialc Licensees. places emphasis on quick decisions and prompt action in materials license accident release scenarios. For this reason, the descriptive cause of the Site Area Emergency initiating event was shortened to "fim involving more than 3 grams of TRUMP-S materials . . . . " so that any judgment regarding what is or is not a " prolonged fire" would not reduce the ability to quickly initiate protective actions.

This phrase regarding cause of the emergency is intended to be a direct and shorthand version of the "pmlonged fire or explosion" phrase much as the Commission intended at page 4 of CLI-95-08.

'Ihe licensed staff who are trained to implement the MURR Emergency Plan recognize that the term

" fire" would include " prolonged fire or explosion."

Information Reauest #2

2. Provide the technical basis or the analysis to show that 3 grams of TRUMP-S materials dispersed in a fire will result in a exposure of 1 rem whole body or approaching EPA PAG levels.

Response

l In CLI-95-11, paragray 2, the Commission states "the potential for significant exposures at the sits boundary is what triggers a Site Area Emergency." The technical evaluation that follows employs the Commission's computational methodology of the maximum expected off-site inhalation dose level

[CLI-95-01, p.121, footnote 125] and uses the worst case radionuclide (Am-241) as the source of the )

release. The calculation demonstrates that more than 3 grams of Am-241 have to be dispersed from a )

l fire to approach'l rem whole body exposure at the nearest site boundary. The " nearest site boundary" is defined in the MURR Emergency Plan [p. 22] as "the site boundary east-southeast of the MURR exhaust stack that represents the shortest distance between the stack and any site boundary for emergency planning purposes (approximately 400 meters).

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Computation of the Maximum Exnected Off-Site Inhalation Dose Level from a fire involving 3 ernms of Am-241 The fundamental equations from CLI-95-01, p.121, footnote 125 are:

Inhalation Dose (D(r)) = (DCF) . (B) + (X/Q) + (Q)

Release Quantity (Q) = (Qrotal) . (RF)

These are combined to yield the following expression of dose rate:

D(r) = (DCF) + (B) + (X/Q) + (Qrotal) . (RF)

D(r) = (530 rem /pci)(2.66 x 104 m3/sec)(5.8 x 104 sec/m3)(10.29 x 106 Ci) (10-3)

D(r) = 0.84 rem at 400 meters The five factors on the right side of the equation are derived below end are appropriate to reflect the dose at 400 meters from a release of 3 grams of Am-241:

= 530 rem /pCi (NUREG-1140 at 80, Table 13)

(DCF)

(B) = 2.66 x 104 m3/sec (NUREG-1140 at 12)

(Qrotal) = 10.29 Ci or 10.29 x 106 Ci (RF) = 10-3 (NUREG-1140 at 80, Table 13)

(X/Q) = 5.8 x 104 sec/m3 for r = 400 m [NUREG-1140 at 13 (for meteorology condition F,1 m/sec, no buoyancy)]

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